United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-4SQ/0-00-000
February 1990
Air
Quality Review Guidelines
For Post-1987 State
Implementation Plan (SIP)
Base Year Emission
Inventories
Draft Report

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United State*
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-450/0-00-000
February 1990
Air
Quality Review Guidelines
For Post-1987 State
Implementation Plan (SIP)
Base Year Emission
Inventories
Draft Report

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OCN No. 90-203-080-68-08
Radian No. 203-080-68
EPA Contract No. 68-02-4392
Work Assignment No. 68
         QUALITY REVIEW GUIDELINES FOR POST-1987 STATE IMPLEMENTATION
                   PLAN  (SIP)  BASE YEAR EMISSION INVENTORIES
                                 Draft Report
                                 PREPARED  FOR:

                            Mr.  David M1senhe1mer
                        Monitoring  and  Reports  Branch
                          Technical  Support Division
                                    (MD-14)
                     U.  S.  Environmental Protection  Agency
                Research Triangle Park, North Carolina   27711
                                 PREPARED BY:

                      Glenn D. Rives and Garry U. Brooks
                              Radian Corporation
                     3200 Chapel Hill Road/Nelson Highway
                                P.  0.  Box  13000
                 Research  Triangle  Park, North Carolina   27709
                               February  22,  1990

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                                  DISCLAIMER

This report has been prepared for the Office of Air Quality Planning and
Standards, Technical Support Division, U. S. Environmental Protection Agency
by Radian Corporation.  Approval does not signify that the contents
necessarily reflect the views and policies of the Agency, neither does mention
of trade names or commercial products constitute endorsement or recommendation
for use.
c«o. 025m

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                                 TABLE  OF  CONTENTS
  Section                                                                  Page
  Disclaimer 	  ii
  List of Tables 	  v
  1.0   Introduction 	  1-1
        Background 	  1-1
        Purpose of Document 	  1-2
  2.0   Overview of Inventory Guidelines 	  2-1
  3.0   Level I Review 	  3-1
        Introduction 	  3-1
        Instructions for Completing Level  I Review Checklist 	  3-2
  4.0   Level II Review - Stationary Point Sources 	  4-1
        Introduction	  4-1
        Instructions for Completing Level  II Checklist	  4-1
  5.0   Level II Review - Stationary Area Sources 	  5-1
        Introduction 	  5-1
        Instructions for Completing Level  II Checklist	  5-1
V6.0   Level II Review - Area Highway Mobile Sources	  6-1
        Introduction	  6-1
        Instructions for Completing Level  II Review Checklist for Area
        Highway Mobile Sources	  6-1
V7.0   Level II Review - Area Nonhighway Mobile Sources 	  7-1
        Introduction 	 	  7-1
        Instructions for Completing Level  II Checklist	  7-1
  8.0   Inventory Review Summary and Follow-up Activities 	  8-1
  c»o.025«
                                        111

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                               TABLE OF CONTENTS
                                  (Continued)
Section                                                                  Page
Appendix A - Quality Review Guidelines Checklist Package  	  A-l
      Table A-l - Identification of Responsible Agencies  and Specifica-
                  tion of Geographic Scope  	  A-2
      Table A-2 - Inventory Quality Review  Record  	  A-4
      Table A-3 - Record of Correspondence  Concerning Inventory Quality
                  Review 	  A-7
      Table A-4 - Level I Quality Review Checklist  	  A-10
      Table A-5 - Level II Quality Review Checklist:  Point Source  	  A-20
      Table A-6 - Level II Quality Review Checklist:  Area Stationary
                  Sources 	  A-24
      Table A-7 - Level II Quality Review Checklist:  Area Highway
                  Mobi1e Sources 	i	  A-29
      Table A-8 - Level II Quality Review Checklist:  Area Nonhlghway
                  Mobile Sources 	  A-31
Appendix B - Level III Reasonableness Ranges 	  B-l
cao.02S«
                                       iv

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                               1.0  INTRODUCTION

BACKGROUND

     States with areas classified as nonattainment with respect to the
National Ambient Air Quality Standards (NAAQS) were required by the Clean Air
Act (CAA) Amendments of 1977 to submit attainment plans in 1979 which
demonstrated attainment by 1982.  Although attainment plans were submitted and
control strategies implemented, several areas failed to demonstrate compliance
with the carbon monoxide (CO) and ozone standards by the 1982 deadline.  In
response, the U.S. Environmental Protection Agency (EPA) extended the deadline
for attainment to 1987.  In 1987, the EPA determined that despite the 10-year
effort, many of these nonattainment areas were still unable to comply with the
NAAQS requirements.  In addition, new areas were being classified as
nonattainment for ozone and CO.

     In order to assist these areas in achieving the NAAQS, the EPA proposed a
post-1987 policy that set forth conditions and provided guidance that States
must meet to revise their State Implementation Plans (SIPs) and demonstrate
compliance with the ozone and CO NAAQS.  The proposed policy was published in
the Federal Register on November 24, 1987.  In the June 6, 1988 Federal
Register, the EPA published a 11st of areas proposed to be designated as
nonattainment for ozone and CO.  The September 7, 1988 Federal Register
contained a 11st of areas that the EPA formally designated as nonattainment
for ozone and CO and Issued SIP calls for these areas.

     As a part of the proposed post-1987 policy and as a result of their
status as nonattainment areas, the areas receiving SIP calls were required to
submit revised SIP emission inventories for either the 1987 or 1988 base year.
These base year Inventories are to be used for emissions projection purposes
and as a starting point for defining control strategy options for getting the
areas into attainment.  The EPA has put a significant amount of attention and
resources into the revision of the existing SIP Inventories for nonattainment
areas because it recognizes that without a sound base year Inventory from
which to begin, effective control and attainment strategies cannot be
formulated.
e»o.023*
                                      1-1

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      To  assist States with the preparation of revised  inventories, the EPA has
developed  a large complement of inventory guidance materials.  A listing of
the guidance materials published for implementing the  post-1987 policy is
given  in Table 1-1.  With dozens of inventories being  prepared all across the
country, the EPA is concerned about consistency, quality, and adherence to the
published  guidance.  To this end, this document has been developed to serve as
a common basis for quality review of revised SIP inventories in all ten EPA
regions.

PURPOSE  OF DOCUMENT

     The primary purpose of this document is to provide EPA regional offices
with a standard set of guidelines to use in conducting formal reviews of
revised  SIP inventories received from ozone and CO nonattainment areas.
Having a standard set of inventory review guidelines will help ensure national
consistency in the level of scrutiny that submitted inventories will undergo.
These guidelines will also ensure the proper documentation of review
activities to allow for serial review with minimal overlap.  A third use of
this document and the review guidelines is to provide State agencies preparing
the inventories with information to use as a self-check prior to submitting
the inventories to EPA.

     This document provides review guidelines that address whether States
followed the overall requirements for inventory preparation published in the
guidance material shown in Table 1-1 and whether the Inventories meet
developed  specifications for completeness, consistency (both internal and with
national trends), reasonableness of emission values, and overall documentation
requirements.  The review guidelines given in this document are not meant to
be used  to determine the absolute accuracy of an Inventory or whether values
are "right or wrong."  Instead, the guidelines should serve as a mechanism for
promoting timely feedback to the preparing agency on ways they need to revamp
their inventory to be acceptable for the purposes of post-1987 SIPs.
c«o.023«
                                      1-2

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              TABLE 1-1.  LIST OF EPA GUIDANCE MATERIALS THAT SIP
                          EMISSION INVENTORIES SHOULD CONFORM TO
1.    Emission Inventory Requirements For Post-1987 Ozone State Implementation
      Plans. EPA-450/4-88-019, U. S. Environmental Protection Agency, Office
      of A1r Quality Planning and Standards, Research Triangle Park, North
      Carolina, December 1988.

2.    Procedures for the Preparation of Emission Inventories for Precursors of
      Ozone. Volume 1. EPA-450/4-88-021, Third Edition, U. S. Environmental
      Protection Agency, Office of A1r Quality Planning and Standards,
      Research Triangle Park, North Carolina, December 1988.

3.    Emission Inventory Requirements for Post-1987 Carbon Monoxide State
      Implementation Plans. EPA-450/4-88-020, U. S. Environmental Protection
      Agency, Office of Air Quality Planning and Standards, Research Triangle
      Park, North Carolina, December 1988.

4.    Example Emission Inventory Documentation for Post-1987 Ozone State
      Implementation Plans (SIPs). EPA-450/4-89-018, U. S. Environmental
      Protection Agency, Office of Air Quality Planning and Standards,
      Research Triangle Park, North Carolina, October 1989.

5.    Procedures for Emission Inventory Preparation. U. S. Environmental
      Protection Agency, Office of Air Quality Planning and Standards,
      Research Triangle Park, North Carolina:

      a.    Volume I:  Emission Inventory Fundamentals. EPA-450/4-81-026a,
            September 1981.

      b.    Volume II:  Point Source. EPA-450/4-81-026b, September 1981.

      c.    Volume III:  Area Source. EPA-450/4-81-026C, September 1981.

      d.    Volume IV:  Mobile Sources. EPA-450/4-81-026d (Revised), July
            1989.

      e.    Volume V:  Bibliography. EPA-450/4-81-026et September 1981.

6.    AIRS Facility Subsystem Source Classification Codes (SCCsl and Emission
      Factor Listing for Criteria Pollutants. U. S. Environmental Protection
      Agency, Office of A1r Quality Planning and Standards, Research Triangle
      Park, North Carolina, September 1989.

7.    Guidance for the Preparation of Quality Assurance Plans for 0,/CO SIP
      Emission Inventories. EPA-450/4-88-023, U. S. Environmental Protection
      Agency, Office of Air Quality Planning and Standards, Research Triangle
      Park, North Carolina, December 1988.

                                                                  (continued)

c.o.023.                                1-3

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8.    Quality Assignee Program for Post-1987 Ozone and Cgrbop Monoxide State
      Implementation Plan Emission Inventories. EPA-450/4/89-004, U. S.
      Environmental Protection Agency, Office of A1r Quality Planning and
      Standards, Research Triangle Park, North Carolina, March 1989.

9.    SIP Air Emission Inventory Management System (SAMS) Version 2.1 and SAMS
      User's Guide. U. S. Environmental Protection Agency, Office of Air
      Quality Planning and Standards, Research Triangle Park, North Carolina,
      November 1989.

10.   User's Guide to MOBILE4 (Mobile Source Emission Factor Model).
      EPA-AA-TEB-89-01, U. S. Environmental Protection Agency, Office of
      Mobile Sources, Ann Arbor, Michigan, February 1989.

11.   Procedures for Estimating and Applying Rule Effectiveness in Post-1987
      Base Year Emission Inventories for Ozone and Carbon Monoxide State
      Implementation Plans. U. S. Environmental Protection Agency, Office of
      Air Quality Planning and Standards, Research Triangle Park, North
      Carolina, June 1989.
c«o.023»

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      Three  levels  of  review  have  been  designed  and  are  presented  in  this
 document.   The document contains  a  set of  blank review  forms  in Appendix  A
 that implement these  review  levels.  The forms  may  be copied  and  used  as  often
 as necessary.  Instructions  for completing the  forms are given in Sections 3
 through 8.  A more detailed  description of the  three levels of review  and the
 overall intended review process is given in Section 2.
eao.025*                                ,  _

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                     2.0  OVERVIEW OF INVENTORY GUIDELINES

     The quality review program for post-1987 SIP nonattainment base year
emission inventories presented in this document contains three levels of
review.  These levels are known simply as Level I, Level II, and Level III.
The levels are successively more detailed and specific as one goes from Level
I to III.  The levels are designed to be performed sequentially.  There are,
for example, questions in Level I that if answered negatively would require
the reviewing agency to send the inventory back to the preparers for revision
before further review could be performed.  Failure to meet minimum standards
set forth in Level I would dictate that Levels II and III would not even be
attempted.

     Level I is Intended to be a global check of the inventory to ensure that
it meets the minimum requirements and quality standards set forth in the
guidance document Emission Inventory Requirements for Post-1987 Ozone State
Implementation Plans (EPA-450/4-88-019).  Purposes of the Level I checks
include:

     -  ensuring that the whole inventory was prepared according
        to the specified procedures (e.g., seasonal adjustment,
        rule effectiveness) and that all essential data
        elements (e.g., point, area, and mobile sources, VOC, NO,,
        and CO emissions) are present,

     -  flagging obvious omissions for the purpose of providing
        immediate feedback to the preparing agency, and

     -  providing the bases for making decisions regarding whether
        or not Inventory review should continue in the event
        problems are discovered.

Level  I 1s explained in detail in Section 3 as is the guidance for using the
Level  I checklist.  The complete Level I checklist 1s given in Appendix A,
Table A-4.
c»o.02J«
                                      2-1

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     The  Level  II quality review process is slightly more detailed and
 specific  than Level  I.   Its purpose is to check the inventory with respect to
 completeness of source coverage, the correct application of procedural
 requirements, and overall consistency both within the inventory and with
 nationally-based representative values.  Level II checks have been developed
 for stationary  point sources, stationary area sources, highway mobile area
 sources,  and nonhighway  mobile area sources.  Detailed descriptions of the
 Level  II  checks for these sources can be found in Sections 4, 5, 6, and 7,
 respectively.

     The  Level  II checklists are contained in Appendix A according to the
 following schedule.

     Table A-5:  Stationary Point Sources
     Table A-6:  Stationary Area Sources
     Table A-7:  Highway Mobile Area Sources
     Table A-8:  Nonhighway Mobile Area Sources

     The  Level  III quality review checks pertain to a collection of
 reasonableness ranges that have been developed for many of the point and area
 source categories.  These reasonableness ranges have been determined for
 parameters such as emissions, activity levels, production throughputs, and
 control device efficiencies.  The ranges have been developed using several
 sources of nationally-based data such as the National  Emissions Data System
 (NEDS), the National Add Precipitation Assessment Program (NAPAP) data base,
 and U.S. Department of Transportation data.  The Level III values represent
 ranges in which the comparable inventory values should fall if they are in the
 5th to 95th percentile of such data in the U.S.  The Level III reasonableness
 range checks are located in Appendix B of this document. [NOTE TO THE READER:
 LEVEL III REASONABLENESS RANGES HERE STILL BEING DEVELOPED AS OF THE
AVAILABILITY OF THIS DRAFT DOCUMENT.  ONCE COMPLETED,  THE RANGES HILL BE
CONTAINED IN LATER VERSIONS OF THIS DOCUMENT.]
cao.023*
                                      2-2

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     A diagram  illustrating the overall review process and the sequencing of
all three levels  is shown in Figure 2-1.  The complete quality review
checklist package  is provided in Appendix A.  It consists of Tables A-l
through A-8.  The  Appendix A forms can be duplicated for use in as many
inventories as  needed.   [NOTE: THE LEVEL III REASONABLENESS RANGES ARE NOT
CONTAINED IN THE PACKAGE AT THIS TINE.  THEY HILL BE ADDED TO THE PACKAGE WHEN
COMPLETED.]

     Special attention should be paid to the first three tables of Appendix A.
These tables are part of the review package but are not part of either the
Level I, II, or III checklists.  These tables more administrative in nature in
terms of properly  documenting how the quality review was performed.  Table A-
1 documents such items as:

     - what agency submitted the inventory,
     - what agency prepared the inventory, and
     - what is the geographic area represented by the inventory.

Table A-l should be filled out for each unique inventory submitted.

     Table A-2 documents the quality review process carried out at the
regional level.  It records the original receipt of the inventory and
chronicles who reviewed it, when they reviewed it, and what parts were
reviewed.  Table A-3 is used to provide a record of the correspondence between
the region and the States on discussions relating to inventory preparation and
quality.  Table A-3 only requires that a copy of all such correspondence be
attached as a part of the quality review package.

     Section 8 of  this report discusses how the entire inventory review
process should be  summarized and follow-up activities that should occur.  It
describes what activities should take place once the Appendix A checklist
package has been completed.  Essentially, the Region should transmit the
completed package back to the submitting agency and supply them with a write-
up describing all  inventory deficiencies.  To complement the summarization
cao.025»
                                      2-3

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                                      State prepare* and submit*
                                       Inventory to EPA Region
                                      EPA Region Initiate* quality
                                       review checklist proem
                                     Appendix A fonra Table* A-1
                                         and A-2 completed
                                        Level I Review Initiated
                                               nable
                                            to Complete
                                        review proeeaa, return
                                            inventory to
                                               State
                                       Level I Review complete
                                        Level II Review Initiated
                                            to Complete
                                        review proceee, return
                                            Inventory to
                                               State
                                    [  Level II Review complete  [
                                           Level III Review
                                        CompleteTableA-3c*
                                     EPA Region prepare* review
                                      •ummaiyandtranemtoto
                                      State requesting Inventory
                                              revWor*
                                      State revleae inventory and
                                       reeubmlt* It to the Region
                                       Region check* to enture
                                               i were corrected
                                    Baea year SIP Inventory finalized
            Figure 2-1.  General Overview of the Quality Review Process
c.o.023*
                                                2-4

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 discussion,  Section  8 also contains an example of a review summary transmital
 memo that can  be  used to  debrief States on the Region's comments regarding
 inventory adequacy.
e«o.023«                                - _

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                              3.0   LEVEL  I  REVIEW
INTRODUCTION

      The purpose of this section Is to define Level I quality review as It
pertains to State Implementation Plan (SIP) nonattainment Inventories and
describe the kinds of specific data quality checks it entails.  Level I is
essentially the Initial level of broad review that should be performed on
inventories.  Level I checks parallel the inventory preparation guidance
requirements found in the report Emission Inventory Requirements for Post-
1987 Ozone State Implementation Plans (EPA-450/4-88-019).  The questions found
in the Level I checklist in Appendix A, Table A-4 are designed to quickly and
easily allow a determination to be made on whether the basic inventory
requirements specified by EPA have been met.

      The Level I checks also have the purpose of serving as a way to flag
obvious omissions such that Immediate feedback can be provided to the
preparing agency.  The checklist can be used as a decision tool to determine
whether an inventory contains sufficient Information to even bother going
through an entire review procedure.  The Level I process may uncover Inventory
flaws that make continuing with the review process an unproductive venture.
Flagging such flaws early helps get the Inventory back into the preparer's
hands for revision.

      Level I ensures that the key "big picture" Inventory Items have been
satisfactorily addressed before more detailed review takes place in Levels II
and III.  For example, it addresses such items as were point, area, and mobile
sources included; were VOC, NO,,  and CO emissions estimated;  was the
nonattainment area of the inventory clearly defined; were key procedural
requirements such as rule effectiveness and ozone season adjustment followed;
and was some type of quality assurance performed.  Level I review 1s not a
measure of whether a specific number is right or wrong.,
eao.023                                  ->  i

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      The remainder  of  this  section  provides  a set of detailed instructions
for inventory  reviewers to follow 1n using  the Level  I checklist found in
Appendix A.  In  addition to  the  instructions,  a copy  of the associated
checklist sections are  also  provided for  clarification purposes and to avoid
having to Jump back  and forth  between Section  3.0 and Appendix A when reading
the instructions.

INSTRUCTIONS FOR COMPLETING  LEVEL I  REVIEW  CHECKLIST

      This section contains  detailed Instructions for completing the Level I
Review Checklist in  Appendix A,  Table A-4.  The Instructions are keyed to the
checklist numbering  system found in  the appendix.  The Instructions contain
text describing how  to  use the checklist, tables with examples of the kinds of
information the reviewer should  be looking  for in the inventory, and a copy of
the actual checklist sections  being  described  to give the reviewer a quick
reference tool as they  are reading the Instructions.   If the guidelines in the
instructions are not met by  the  Inventory,  the box for that question should be
checked No.
Table A-4
Question                       Instructions

4.1  INVENTORY OVERVIEW

4.1.1       The nonattainment  area  that  the  Inventory was developed for should
            be Identified  1n the  Inventory.   The  area should be consistent
            with the list  of SIP  call  areas  published In  the Federal  Register
            on September 7, 1988  (Volume 53,  No.  173).  A 11st of these areas
            Is provided In Table  3-1.
                                               YES   NO    COMCNTS
         4.1.1  It the nonattainmnt aru to which the     r—i   t—i
               inventory <• applicable defined?
c.o.023

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TABLE 3-1.   LIST OF OZONE AND  CO  NONATTAINMENT AREAS
                PUBLISHED  IN  THE FEDERAL REGISTER
 TABLE A.—CALLS FOB SIP REVISIONS
              O2ONH


         Siata and area
      Blown Co.
      j«rtanonCo.
      SLCMrCo.
      Shaft* Co.
      wafearCo,
      AiMugaCa
      BmoraCo.
      Montgamary Co.
   Aitxona:
             Ca
      CnnandanCa
     3a*
      KamCo.
      FraanoCa
      Kings Co.

      Laa Afigataa Co.
      OrangaCo,
      Rwanda Co.
      San BamMno Ca
      VaMmCa

                                  IV
                                            TABLE A.—CAULS FOR SIP Revisions
                                                   OzO*a}—Continued
                                                   Siaiaanoara.

                                           watfmgwn
 Ptwaowora-Wilrninijtoivrraraon......
   NawCaaoaCo.
   Kant Co.*
Oiatna oi COUMMC
                                           •LMMenvtfa	
                                             CUyCa
                                             OuvalCo.
                                             NaaaauCo.
                                             Si JormaCo.
                                           Miami Ton: Uuoaroata:
                                           Baacn
                                         Btomma Co.
                                         OadaCo.
                                                      l Riion-O*«y
                                                      Co.*
                                         HamanooCa
                                         HHaberouon Ca
                                              Ca.
                                               Ca
                                             SamwCo.
                                             BooaCo.
                                         CttvwnCa
                                         CoBOCo.
                                         CoaottCo.
                                         OaKaACa
                                         OouoMoCa
                                         Parana Co.
                                         FonyoiCo.
                                         FiMonCo.
                                         Many Co.
                                         NawioiiCa
                                         PauMkigCo.
                                         AoeMMaCo.
                                         SoaWnaCa
                                         WaaonCa.
                                      IKnoac
                                        CMcaoa-GanMJfco Co
                                             CoofcCa
                                             OuPaoaCa
                                             OrwioyCo.
                                             KanoCa
                                             KanaMCa
                                             uakoCa
                                             MeMamyCa
                                             w«Co.
                                            SLLOUC
                                             OMonCo.
                                             JanjoyCo.
                                                                         IV
                                              MonroaCo.
                                              SLOw Co.
                                            CUmage Oary Laha County..
                                              LOMCO.
                                              PortarCa
                                              OoatcwnCo.
                                              BoontCo.
                                              HartBonCo.
                                                    Co.
                                                     Co.
                                              JonnaonCa
                                              ManonCo.
                                              Morgan Co.
                                              snaayCo.
                                              cum Co.
                                              FioydCo.
                                              HantaonCo.
                                                                          V
                                        3-3

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                                        TABLE 3-1.    Continued
 TABUS A. -CALLS fort SIP REVISIONS
         OZONE— Continued
         SUM «nd VM
                               6PA
  Boon* Co.
  CamoowtCo.
  Kemon Co.
Muflnngton-Ainuno:
  3oydCo.
  GreonuoCo.
  SouroonCa
  CUr* Co.
  FayomCo.
  JesMmrwCo.
  Scon Co.
  wooofcxaCo.
LOU**!*:
  SUM Co.
  JefltraonCo.
  OWnamCo.
  SnMbyCo.
  AieMWonPv.
  6. 3Mon fteuo* P».
  Uvwgnon PIT.
  W. 9Man Aougo Pv.
   PoM*CowM*P«r.*
Mane
  CuifMfMMCO.
  vork Co. (Al Eiewo;
   EMToMi
   KMytowt
   rf .
Pommoua>-0e»*r nocminr
  vortCo.1
   SOTNC*
   KitMry town
   N. a*rwc*town
   OgmqMBMi
   S.
 HMOOOlCo.
 KnoiCo.
 uneomCo.
  Ann* Afuno« Co.
  9««mo»»Co.
  Cam* Co.
  OaHmomCo.
  Ou«*ji Aornt Co.
PtMaoMpma-wonnov
  CMrtMCa.
  f>«*K* Co.
  Mor«o»in*(v Co.
  Prtne* GMTOM Ca
                              VI
                              M
                                         TAOL£ A.— CAUS FOB SIP REVISIONS
                                                 OZONE— Continued
                                                SUM and «••
                                         9o*ton-LM»«no»-SaMm
                                         SonngMd
                                         WorCMMT
                                         PrTMrtnie* Pn.>u.n»<-P««
                                         NoftMSA ATWM (In PHMOU*
                                               MMen mouMt
                                          LmngHonCa
                                          MonmCa
                                          OmandCa
                                          Si cur Co.
                                          KMtCO.
                                          OMMCa
                                         MiattgonCo.
                                       M(
                                         0*SotoCa
                                        •owe
                                       SLLOuk	
                                          JMDmonCa
                                          StQwrtMCo.
                                          SttowiCo.
                                         RoaMngMm Co. (Partt

                                         SMMCaPv*
                                         RoottigiMm Ca 
-------
                                           TABLE 3-1.   Continued
  TABLE A.—CALLS FO« SIP REVISIONS
           OZONE—Continued

           Slat* ana araa
  CaOarrus Co.
  Gaston Co.
  uncom Co.
  MecktonOurq Co.
  "owan Co.
  Union CO.
   OunamCo.
   FranunCo.
   OrangaCa
   waM Co.
   GfanwUaCo.'
Ohio:
 SuHvCo.
 OormoniCo.
 HarMtgnCo.
 wanwiCo.
 Cuyanoga Co.
  UMC&
  Lor Ml Co.
  Medina Ctt
  PorlagaCa
  SurmMCa.
   LawanoaCo.
  Pamaraaug Manaita
   WaaNngmCo.
Oklahoma:
   CraaftCo.
   OiagaCo.
   RogaraCo.
   TutaaCo.
   WagonarCo.
Oragonc
  Pomand-va
   QacMmaaCo.
   MunnomanCo.
   waaftngun Co.
   vamMCo.
All*
  CueonCo.
  LtmghCo.
      Ma-Wilmni
                »>Ti
  BucMCa
     Ar«
     SUM)*
Scum Carokna:
  vomCo.
                               VI
                                to
                                IV
                                IV
                                          TABLE A.— CALLS FOR SIP REVISIOHS
                                                  OZONE— Continued
                                                                                     TABU A.— CALLS FOA SIP REVISIONS
                                                                                             OZONE— Continued
                                            CNMtnimCo.
                                            OamMonCo.
                                            OckMnCo.
                                            PoowuonCo.
                                           SuninvCo.
                                           WiiMfnionCo.
                                           WiMonCo.
                                           8«awnonM>on Arinur.
                                             Martin Co.
                                             J«NaraonCa
                                             OaogeCo,
                                           OUaa Ft Wonrt
                                             CoHnCo.
                                            OwMnCo.
                                            en* ce.
                                            jonmanCo.
                                            KauMHftCO.
                                            PwMrCo.
                                         Q
                                           T«nmc&
                                           ElPnoCo.
                                           Fona*MC&
                                           HanwCo.
                                           Uxrt^Co.
                                           MOfMQQRMfy Co*
                                           WMMrCa
                                        UMC
                                           Om* COL
                                           StfLKwCo.
                                           Ncrtaavviniraa BaaavN^oon Nawa—
                                                    rCo.
                                             YomCa


                                             Mmoen Hfmt
                                           OwrtHCiiyCa
                                           ChwHrtMtCa
                                           ObwMdtoCa
                                           GoocflMfldCo.
                                           HanaiMrCa.
                                           HomooCo.
                                                   Co.
                                                                                      Prnet G«orq* Co.
                                                                                      ColoncM K»qnn
                                                                         VI
                                                                         vn
                                                                         IV
                                                                                      ArlinqionCo.
                                                                                      Fairfax Co.
                                                                                      LoudounCo.
                                                                                      Prmoa WcHam Co.
                                                                                      SlaAMCo.
                                                                                      AimandrM
                                                                                      Faita
                                                                                      FaMChjrcft
                                                                                    Portland-Vaocouv«r.
                                                                                      da* Co.
                                                                                   Waal Virginia:
                                                                                       Cabal Co.
                                                                                       waynaCo.
                                                                                     Parkarabwo»Mana«U
                                                                                       Wood Co.
                                                                                     KatMMCO.
                                                                                      VttaaMMCo.
                                                                                      CnukMCa
                                                                                      RaoMCo.
                                                                                      WaaNnevon Co.
                                                                                      waMonRCo.'
                                                                                     Sh**oygart
                                                                                      SDaeeyvanCo.
                                                                                      MaritMocCo.*
                                                                                     Kiaaunaa Co.
  •Trw eounaaa (or oMa* or iu»»ia>«ua» ara «n«wr
(a) pan o* M oraimua piannng ana em not pan <*
ma CMSA (or MSA) or (01 oonMaa adMoam to in*
CMSA (or MSA! and maaaimg notaaona.
  ••Tn» LaM Tahot. CA araa • aacMdad *rom in*
SIP eai OaeauN a • pn>aKa» aaparaMd from m«
SuonMame araa By a mouncan ranga. A 1*1 o*.
icnpaon ot ma LaM Tahoa araa appaan n *0 CFR
                                                                                     "•Santi Cna Cg. CA waa not txhBad aacauaa
                                                                                    4 !• Df^fflaCHly SflOMMd  frOHl 9W QtOf AfO.1 OV •
                                                                                    ••••No a* qua** data am vat i
                                                                                  bcoaua* « « pr^vxaay aurawioad by nonananrwni
                                                                                  araaa. a la racaxxg a SIP eaa.

                                                                                    TABLE 8.—CALLS ran SIP RCVWION*
                                                                                            CAABON MONOXIOC
                                                                                             Slaw and AIM
                                                                                     Anenoraga Borougn
                                                                                    Fa
                                                                                                                     6PA
                                                                                    Norm Star Borougn (FartaoWt
                                                                                                           	I IX
                                                                                     ManoopaCo.
                                                                                                               .._., .1
                                                                                       OnanoanCo.
                                                                                   Cu**n*
                                                                                     Ctten,
                                                        3-5

-------
                                      TABLE 3-1.   Continued
TABUI 8.—CALLS row SIP REVISIONS
  CARBON MONOXIOC—Continued

                          :  EPA
  BbMCo.
 LOS
 San
            Ca
Sjcunnmo
 Q OmdeCo.
     rCa
 Conn Coat Ca
 M«*iCa
 NwaCa
 Stn ftvicMoo Ca
 SoMCa
 H|HJMC&(PM)
                                     TABLE 8.—CAUS FOR SIP REVISIONS
                                       CARSON MONOXIDE—Continued
                                            Siautnd ATM
                                                                 EPA
floe*y M* IOMI
Sin
5.
Su
W.
                                       wta«er LOOM «MI
                                       Soutmgtan wwi
                                           CafPirt
                                       EftigMn
                                       E. HftOdMI IDM0I
                                           IA POfQOA Of HBTtlOMtf (PWt Of
                                              Piwnnp  A/M ACCM
                                       MOMMHMI
                                       tveodbnog* tg
                                   Oanet o* COMMM:
                                        8.—CALLS FOA SIP REVISIONS
                                    CARBON MONOXIDE—Continued
                                                                                SUMind AKM
                                                                                                   i  EPA
                                                                          MenmCa
                                                                          CMMMCa
                                                                          SlC*rCa
                                                    3-6

-------
                                        TABLE  3-1.   Continued
TABLE 8.—CALLS FOR SIP Revisions
  CARBON MONOxioe—Continued
                                         TABLE B.—CALLS FOR SJP REVISIONS
                                           CARBON MONOXIDE—Continued
                                       TABLE 8.—CALLS FOR SIP REVISIONS
                                         CARBON MONOXIDE—Continued
        Slaw and Are*
                               EPA
                                                SUM and ArM
                                                                      :  EPA
                                                                                        SUM and Araa
                                                                                                               EPA
 Si. Loon Co.
           Paul
                                           Mont Vernon town
  C*v«rCo.
  gv sago Co.
  Oakou Co.
  Hannaom Co.
  iswwCo.
  RamaayCa
  ScoaCo.
  waannaton Co.
  WngmCa
Si. Cloud
  BamonCa
  SflarOumaCo.
  StaamaCa
                                           ktancMttv oxy
                                         Mommaok Co. (P*9
                                                 town
                                         Bockmgnam Ca (Part)
                                           Auburn town
                                           Canoaittwi
island.
BarganCa

HudaonCa
HuMardonCa
MiM	Ca
MonmoumCa
MerwCa
OcaanCa
PataacCa
SomanaiCa
                                         Union Oa
                                          nimaaaoCa
                                       NawYortc  	
                                        Now  Yoffc^tofifiofn
                                                       Naw Jaraay-Long
                                          Kings Ca

                                          Naw Yortc Ca (Mamwnanl
                                         OuaanaCa
                                         Richmond Ca
                                         RockMndCa
                                         SuHokCa
                                         WaatenaatorCa-
                                        Synjoua*
                                         OnondagmCo.
                                         OwtMMCO.
                                         FfWMklCt.
                                      OMOf
                                                                      VI
                                                                      rv
                                        JackaonCa
                                      Ptydand-vaneouvar
                                        OaekamuaCo.
                                        •AiHnoman Co.
                                        WamngtonCo.
                                        vamnalCa
                                     Pennsywanc
                                      Ptmourqn Q»»,or VM«y..
                                        «iiagnan>Ca
                                        8«awarCa
                                        Fa»ae*Ca
                                        waaMngton Ca
                                                  Ca
                                                                                                            ..; in
                                                                                 npionCa
                                                                                 ChadBiddi Ca
                                                                                 OanidMnCa
                                                                                 OidcaonCa
                                                                                 Robanaon Ca
                                                                                 SumnarCo.
                                                                                 WWamaonCa
                                                                                 WifeMlCa.
                                                                                QPaao.
                                                                                 BPMoCa
                                                                                 Port Band Co.
                                                                                 HamaCa
                                                                                 (jbait/Ca
                                                                                 WaJhvCo.
                                                                              uwt
                                                                                  utanCa
                                                                                 SaMLakdCkVOgMn
                                                                                  0*^aCa
                                                                                  SaHUfcaCa
                                                                                  WabarCa
                                                                                w*
                                                                                                              VI
                                                                                                              vw
                                                                                  AMnamCo.
                                                                                  P«rta»Ca.
                                                                                  Louden Ca
                                                                                                           ._ M
                                                                                  StaflMCa
                                                                                             Ca
                                                                                  FaaaQmren
                                                                               waann
                                                                                  OartiCa
                                                                                 ianta-T
                                                                                  King Co.
                                                                                  P-awaCa
                                                                                          Ca
                                                                                  SpokanaCo.
                                                                                  vatamaCa
                                                                               MaalVlrana:
                                                                                Stauban*aa KMarten.
                                                                                  SraoMCa
                                                                                  HanaocuCo.
                                                       3-7

-------
                                TABLE 3-1.   Continued
      TABLE 8.—CAUS FOB SIP REVJSJONS
        CARBON MONOXIOC—Continued


             Slat* end ATM
       Couotos Co.                  |

       Si Cron Co.

      •lores:
      • vennra Co.. CA >M not nctudvd tweauw 4 •
    ;nvsicaMY Moaraiad (rom m* Sown Cot* A* I
    DV a rnountam nm*.
      " Santa Cna Co.. CA  not ncMjdad I	
    .1 « onyvealv aaparaiad trorn •<• Say Araa By a
      ••• rh« COUMM* for CIM* or
    TI m« pnpnoui OMmrg «M« ou not pan ot aw
    CMSA or MSA,
Reference:   Federal  Register. Volume 53, Number 173,  September 7,  1988.
                                              3-8

-------
4.1.2       Each nonattainment area contains a certain number of affected
            counties.  The counties in the nonattainment area that are
            addressed 1n the Inventory should be clearly Identified.  The
            September 7, 1988 Federal Register lists these counties.

4.1.3       The guidelines for SIP nonattainment base year Inventories
            requires that all 100 ton/yr emission sources found In the
            geographic area extending 25 miles out from the boundary of the
            designated nonattainment area be Included In the base year
            Inventory.  The 25-mile zone should be defined In some way either
            descriptively or by the use of a map.

4.1.4       The Inventory should address VOC, NO,,  and CO emissions.   If any
            one of the three are not Included for a source type where It is
            applicable (e.g., NO, from mobile sources was not covered),  the
            box should be checked No.  Table 3-2 should serve as an aid in
            determining which pollutants are associated with what categories.

4.1.5       Summary emission tables should be provided that are specific to
            each pollutant (I.e., VOC, NO,,  and CO).   An example of what such
            tables should look like 1s provided in Table 3-3.

4.1.6       Summary emission tables for each pollutant should be provided on
            an Individual county basis.  For example, 1f the nonattainment
            area has three counties, there should be three summary tables for
            VOC emissions, three for NO,,  and three for CO.

4.1.2
4.1.3

4.1.4





4.1.5

4.1.6

Are individual count its represented in
the inventory identified?
Hat the 25 -«ile inventory requirement
zone outside of the nanattainaent area
been defined and included in the inventory?
Have each of the following pollutants
been included in the inventory for each
source type where it is applicable?
• Volatile Organic Compounds (VOC)
• Nitrogen Oxides (NO,)
• Carbon Monoxide (CO)
Are sunaary •mission totals tables
provided that are specific to VOC,
NO,, and CO?
Are sunary Mission totals provided for
each pollutant on a county- specific basis?
YES
a
a




CD
a
a
a

a
NO COMMENTS
a
a




a
a 	
a 	
a 	

a 	
eao.023
                                       3-9

-------
                     TABLE 3-2.   EXAMPLE  OF  A  PC-SAM SUMMARY  TABLE
                SUMNMT TABLE OF SEASONALLY ADJUSTED VOC EMISSIONS FOR OZONEV1LLE MSA (ton* per day)
                                                                                              Base Year
                                                                            ...                  (1987)
                                                       Applicable Regulation"'             Point      Area


STORAGE, TRANSPORTATION AND MARKETING OF VOC


 Gasoline and Crude Oil Storag«<3)
      Fixed Roof
      External Floating Roof
 Volatile Organic Liquid Storage               I,II- 0923.0933,0518,0524                    0.0(2>
 Barge and Tanker Cleaning
                 neinals(I>
 Gasoline Bulk Plants19'                          I- 0926.0518,0524,0525                    0.0
 Service Stations
      Tank Truck Unloading                        I- 0932,0928,0518                                    12.7
      Vehicle Refueling                                                                                 9.4
      Tank Breathing Losses                       I- 0518.0524                                          0.8
      Tar* Trucks in Transit                                                                            0.1


INDUSTRIAL PROCESSES

Rubber Tire Manufacture                         II- 0937,0518,0524                          2.2
Bulk Gasoline Terminals'1'                        I- 0927.0518,0524,0525                   13.9
                  »-(*)
 INDUSTRIAL SURFACE COATIMO


 Paper Products                                   I- 0920,0518,0524                         1.7
 Fabric and Vinyl                                 I- 0921.0518,0524                         4.0


MOM'INDUSTRIAL SURFACE COATIIM
 Architectural Coatings                                                                                10-3
 Auto Refinishing                                                                           0.3         6.4


OTHER SOLVENT USf
 Solvent Metal Cleaning
      Cold Cleaners                               I- 0930,0518                                          6.0
      Open Top vapor Degreasers                   I- 0930,0518                              0.2       103.8
      Conveyoritad Oegreesers                     I- 0930,0518                              0.1
 Dry Cleaning
      Perchloroethylene                                   II- 0938,0518                     0.8         1.1
      Petroleua                                      II- 0938,0518,0524                                 0.5
 Graphic Arts
      Rotogravure                               I,II- 0936,0920,0518,0524                    4.1         1.4
      Flexography                               I.II- 0936,0920.0518,0524                    0.6
 Adhesives                                                                                              °-5
 Cutback Asphalt                                  I- 0931,0518,0524                                     0.4
 Consuaar/Conaarcial Solvent Use*                                                                       10-8
                                                   3-10

-------
 TABLE 3-3.  SOURCE CATEGORIES ASSOCIATED WITH VOC,  NO,, AND CO  EMISSIONS
                                                            POLLUTANTS
                  SOURCES OP EMISSIONS
                                                          VOC  CO
Storage, Transportation, and Marketing of Petroleum
  Products and Volatile Organic Liquids

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

Industrial Processes

   Petroleum Refineries                                    Z    Z    Z
   Natural Gas and Petroleum Product Processing            Z    Z    Z
   Lube Oil Manufacture                                    Z    Z    Z
   Organic Chemical Manufacture                            Z    Z    Z
   Inorganic Chemical Manufacture                          Z    Z    Z
   Iron & Steel Production                                 Z    Z    Z
   Coke Production                                         Z    Z    Z
   Coke By-Product Plants                                  Z    Z    Z
   Synthetic Fiber Manufacture                             Z
   Polymers and Resins Manufacture                         Z
   Plastic Products Manufacture                            Z
   Fermentation Processes                                  Z
   Vegitable Oil Processing                                Z
   Pharmaceutical Manufacturing                            Z
   Rubber Tire Manufacture                                 Z
   SBR Rubber Manufacture                                  Z
   Ammonia Production                                      Z
   Carbon Black Manufacture                                Z    Z    Z
   Phthalic Anhydride Production                           Z
   Terephthalic Acid Production                            Z
   Maleic Anhydride Production                             Z
                                     3-11

-------
                         TABLE 3-3.  Continued
                                                            POLLUTANTS
                  SOURCES OF EMISSIONS                   	
                                                          VOC  CO   NO*
Industrial Processes (Concinued)

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

Industrial Surface Coating
                                                           X
   Large Appliances                                        X
   Magnet Wire                                             X
   Autos and Light Trucks                                  X
   Cans                                                    X
   Metal Coils                                             X
   Paper/Fabric                                            X
   Wood Furniture                                          X
   Metal Furniture                                         X
   Miscellaneous Metal Parts and Products                  X
   Flatvood Products                                       X
   Plastic Products                                        X
   Large Ships                                             X
   Large Aircraft                                          X
                                3-12

-------
                         TABLE 3-3.  Continued
                                                            POLLUTANTS
                  SOURCES OF EMISSIONS                   	
                                                          VOC  CO   N0«
Nonindustrial Surface Coating

   Architectural Coatings                                  X
   Auto Refiniihing                                        X

Other Solvent Use

   Degreasing*                                             X
   Dry Cleaning                                            X
   Graphic Arts                                            X
   Adhesive*                                               X
   Solvent Extraction Processes                            X
   Cutback Asphalt                                         X
   Consumer/Commercial Solvent Use                         X
   Asphalt Roofing Kettles                                 XXX
   Pesticide Application                                   X

External Combustion Sources*

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

Stationary Internal Combustion*

   Reciprocating Engines                                   XXX
   Gas Turbines                                            XXX

Waste Disposal

   Publicly Owned Treatment Works                          X
   Industrial Wastewater Treatment                         X
   Municipal Landfills                                     X
   Hazardous Waste Treatment, Storage and Disposal         X
     Facilities
                                  3-13

-------
                        TABLE 3-3.  Continued
                                                             POLLUTANTS
                   SOURCES OF EMISSIONS                   	
                                                          VOC  CO    NO,
Mobile Sources
Highway Vehicles
Nonhighway Vehicles
X
X
X
X
X
X
 Emissions from these sources may occur from source categories
 identified elsewhere in Table 2.2-1.  For example, carbon monoxide  and
 oxides of nitrogen are emitted from industrial boilers at organic and
 inorganic manufacturing facilities.  Likewise, carbon monoxide and
 oxides of nitrogen are emitted from reciprocating engines at oil and
 gas production facilities, and volatile organic compounds are emitted
 from many industries involved in degreasing operations.  An effort
 should be made to avoid double counting from these sources.
Reference:  Procedures for the Preparation of Emission Inventories for
            Precursors of Ozone. Volume 1. EPA-450/4-88-021,  U.  S.
            Environmental Protection Agency,  Research Triangle Park,  North
            Carolina, December 1988.
                                 3-14

-------
4.1.7        The calendar year on  which the inventory data are  based and
             applicable to should  be stated somewhere in the  inventory report.

4.1.8        The inventory should  address stationary point sources, stationary
             area  sources, highway mobile sources,  and nonhighway mobile
             sources.   These should be included  for each county in the
             nonattainment area.

4.1.9        For each  pollutant, the reviewer  is  asked to calculate the percent
             contribution to emissions from each  of the four  major source
             types:  stationary point sources, stationary area  sources, highway
             mobile  sources, and nonhighway mobile  sources.   Enter the percent
             contributions on the  lines provided.   The percentages should be
             for the total area included in the  inventory and not individual
             counties.

4.1.10       The reviewer should check the emission estimates and the
             calculations to verify that emissions  are specific to the ozone
             season  and that daily activity has  been incorporated into the
             estimate.   Examples of seasonal adjustment factors for area
             sources are given in  Table 3-4.
                                                 YES    NO    COMMENTS
          4.1.7  Is the calendar year basis for the base-
                line inventory specified?

          4.1.8  Have each of the following source types
                been addressed in the inventory?

                • Stationary Point Sources (SPS)

                - Stationary Area Sources (SAS)

          4.1.9  Specify the percent contribution
                of each of the source types listed in
                4.1.8 to the total inventory emissions
                for VOC, NO,, and CO.
                           n
                           n   n
                           a   a
vocai
                                    co(X)
                -SPS
                - SAS
          4.1.10 Do the Missions estimates for VOC,
                NO,, and CO reflect seasonal and
                weekday adjustments?
                           n   n
e»o.023
                 3-15

-------
      TABLE 3-4.  OZONE SEASONAL ADJUSTMENT FACTORS FOR AREA SOURCES
 Category
Seasonal Adjustment
     Factors
Activity Days
   Per Week
Gasoline  Service Stations
  Tank Trucks  in Transit
  Tank Trucks  Unloading (Stage  I)
  Vehicle Fueling  (Stage II)
  Storage Tank Breathing Losses

Solvent Users
  Degreasing
  Dry Cleaning
  Surface Coatings
    Architectural
    Auto  Reflnishing
    Other Small Industrial
  Graphic Arts
  Cutback Asphalt
  Pesticides
  Commercial/Consumer

Waste Management Practices
  POTWs
  Hazardous Waste TSOFs
  Municipal Landfills

Stationary Source Fossil Fuel Use
  Residential
  Commercial/Institutional
  Industrial

Solid Waste Disposal
  On-site  Incineration
  Open Burning

  Structural Fires
  Field/Slash/Prescribed Burning
  Wildfires

Off-highway Mobile Sources
  Agricultural Equipment
  Construction Equipment
  Industrial Equipment
  Lawn and Garden Equipment
  Motorcyles
Seasonal variations in through-    6
put vary from area to area.        6
Use average temperature for a      7
summer day where appropriate.      7
Uniform                            6
Uniform                            5

1.3                                7
Uniform                            5
Uniform                            5
Uniform                            5
0
1.3                                6
Uniform                            7
1.4                                7
1.2                                7
Uniform                            7
0.3                                7
0.6                                6
Uniform                            6
Uniform                           7
Refer to local regulations
and practices                     7
Uniform                           7
0
Refer to local fire conditions    7
1.1
Uniform
Uniform
1.3
1.3
Reference:  Procedures for the Preparation of Emission Inventories for
            Precursors of Ozone. Volume 1. EPA-450/4-88-021, U. S.
            Environmental Protection Agency, Research Triangle Park, North
            Carolina, December 1988.
                                    3-16

-------
4.1.11      The reviewer should check the inventory and the documentation to
            ensure that non-reactive VOC have not been included in the VOC
            emission totals.  Non-reactive VOC are not allowed to be counted
            as VOC for the purposes of SIP ozone nonattainment inventories.
            The list of non-reactive VOC is given in Table 3-5.

4.1.12      The emission inventory estimates should have been determined by
            taking into account existing regulatory requirements.  The
            specific requirements applicable to each source category should
            have been denoted.  Examples of the types of regulations that
            should have been included are given in Table 3-6.

4.1.13      The reviewer should check the inventory documentation and
            calculations to make sure that rule effectiveness and rule
            penetration were incorporated where applicable.  These conditions
            are applicable for any source category that has existing
            regulatory requirements on it to reduce emissions and that is not
            an uncontrolled source.  In cases where rule effectiveness was
            applied, the reviewer should check to see if an effectiveness
            level  other than the 80 percent EPA default was used.  If so,
            documentation should be provided for the alternative level used.
4.2  POINT SOURCES

4.2.1       Emission estimates should have been developed for all VOC point
            sources with actual emissions of at least 10 tons/yr.  The
            reviewer should check the inventory documentation to determine how
            point sources were identified for inclusion in the inventory.
            Source types such as those shown in Table 3-7 would need to have
            been evaluated for inclusion in the inventory.  The method of
            source identification should be delineated as a part of the
            documentation.  Identification methods might include: 1) existing
            State permit files, 2) NEDS source listings, 3)NAPAP source
            listings, 4) industrial directory listings, 5) existing SIP
            inventory listings, and 6) source survey results.

4.1.11
4.1.12
4.1.13
4.2,1

Have adjustments ba«n mad* to the VOC
missions estimates to reflect the non-
reactive compounds that cannot be
counted as VOC emissions for the
purpose of SIP attainment inventories?
Have all existing regulatory require-
ments for each source category type
been identified?
Has rule effectiveness and rule
penetration been factored into
emissions esti nates where appropriate?
Have all VOC point sources with actual
emissions equal to or greater than 10
tons/yr been included in the inventory?
YES
n
n
n
n
NO COMNTS
n 	
n 	
a 	
a _
cao.025
                                      3-17

-------
            TABLE 3-5.  LIST OF NON-REACTIVE VOC THAT ARE NOT TO BE
                        INCLUDED AS VOC IN SIP NONATTAINMENT INVENTORIES


      methane
      ethane
      1,1,1-trichloroethane
      methylene chloride
      trichlorofluoromethane (CFC 11)
      dichlorodifluoromethane (CFC 12)
      chlorodlfluoromethane (CFC 22)
      trlfluoromethane (CFC 23)
      trlchlorotrlfluoroethane (CFC 113)
      dfchlorotrlfluoroethane (CFC 114)
      chloropentafluoroethane (CFC 115)
      dlchlorotrlf1uoroethane (HCFC-123)
      tetrafluoroethane (HFC-13a)
      dlchlorofluoroethane (HCFC-1416)
      chlorodIf!uoroethane (HCFC-1426)


Reference:  1)  Procedures for the Preparation of Emission Inventories for
                Precursors of Ozone. Volume 1. EPA-450/4-88-021, U. S.
                Environmental Protection Agency, Research Triangle Park,
                North Carolina, December 1988.

            2)  Federal Register. Volume 54, Number 11, January 18, 1989.
                                    3-18

-------
           TABLE 3-6.  EXISTING VOC REGULATIONS AND CONTROL REQUIREMENTS
                       THAT MAY AFFECT SIP VOC INVENTORIES
1.    NESHAP Regulations
2.    NSPS Regulations
3.    Existing SIP requirements such as application of RACT specified by CTGs:
      GROUP I
      •     Surface Coating of Cans, Colls, Paper, Fabric, Automobiles, and
            Light Duty Trucks (EPA-450/2-77-008).
            Surface Coating of Metal Furniture (EPA-450/2-77-032).
      •     Surface Coating for Insulation of Magnetic Wire
            (EPA-450/2-77-033).
            Surface Coating of Large Appliances (EPA-450/2-77-034).
      •     Storage of Petroleum Liquids in Fixed Roof Tanks
            (EPA-450/2-77-036).
            Bulk Gasoline Plants (EPA-450/2-77-035).
            Solvent Metal Cleaning (EPA-450/2-77-022).
            Use of Cutback Asphalt (EPA-450/2-77-037).
            Refinery Vacuum Producing Systems, Wastewater Separators, and
            Process Unit Turnaround (EPA-450/2-77-025).
            Hydrocarbons from Tank Gasoline Loading Terminals
            (EPA-450/2-77-026).
            Design Criteria for Stage I Vapor Control Systems, Gasoline
            Service Stations, U. S. EPA, OAQPS, November 1975.  Unpublished.
      Group II
      •     Leaks from Petroleum Refinery Equipment (EPA-450/2-78-036).
            Surface Coating of Miscellaneous Metal Parts and Products
            (EPA-450/2-78-015).
            Surface Coating of Flat Wood Paneling (EPA-450/2-78-032).
      •     Manufacture of Synthesized Pharmaceutical Products
            (EPA-450/2-78-029).
                                                                (continued)
                                   3-19

-------
                       TABLE 3-6.   Continued
      Manufacture of Pneumatic Rubber Tires (EPA-450/2-78-030).
      Graphic Arts - Rotogravure and Flexography (EPA-450/2-78-033)
      Petroleum Liquid Storage in External Floating Roof Tanks
      (EPA-450/2-78-047).
      Perch!oroethylene Dry Cleaning Systems (EPA-450/2-78-050).
      Leaks from Gasoline Tank Trucks and Vapor Collection Systems
      (EPA-450/2-78-051).
GROUP III
•     Control of VOC Emissions from Large Petroleum Dry Cleaners
      (EPA-450/3-83-009).
•     Control of VOC Emissions from Manufacture of High Density.
      Polyethylene, Polypropylene, and Polystyrene Resins
      (EPA-450/3-83-008).
      Natural Gas/Gasoline Processing Plants (EPA-450/3-83-007).
      SOCMI Fugitive (EPA-450/3-83-006).
      SOCMI - Air Oxidation (EPA-450/3-84-015).
                            3-20

-------
     TABLE 3-7.  LIST OF POINT SOURCE TYPES THAT SHOULD BE CONSIDERED
               FOR POSSIBLE INCLUSION IN THE INVENTORY
Storage.  Transportation And Marketing Of Petroleum Products
     tile  Organic Liquids fVQLl
Oil And Gas  Production
  Storage
  Fugitives
  Other Process  Units  (specify)

Natural Gas  And  Gasoline Processing
  Storage
  Fugitives
  Other Process  Units  (specify)

Oil Processing
  Storage
  Fugitives
  Other Process  Units  (specify)

Tank Farms (specify material  stored)
  Fixed Roof Tanks
  External Floating Roof Tanks
    Primary  Seals
    Secondary Seals
  Internal Floating Roof Tanks

Bulk Gasoline And VOL  Terminals
  Leaks From Valves, Flanges  Meters,  Pumps
  Vapor Collection Losses
  vapor Control  Unit Losses
  Filling Losses From  Uncontrolled Loading Racks
  Tank Truck Vapor Leaks From Loading Of Gasoline
  Non-tank Farm  Storage

Gasoline Bulk Plants
  Gasoline Bulk  Storage
  Loading And Unloading  Racks (Controlled And Uncontrolled)
  Tank Truck Vapor Leaks Prom Loading And Unloading Of Gasoline
  Leaks From Valves, Flanges,  Meters, Pumps

Barge And Tanker Transfer
  Gasoline Loading/Barge
  Crude Oil  Ballasting/Tanker

Barge And Tanker Cleaning
                                3-21

-------
                      TABLE 3-7.  Continued

 Industrial  Processes

 Petroleum Refineries
   Process Drains And  wastewater Separators
   Vacuum  Producing Systems
   Process Unit Turnarounds
   Fugitive  Leaks From Seals,  Valves,  Flanges
    Pressure Relief Devices,  Drains
   Other Process Emissions  Such  As  Heaters,  Boilers
    Cat Cracker Regenerators  (specify)

 Lube Oil  Manufacture

 Pharmaceutical Manufacture
   Process Units Such  As Vacuum  Dryers, Reactors,
    Distillation Units, Filters, Extractors,
    Centrifuges, Crystallizers
   Major Production  Equipment  Such  As  Exhaust Systems  And
    Air Dryers
   Storage And Transfer
   Other Process Units (specify)

Rubber Tire Manufacture
   Undertread And Sidevall  Cementing
   Bead Dipping
   Bead Swabbing
  Tire Building
  Tread End Cementing
  Green Tire Spraying
  Tire Curing
   Solvent Mixing
   Solvent Storage
  other Process Units (specify)

Styrene Butadiene Rubber Manufacture
  Slowdown Tanks
  Steam Stripper
  Prestorage Tanks
  other Process Units (specify)

Vegetable Oil
  Oil Extraction And  Desolventization
  Mean Preparation
  Oil Refining
  Fugitive Leaks
  Solvent Storage
  other Process Units (specify)
                                3-22

-------
                      TABLE 3-7.  Continued

Organic Chemical Manufacture  (specify major chemicals)
  Fugitive Leaks From Seals,  Valves, Flanges,
    Pressure Relief Devices,  Drains
  Air Oxidation Units
  Waste Water Separators
  Storage And Transfer
  other Process Units (specify)

Polymer And Resin Manufacture
  Catalyst Preparation
  Reactor Vents
  Separation of Reactants, Solvents And
    Diluents From Product
  Raw Material Storage
  Solvent Storage
  other Process Units (specify)

Plastic Products Manufacture
  Mold Release
  Solvent Consumption
  Adhesive* Consumption
  other Process Units (specify)

Inorganic Chemical Manufacture
  Fugitive LeaJcs from Seals, Valves, Flanges,
    Pressure Relief Devices, Drains
  Storage And Transfer
  Other Process Units (specify)

Fermentation Processes
  Fermentation Tank Venting
  Aging/Wine or whiskey
  Other Process Units (specify)

Iron And Steel Manufacture
  Coke Production
    Coke Pushing
    Coke Oven Doors
    Coke Byproduct Plant
    Coke Charging
    Coal Preheater
    Topside Leaks
    Quenching
    Battery Stacks
  Sintering
  Electric Arc Furnaces
  Other Process Units (specify)
                               3-23

-------
                       TABLE 3-7.  Continued

 Synthetic  Fiber  Manufacture
   Dope  Preparation
   Filtration
   Fiber Extrusion - Solvent Recovery
   Takeup Stretching, Washing,  Drying,  Crimping,  Finishing
   Fiber Storage  - Residual  Solvent  Evaporation
   Equipment Cleanup
   Solvent  Storage
   Other Process  Units  (specify)

 Industrial Surface Coating

 Large Appliances
   Cleaning And Pretreataent
   Prime Spray, Flow, Or Dip Coating Operations
   Topcoat Spray
   Coating Mixing
   Coating And Solvent Storage
   Equipment Cleanup
   Other Process  Emissions (specify)

Magnet  wire
   Cleaning And Pretreatment
   Coating Application And Curing
   Coating Mixing
   Coating And Solvent Storage
   Equipment Cleanup
   Other Process  Emissions (specify)

Automobiles And  Light Duty  Trucks
   Cleaning And Pretreatment
   Prime Application, Electrodeposition, Dip Or Spray
   Prime  Surfacing Operations
   Topcoat Operation
   Repair Topcoat Application Area
   Coating Mixing
   Coating And Solvent Storage
   Equipment Cleanup
  Other Process.  Emissions (specify)

Cans
   Cleaning And Pretreatment
   Two Piece And  Exterior Base Coating
   Interior Spray Coating
   Sheet Basecoating (Interior)
   Sheet Basecoating (Exterior)
   Side Seam Spray Coating
   End Sealing Compound
   Litography
   Over Varnish
   Coating Mixing
   Coating And Solvent Storage
                               3-24

-------
                        TABLE 3-7.  Continued

Cans  (continued)
  Equipment Cleanup
  Other Process Emissions  (specify)

Paper
  Coating Operations
  Coating Mixing
  Coating And Solvent Storage
  Equipment Cleanup
  Other Process Emissions  (specify)

Coil  Coating
  Prime Coating
  Finish Coating
  Solvent Nixing
  Solvent Storage
  Equipment Cleanup
  Other Process Emissions  (specify)

Fabric
  Coating Operations
  Coating Mixing
  Coating And Solvent Storage
  Equipment Cleanup
  Other Process Emissions  (specify)

Metal And Wood Furniture
  Cleaning And Pretreatment
  Coating Operations
  Coating Mixing
  Coating And Solvent Mixing
  Equipment Cleanup
  Other Process Emissions  (specify)

Flatvood Products
  Filter
  Sealer
  Basecoat
  Topcoat
  Inks
  Coating Mixing
  Coating And Solvent Storage
  Equipment Cleanup
  Other Process Emissions  (specify)

Plastic Products
  Cleaning And Pretreatment
  Coating Operations, Flow, Dip, Spray
  Coating Mixing
  Coating And Solvent Storage
  Equipment Cleanup
  Other Process Emissions  (specify)
                                3-25

-------
                        TABLE 3-7.  Continued

 Large  Ships
   Cleaning And Pretreatment
   Prime Coat Operation
   Topcoat  Operation
   Coating  Mixing
   Coating  And Solvent Storage
   Equipment  Cleanup
   Other Process Emissions  (specify)

 Large  Aircraft
   Cleaning And Pretreataent
   Prime Coat Operation
   Topcoat  Operation
   Coating  And Solvent Storage
   Equipment  Cleanup
   Other Process Emissions  (specify)

 Miscellaneous Metal Parts  And Products
   Cleaning And Pretreatment
   Coating  Operations, Flow, Dip,  Spray
   Coating  Mixing
   Coating  And Solvent Storage
   Equipment  Cleanup
   other Process Emissions  (specify)

 Other  Solvent Use

 Dry Cleaning
   Perchloroethylene
   Petroleum
   Other

 Oegreasing
   Open  Top Vapor Oegreasing
   Conveyorized Oegreasing  - Vapor
  Conveyorized Degreasing  - Cold  Cleaning

Solvent  Extraction Processes

Adhesives
  Adhesive Application
  Solvent Nixing
  Solvent  Storage
  Other  Process  Emissions  (specify)

Grahic Arts
  Letter Press
  Rotogravure
  Offset Lithography
   Ink Mixing
   Solvent  Storage
                                3-26

-------
                             TABLE 3-7.   Continued

     Waste  Disposal

     Municipal Waste
       Combustion
         RDF
         Mass Burn
         Co-fired
         other
       Landfills

     TSDPs
       Lagoons
       Tanks
       Mixing
       Aeration
       Landfills
       Other

     POTWs
       Tanks
       Lagoons
       Aeration
       Nixing
       Digestion
       other

     ITWS
       Tanks
       Lagoons
       Aeration
       Mixing
       Digestion
       other

     Industrial  Boilers
       Co-firing (specify major substances and co-firing fuels,
                  such as oil, gas, coal, etc.)
Reference:  Emission Inventory Requirements for Post-1987 Ozone State
           Implementation Plans. EPA-450/4-88-019, U. S. Environmental
           Protection Agency, Research Triangle Park, North Carolina,
           December 1988.
                                    3-27

-------
4.2.2       For point sources with  VOC emissions  equal  to or greater than 25
             tons/yr,  the inventory  should contain process, point,  and segment
             level data.   The parameters represented  by these three data types
             are shown in Table 3-8.   The parameters  required for SIP
             inventories  are noted.

4.2.3       The reviewer should check to see that 100 ton/yr VOC emission
             sources  in the 25-mile  zone extending out from the nonattainment
             area have been addressed in the inventory.   These sources should
             all be in the inventory and should have  process, point,  and
             segment  level data requirements met as shown in Table  3-8.


4.2.4       The reviewer should determine how emissions estimates  were derived
             for VOC  sources in the  10-25 tons/yr  range.  If the estimates were
             determined by using facility-specific data  gathered through a
             written  survey, phone survey, or other means, check Yes  to this
             question.  If facility-specific data  were not used (e.g., a
             category  emission factor was used or  extrapolations were made from
             similar  sources), check No.

4.2.5       If the reviewer determines that facility-specific data were not
             used to estimate emissions for 10-25  ton/yr VOC sources, a check
             should be made of the documentation to see  if a statistical
             extrapolation approach  was used.  This approach involves
             determining  emissions or an emission  factor for a subset of
             sources within a category and extrapolating this emission rate to
             the other members of the category based  on  an activity level  or
             other surrogate parameter.
                                                 TES
                                        NO
            CCHWITS
          4.2.2
          4.2.3
          4.2.4
          4.2.5
Have proceaa, point, and aegaant level
data bMn providad for all VOC point
sourcea with actual eariaaiona aqual to
or greater than 25 tona/yr?
For aourcea fn the 10*25 tona/yr
•afufona rang*, Mar* facility-specific
data uaad to docuaant (Mission*
eatiMtaa?

If facility-specific data were not utad
to docuaant sourcaa in tha 10-25 tona/yr
rang*, was a statistical extrapolation
procadura uaad to aatimata and docuaant
emissions?
                                                 a   a
Have all VOC aourcM in tha 25-arfle zone
outaide of the nonattainaent area with    ,—•
•aiaaiona greater than 100 tona/yr been   I—'
addressed in the inventory?
      n

      n

n   n
e«o.023
                                      3-28

-------
            TABLE 3-8.  REQUIRED PARAMETERS FOR PROCESS, POINT, AND
                        SEGMENT LEVEL DATA
I.  Plant Information

    -  NEDS State ID
    -  NEDS County ID
    -  NEDS Plant ID
    -  NEDS Pollutant ID
    -  Model Area (County,
       Township, or Grid Cell)
    -  Number of Employees
    -  Base Year of Inventory
    -  UTM Zone
    -  UTM Coordinates (km)
        X:
        Y:
    -  Plant Name
    -  Street Address
    -  City
    -  State
    -  Zip Code
    -  Plant Contact
    -  Plant SIC Code(s)
    -  Principal Product
    -  Projected Attainment Year
    -  Total Plant Banked Emissions
    -  Year Emissions Banked

II. Point Information

    -  NEDS Point ID
    -  Point Description
    -  % Annual Throughput
       Dec-Feb
       Mar-May
       June-Aug
       Sept-Nov
    -  Normal Operation Schedule
         hrs/day
         days/wk
         v*s/yr
         dally start/end tines
    -  Regulation 1n Place? (Y/N)
    -  Emission Limitation
    -  Compliance Year
    -  CTG Category (I, II, III)
III.   Segment ^formation

      -  sec
      -  SCC Description
      -  Process Rate Units
      -  Actual  Annual  Process Rate
      -  Seasonal  Adjustment Factor
      -  0,  Season Dally Process  Rate
      -  Maximum Hourly Design Rate
      -  Control Equipment
           primary
           secondary
      -  Control Efficiency (X)
      -  Emission Estimation Method
      -  Emission Factor Units
      -  Emission Factor (uncontrolled
           emissions)
      -  Annual  Base Year Emissions
           (tons/yr)
      -  Rule Effectiveness (X)
      -  0,  Season Dally Emissions
            (Ibs/day)
      -  Banked  Emissions (tons/yr)
      -  Comment
*Bold type Indicates required data.

Reference:  Procedures for the Preparation of Emission Inventories for
            Precursors of Ozone. Volume 1. EPA-450/4-88-021, U. S.
            Environmental Protection Agency, Research Triangle Park, North
            Carolina, December 1988.
                                   3-29

-------
4.2.6        If question 4.2.5  is answered  Yes, the reviewer should determine
             if the proper documentation  has been provided.  The  four Hems
             listed refer to  the types of documentation  for the statistical
             extrapolation approach that  EPA requires  in Its inventory
             guidance.

4.2.7        The  reviewer should check the  inventory documentation  and
             calculations to  make sure that rule effectiveness and  rule
             penetration were incorporated  where applicable.  These conditions
             are  applicable for any source  category that has existing
             regulatory requirements on 1t  to reduce emissions and  that is not
             an uncontrolled  source.  In  cases where rule effectiveness was
             applied,  the reviewer should check to see if an effectiveness
             level  other than the 80 percent EPA default was used.   If so,
             documentation* should be provided for the alternative level used.

4.2.8        The  reviewer should check to ensure that NO,  and CO sources  with
             emissions of 100 tons/yr or  greater located in the nonattainment
             area or in the 25-mile zone  extending from  the nonattainment area
             are  addressed 1n the inventory.

4.2.9        The  reviewer should check to make sure that the required process,
             point,  and segment level data  shown in Table 3-8 1s provided for
             all  100 ton/yr NO,  and  CO sources.
                                                 YES
     NO
COMNENTS
          4.2.6   If Qutstlon 4.2.5 it answered yes, are
                 the following docunentation parameters
                 provided?

                 -  Is the statistical survey sample set'
                   of sources identified?

                 -  For the survey set, are locations,
                   activity levels, and emissions
                   provided?
          4.2.7  Has rule effectiveness been applied
                in estimating VOC Missions for all
                sources (regardless of size) where
                it is applicable?

          4.2.8  Have all HO, and CO sources in the MSA
                end in the 25-eiile zone outside of the
                nonattairmnt area with emissions greater
                then 100 tons/yr been addressed in
                the inventory?

          4.2.9  Have all process, point, and segment
                level docunentation data required for
                the 100 ton NO, and CO sources been
                provided?
n   n
a   a

a   a

a   a


a   a
c»o.023
                                        3-30

-------
4.3  AREA  SOURCES
4.3.1        The predominant non-mobile area source categories recognized by
             EPA 1n Its SIP Inventory guidance materials  are listed here.  The
             reviewer should go  through the 11st and determine which categories
             have been Included  In  the Inventory and which  have not.
             Documentation should be present in the Inventory describing why
             missing categories  were not Included.

4.3.2        The reviewer should evaluate the documentation for the area source
             emissions estimates and ensure that at a minimum all emission
             factors and activity levels used are presented and the sources of
             these data are given.   If equations are used (e.g., for storage
             tanks), the values  of  all variables, the sources of the values,
             and any other assumptions used should be presented.  If sufficient
             information is not  given to independently  replicate the emissions
             estimates, then documentation 1s not sufficient and No should be
             checked.

4.3.3        The reviewer should check to ensure that point source
             contributions have  been subtracted out from  area source category
             totals whenever appropriate. Some area source  categories, such as
             graphic arts, contain  both area and point  sources.  Large
             operations are treated as point sources and  are handled in the
             point source component of the inventory.   However, the mechanism
             for calculating area source emissions Involves looking at the
             entire category,  Including the point source  component.  To avoid
             double counting,  the point source contribution has to be
             subtracted out.   The categories most likely  to have a point source
             contribution are  degreasing, graphic arts, drycleaning, and
             surface coating.
                                                 YES
      NO    COMCNTS
          4.3.1   Have each of the following najor
                categories of nan- mobile area source
                emissions been addressed in the
                inventory?

                -  Gasoline Distribution
                -  Dry Cleaning

          4.3.2  Are all area source emissions estimates
                doc minted by providing the emission
                factor and activity level used and the
                sources of these data?

          4.3.3  Where appropriate, have point sources
                contributions been subtracted out from
                area source category estimates?
                                                n   n
a
a
a
a
a   a
cao.023
                                       3-31

-------
4.3.4       The reviewer should check the inventory documentation and
            calculations to make sure that rule effectiveness and rule
            penetration were incorporated where applicable.  These conditions
            are applicable for any source category that has existing
            regulatory requirements on it to reduce emissions and that is not
            an uncontrolled source.  In cases where rule effectiveness was
            applied, the reviewer should check to see if an effectiveness
            level other than the 80 percent EPA default was used.  If so,
            documentation should be provided for the alternative level used.
4.4  MOBILE SOURCES
4.4.1       The reviewer should check to ensure that all of the eight highway
            vehicle classes shown in the checklist have been addressed for all
            counties in the inventory.  Failure to address any category
            without sufficient documentation should result in that category
            being answered No.

4.4.2       The reviewer should determine if EPA's MOBILE4 model was used to
            generate VOC, NO,, and CO emission factors for highway vehicle
            emissions estimates.  The California Air Resources Board has
            developed a model called EMFAC70 that Is similar to MOBILE4 but is
            more specific to California.  The model, however, requires more
            detailed and site-specific Information and, therefore, MOBILE4 may
            have been used even for California areas.  If MOBILE4 was used in
            an area, Including California, answer the question Yes.  If
            EMFAC7D was used in California areas, answer the question No and
            note in the Comments field what model was used.

4.3.4

4.4.1





4.4.2


Uhere appropriate, has rule effectiveness
and rule penetration ba«n rtflacted in
emission estlMtes?
Haw all of the following highway
vehicle classes been addressed in
the inventory?
(LOGV)
(LOGT1)
UDGT2)
Has EPA's MOBILE4 model been used
to estimate highway vehicle mobile
source emission factors?
YES
n




a
a
a
a

NO COMMENTS
a




a
a
a
a

c.o.023
                                   3-32

-------
4.4.3        If MOBILE4 was used to  estimate highway vehicle emissions, the
             reviewer should check the inventory documentation  to  verify that
             the methods by which the model was used to determine  emissions  are
             explained.

4.4.4        If MOBILE4 was used, the reviewer should examine the  inventory
             documentation for the modeling exercise to determine  if the source
             of information for the  key model inputs listed are explained.   If
             the source of the value used for the  listed parameter is not
             explained, the question for that parameter should  be  answered No.

4.4.5        If a procedure other than the MOBILE4 model was used  to generate
             highway  vehicle emission factors, the reviewer must determine if
             this alternative procedure has been documented in  the Inventory
             such that the data could be replicated by independent reviewers.
             If replication is not possible then the question should be
             answered No.
         4.4.3
         4.4.4
Has information been provided to
docvnent how highway vehicle mobile
source Missions estimates uere
determined using M08ILE4?

Is information provided to document
how each of the following NOBILE4
inputs was derived?
                                                 YES    NO
                                                 a    a
                                              CQMNEMTS
                -  t
          4.4.5
        ing rates
 If a procedure other than the NOBILE4
 modal was used to generate emission
 factors, was the procedure identified
 and documented?
a   a
a   a
c«o.023
                                     3-33

-------
4.4.6       The reviewer should determine if the estimates provided for
            vehicle miles travelled (VMT) are on the basis of the following
            specific road types.
                Urban

                interstate
                other freeways
                other principal
                  arterial
                minor arterial
                collector
                local
    Rural

interstate
other principal
arterial

minor arterial
major collector
minor collector
local
            If an attempt has been made to break the VMT down Into at least
            three of these road types, answer the question Yes.

            The reviewer should also determine if the VMT estimates provided
            have been reported on the basis of vehicle type.  The vehicle type
            classes of importance are shown in question 4.4.1.
4.4.7       The reviewer should determine if the VMT data provided in the
            inventory are documented by any one or more of the methods shown
            in the checklist.

4.4.8       The reviewer should check to ensure that all of the eight
            nonhighway vehicle classes shown in the checklist have been
            addressed for all counties in the inventory.  Failure to address
            any category without sufficient documentation should result in
            that category being answered No.

4.4.6



4.4.7


4.4.8






Are estimates of vehicle eiiles traveled
(VMT) provided that are:
• road-type specific?
• vehicle-type specific?
Are VMT estlMtes documented by any of
the following Methods?
- urben transportation planning model
inputs and outputs are provided
Have all of the following nonhighway
vehicle classes been addressed in the
i nventory?
- fara equipment
- construction equipment
• industrial machinery
YES


n
n


n



a
a
a
NO COMMENTS


a 	
a


a 	



a
a
a

c»o.023
                                    3-34

-------
4.4.9       The reviewer should examine the documentation for the nonhighway
            vehicle emissions estimates and determine if the MOBILE4 model was
            used to help generate the estimates.  If an alternative approach
            such as using an equipment emission factor and an activity level
            was applied, the question should be answered No.

4.4.10      If the answer to question 4.4.9 was No, the reviewer should check
            the level of documentation of the procedure used by ensuring that
            the parameters in the checklist are provided in the inventory.
            The question should be answered No if documentation is missing for
            any vehicle class.  If documentation is missing for only one or a
            small number of classes, note this in the Comments field.

4.5  QUALITY ASSURANCE PROCEDURES


4.5.1       The reviewer should determine if quality assurance (QA) efforts of
            any type were carried out during the preparation of the inventory.
            If QA efforts were performed for any part of the inventory (e.g.,
            point sources, area sources, or mobile sources or some combination
            thereof), answer the question Yes and delineate in the Comments
            field the extent of the QA effort.

4.5.2       If question 4.5.1 was answered Yes, the reviewer should determine
            the extent to which the QA effort was documented.  The reviewer
            should determine if:  consistency checks were documented and the
            comparison values provided, completeness checks were performed and
            the comparison reference sources identified, reasonableness checks
            were made and the comparison values documented, and if proofing
            checks were made and how many iterations there were.

4.4.9
4.4.10




4.5.1

4.5.2


Was MOBILE* uMd to estimate Mi >• ions
for non-highway mobile sources?
If M06ILE4 HM net used, are the Mission
calculation procedures documented by
providing the following parantters?
- the Mission factor used
• the source of the Mission factor
Were quality assurance efforts carried
out during the development of the
inventory?
If yes, are these efforts documented in
the submitted inventory or an
accompanying plan?
YES
a



a
a
a

a

NO COMMENTS
a



a
a
a

a

eao.025
                                    3-35

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4.5.3        The  reviewer  should examine the  Inventory  documentation and
             determine 1f  EPA's PC-SAMS data  base management system was used to
             compile and report the  Inventory.   An example of a  PC-SAMS report
             Is shown In Table 3-9.

4.5.4        If some type  of QA effort was used 1n the  Inventory,  the reviewer
             should go through the checklist  provided and specify  the
             activities performed by checking Yes where appropriate.  Since the
             checks listed are somewhat subjective, the reviewer should try to
             the  best of their ability to match them with the QA activities
             described in  the inventory.
                                                   YES
                                                          NO   COMMENTS
          4.5.3   was EPA's Personal £onputer - SIP A.ir
                 Pollutant Inventory M,anagement System
                 
-------
          TABLE  3-9.   EXAMPLE  PC-SAMS  INVENTORY  OUTPUT FOR  POINT  SOURCES
Report Date: 07/31/89                              DETAILED POINT SOURCE LISTING
      Pig* 2-2
PROCESS INFORMATION

          SCC Number: 3-08-001-05       SCC Sequence Number: 01                   Laat Updated by: GOB on 07/30/89
          SCC Description: RUBBER/PLASTICS    TIRE MFC            TREAD END CEMENTG
          Type of Source: Process       Parcant Sulfur:  0.0       Pareant Asn:  0.0       Hot Contant:
          Confidentiality: Not available for public review
          Procaaa data Units: 1000 TIRES PRODUCED
          Actual Annual Process Rata:  4380         Maxima Oaaign Rata:    0.000
          03 Saaaon Dally Procasa Rata:  12           CO Saason Max 8-Hour Procass Rata:
          Procasa Laval Comment:
PROCESS EMISSIONS INFORMATION

          Pollutant: VOLATILE ORGANIC COMPOUNDS                                   Last Updated by: OCR on 07/30/89
          Primary Control Device:  DIRECT  FLAME AFTERBURNER
          Secondary Control  Device:  NO EQUIPMENT
          Control Device Efficiency: 76.5 X
          SIP Regulation in Place  ?  T       Compliance rear: 84       Emission Limitation: 25 TONS PER YEAR

          Estimation Method: CALC  USING SPECIAL EMISSION FACTO* OTHER THAN SCC        Emission Factor: 33
          Annual Nonbanked Emissions:      17 tons par year       Annual tanked Emissions:         tons per year
          Seasonal Adjustment Factor: 0.58       Rule effectiveness: 80
          03 Saason Daily Emissions:     154 IDS       CO Saason Max 8-Hour Emiiisions:         ibs
          Procass Emissions Laval  Commsnt:
PROCESS INFORMATION

          SCC Number:  3-08-001-06      SCC Sequence Number: 01                   Last Updated by: GOR on 07/30/89
          SCC Description:  RUUCR/PiASTICS     TIRE NFG            GREEN TIRE SPRAY
          Type of Source: Process      Pareant Sulfur:  0.0       Parcant Ash:   0.0       Hast Content:
          Confidentiality:  Not available for public review
          Procass Rat* Units:  1000 TIRES PRODUCED
          Actual Annual Procass Rsta: 4380          Maximum Design Rat*:    0.000
          03 Season Dally Procass Rate: 12            CO Saaaon Max 8-Hour Proems Rata:
          Procass Laval Comment:
PROCESS EMISSIONS INFORMATION

          Pollutant: VOLATILE ORGANIC COMPOUNDS                                   Last  Updated by: GDR on 07/30/89
          Primary Control  Device: DIRECT  FLAME AFTERBURNER
          Secondary Control  Device:  NO EQUIPMENT
          Control Device Efficiency: 81.0 X
          SIP Regulation in  Place 
-------
                      4.0 LEVEL II  REVIEW -  POINT SOURCES

INTRODUCTION

      The purpose of this section 1s to define Level II quality review
procedures for evaluating the stationary point source component of emission
inventory submittals.  The Level II review is presented in a checklist format
and addresses three types of review checks:   completeness, procedures and
consistency.  Blank checklists for use in performing and documenting the Level
II quality review are included in Appendix A (Table A-5).   The remainder of
this section presents detailed instructions  on how to use the checklists in
performing a Level II point source review.

INSTRUCTIONS FOR COMPLETING LEVEL II CHECKLIST

      This section contains detailed instructions for completing the Level  II
review checklist for Point Sources in Appendix A, Table A-5.  The instructions
are keyed to the checklist numbering system found in the appendix.  The
instructions contain text describing how to use the checklist, and a copy of
the actual checklist sections being described to give the reviewer a quick
reference tool as they are reading the instructions.  If the guidelines in the
instructions are not met by the inventory, or if documentation is insufficient
to determine if guidelines were met, the box for that question should be
checked "No".

      Reviewers should utilize the comment column to describe specific
findings or to qualify their summary findings as deemed necessary.  If
additional comment space is required, reviewers should attach pages as
necessary.  The reviewer should also utilize the checklist comment column to
list the location (I.e., page number(s)) in  the Inventory document where a
particular Item 1s found or discussed.  This page number accounting 1s
important for two reasons: 1) follow-up comments directed to the preparing
agency should be page number specific, and 2) successive reviews performed by
EPA can benefit by avoiding dupHcative review efforts necessary to find the
specific item in question.
c»o.023»
                                      4-1

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 Table A-5

 Question
                     Instructions
 5.1   COMPLETENESS CHECK
5.1.1       The inventory  should include small point  sources.   The absence  of
             small  point sources in the  submitted  inventory illustrates that
             the preparing  agency either failed to  understand the inventory
             preparation guidelines or blatantly refused to follow the
             guidelines.  An  inventory that does not include sources in the  10-
             25  tpy size range is incomplete,  and results in an  underestimate
             of  the total MSA emissions.

5.1.2       Check  the point  source documentation to ensure that the listed
             small  emission source types are represented.  Point sources in  the
             listed categories are expected to be present in all  MSA's.  If  one
             or  more of the categories are not represented, review the
             inventory documentation and describe applicable explanations in
             the comment column.


5.1.3       For a  typical  MSA the point source Inventory is expected to
             contain emission sources in each  of the listed categories.
5.1  COMPLETENESS CHECKS

5.1.1  Does the inventory include
      point sources for VOC in the
      10-25 tpy (actual) range?

5.1.2  Are the following VOC point
      source categories represented
      among the 10-25 tpy plant
      listings?

       - Graphic Arts
       - Coaaercial/institutional
         boilers

5.1.3  Are the following broad source
      categories represented among
      the >25 tpy VOC plant listings?

      - Storage, Transportation and
        Marketing of Petroleua
        Products and Volatile Organic
        Liquids

      - Industrial Processes
                                          a
                                          a
                                          a
                                          a
                                          a
a
a
a

a
ca». 023*
                                         4-2

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5.1.4        Review  the  point source documentation and determine if the  listed
             CO and  NOX  emission source categories are represented.   Utility
             and industrial  boilers are not necessarily present in all MSAs,
             but are expected to be common  in many areas.
5.2    PROCEDURES
5.2.1        Review the  inventory submittal  and determine  if documentation  was
             provided  to identify the methodology used for arriving at the
             point source inventory.  Briefly describe the approach in the
             comment column of the checklist (e.g., based  on existing 1985
             inventory updated to eliminated facilities that have closed, and
             updated emissions and production data through permits, quarterly
             reports,  and plant contacts).   In the checklist comment column,
             identify  the inventory document page number(s)  where the requested
             information is found.

5.2.2        The point source inventory  should reflect a 1987 or 1988 base
             year.  If a previous inventory  was used as a  starting point,
             documentation should be provided to describe  how the previous
             inventory was adjusted to reflect the '87 or  '88 base year.  In
             the checklist comment column,  identify the base year of the
             inventory and identify the  location in the inventory document
             (page number) where the base year is defined.
5.1.4  Are the following CO and NO,
      source categories represented
      among the plant  listings?

      - Utility Boilers

      • Industrial Boilers

5.2 PROCEDURES CHECKS
                                          IIS
                                        Nfl    COMMENTS
                                          >— '
EH
a
5.2.1  Does the inventory documentation
      describe the methodology used
      (i.e.,  survey, plant inspections,
       NEDs,  permit files, etc) to
      develop the point source inventory
      listing?

5.2.2  Does the point source inventory
      reflect a base year of 1987 or
      1988?
                                          r— i
                                          ' — '
o»o.023»
                                        4-3

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5.2.3       The summary emission estimates for point sources should be
            adjusted to reflect the ozone season and rule effectiveness.
            Ozone season adjustments should be based on point source operating
            schedules and quarterly process throughput Information.  Ozone
            season adjustments should be applied on a production unit level.
            Emissions should be presented as ozone season dally emissions.
            Rule effectiveness should be applied to all sources that are
            subject to SIP regulations (with minor exceptions as noted in
            Procedures for Estimating and Applying Rule Effectiveness in Post-
            1987 Base Year Inventories for Ozone and Carbon Monoxide State
            Implementation Plans -- June 1989).

5.2.4       The inventory documentation should define the month(s) that were
            assumed to reflect the MSA ozone season. In the checklist comment
            column, 11st the period identified as the ozone season and list
            the page number of the documentation where the ozone season
            determination is described.

5.2.5       Review the list of emission source categories which are covered by
            EPA Control Technique Guidelines (CTGs) (Section 3, Table 3-6) and
            determine if rule effectiveness was applied to emission estimates.

5.2.6       If an 80 percent rule effectiveness factor was applied to each of
            the categories listed in 5.2.5 check the "yes" box.  If the 80
            percent was applied only to some of the categories check the "no"
            box and make the distinction in the comment column.   The
            inventory documentation should describe any deviation from the 80
            percent rule effectiveness factor.  If the preparing agency used
            rule effectiveness factors that were different than the 80 percent
            default values, show the value used in the comment column.  Also
            in the comment column, list the page number(s) of the Inventory
            document where the alternate factor development procedures are
            described.

5.2.3

5.2.4

5.2.5




5.2.6


Were suoBsry Mission estimates
adjusted to reflect the ozone
season and rut a effectiveness?
DOM tha inventory documentation
dascriba tha methodology used to
define the ozone season?
Was rule effectiveness applied to
emission estimates for the
following point source categories?
- Surface coating of Cans
• Surface coating of Metal Coils
Was a rule effectiveness factor
of 80 percent used for all
categories?
YES
a

a




a
a
a

Sfl COMMENTS
a 	

a 	




a 	
a 	
a 	

cao.025»
                                      4-4

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5.2.7        If a contact person for the  point source  inventory is identified,
             list the  name,  address and phone number in the  comment column.

5.2.8        Select  a  subset of large  (>  25 tpy) point sources  for the purpose
             of performing a detailed  procedures check.  Randomly select a
             single  plant (i.e., record number) as the starting point of the
             subset  and  then review each  plant that chronologically follows
             until a total  of 25 percent  of the inventory has been covered.
             (For example,  detailed review should be performed  on 50 plants  if
             the point  inventory contains 200 plants. Detailed  review might
             cover those facilities with  ID numbers between  No. 72 and 122.)
             The reviewer should list  the ID numbers of plants  selected for
             detailed  review in the comment column.  The specific information
             listed  in the checklist should be compiled and  presented for each
             of the  plants.   The reviewer should check the "no" box if the
             requested  information is  not provided for more  than 90 percent of
             the selected plants.  To  assist the reviewer in locating the
             information,  Table 5-1 contains an example of how  the compiled
             information might look if the inventory was prepared using PC-
             SAMs.

5.3   CONSISTENCY CHECKS

             The following  consistency checks are included to provide an
             overall rule-of-thumb approach to assessing the quality of the
             inventory.   The ranges that  are provided were developed from a
             national perspective and  may not necessarily reflect conditions at
             any given location.  The  reviewer will have to  perform some
             calculations  to derive the comparison indices.  All  calculated
             indices should  be reported in the comment column.

5.3.1        Calculate the  percent of  the total point source VOC emissions that
             are attributed  to small (< 25 TPY) sources.  Report the small
             point total,  the point source total and the calculated value in
             the comment column.
       5.2.7.  Doe* the point source inventory documentation
             include the contact person(s) for referring
             questions?

       5.2.8  Select a subset which represents at least 25X
             of the listed point sources (in the > 25 TPY
             range) and determine if the following data
             are compiled and presented for each of these
             sources?  (Note: Identify in the comment
             colum the record maters of those plants
             that were checked).

              - Plant Name and Location
              - Operating Schedule

       5.3. CONSISTENCY CHECKS

       5.3.1  Does the SUM of emission estimates from small
             VOC point sources represent at least 5 percent
             of the total point source VOC contribution?
                                                   I£S
     COMMENTS
n
c»o.023»
                                        4-5

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5.3.2
5.3.3
Check  the "yes"  box if fugitive equipment leak  VOC emissions are
quantified.  Calculate the  ratio of  VOC emissions from equipment
leaks  to the total  from SOCMI and organic chemical manufacturing
processes and report the value in the  comment column.

Compare the unadjusted annual emission estimates  for VOC,  CO, and
NO, reported in the  base year inventory to similar estimates for
the MSA reported  in NEOs.   Report the  total annual estimates from
both sources in  the comment column and determine  if the  two
inventories agree within 25 percent. Check the  "yes" box if
agreement is within the 25  percent range.
          5.3.2   If point source VOC emissions
                 art attributed to Organic
                 chemicals manufacture or SOCMI,
                 are fugitive leaks also quantified?
                 (Fugitive equipment leak emissions
                  should be 1-10 times larger than
                  emissions fro* vents reactors etc.)

          5.3.3   Are unadjusted annual emission
                 estimates for VOC, CO and NO,
                 fro* point sources within 25X
                 of the values reported in NEOS?
                                   YE.S    j£   COMMENTS

                                   n   a
                                    a    a
c»o.023«
                                         4-6

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                  5.0 LEVEL II REVIEW-AREA STATIONARY SOURCES
INTRODUCTION
     The purpose of this section is to define Level II quality review
procedures for evaluating the area stationary source component of the emission
inventory submittal.  The Level II review is presented in a checklist format
and addresses three types of review checks: completeness, procedures, and
consistency.  Blank checklists for use in performing and documenting the Level
II quality review are included in Appendix A of this document.  The remainder
of this section presents detailed instructions on how to use the checklists in
performing the Level II review.

INSTRUCTIONS FOR COMPLETING LEVEL II CHECKLIST

      This section contains detailed instructions for completing the Level II
review checklist for area stationary sources.  A blank review checklist
covering the area stationary source category is contained in Appendix A.,
Table A-6.  The instructions presented in this section are keyed to the
checklist numbering system found in the appendix.  The instructions contain
text describing how to use the checklist, and a copy of the actual checklist
sections being described to give the reviewer a quick reference tool as they
are reading the instructions.  If the guidelines in the instructions are not
met by the inventory, or if documentation is insufficient to determine if
guidelines were met, the box for that question should be checked "No".
Reviewers should utilize the comment column to describe specific findings or
to qualify their summary findings as deemed necessary.  If additional comment
space is required, reviewers should attach pages as necessary.  The reviewer
should also utilize the checklist comment column to list the location
(i.e., page number(s)) in the inventory document where a particular item is
found or discussed.  This page number accounting is important for two reasons:
I) follow-up comments directed to the preparing agency should be page number
specific, and 2) successive reviews performed by EPA can benefit by avoiding
duplicative review efforts necessary to find the specific item in question.
c»o.023*
                                      5-1

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Table A-6

Question

6.1  COMPLETENESS  CHECK
                         Instructions
6.1.1
6.1.2
For a typical MSA  the area stationary source  inventory is expected
to  contain emission  sources in each of the listed categories.   The
reviewer can quickly determine if these categories are included by
reviewing the overall inventory  summary tables.   To assist  the
reviewer in locating this information, Table  3-9 shows an example
of  a summary table generated using PC-SAMs. If  one or more  of the
categories are not Included, review the inventory documentation
and  describe applicable explanations (and page  numbers) in  the
comment column.

For  a typical MSA  the area stationary source  inventory is expected
to  contain emission  sources in each of the listed categories.
6.2 PROCEDURES CHECK
6.2.1
Review the procedures  used for developing VOC emissions from  each
of the listed area  source categories  and determine if per capita
factors were used.  If  techniques other than per  capita values were
used,  check the "no" box and briefly  identify the approach used in
the comment column  along with the  page numbers where the approach
is described.  If emission area source emission  estimates were not
developed for the listed categories check the "no" box and denote
in the comment column.
                                                 Nfi  COMMENTS
    6.1  COMPLETENESS CHECKS

    6.1.1   DOM the inventory contain VOC area
          source Mission estimates for the
          following source categories.

          - Service Stations: Tank Truck Unloading

          - Service Stations: Vehicle Refueling

    6.1.2   Does the inventory contain CO and
          NO, area source emission estimates
          for the following stationary source
          categories?

          - Industrial Boilers

          - Conaircial Boilers

    6.2 PROCEDURES CHECKS

    6.2.1   Were area VOC emissions estimates for the
          following categories developed using per
          capita Mission factors?

          - Dry Cleaning

          * Degreasing-Cold Cleaners
                               a
                               a
                               a
                               a
a
a
a
a
                                     a
                                     a
eao.02S«
                                        5-2

-------
6.2.2       Review the documentation  supporting  the inventory submittal  and
             determine if one of the listed sources was used  for estimating
             emissions from service stations.  Denote in the  comment  column the
             source used,  along with the report page number where the approach
             is  documented.   If the documentation does not specify how gasoline
             throughput values were derived check the "no" box.

6.2.3       If  all gasoline truck unloading operations in the MSA were assumed
             to  use splash loading do  not check either of the boxes and write
             "N/A Splash  loading" in the comment  column.  If  a portion of the
             gasoline unloading in the MSA was assumed to take place  with
             submerged or balance filling methods,  determine  if the assumptions
             were based on local survey data.  If so, check the "yes"  box and
             report the percent of total gasoline throughput  in the MSA assumed
             to  be unloaded  by each method along  with the report page number
             where the supporting information is  documented.   If the  prevalence
             of  submerged  or balanced  loading was guestimated using a non-
             survey approach check the "no" box and report the approach and
             page number  in  the comment column.

6.2.4       Review the calculational  procedures  and documentations and
             determine if gasoline marketing emissions were adjusted  to reflect
             rule effectiveness.
6.2.5
Review the report  and determine if the  1.25 factor was used.
    ,6.2.2  War* gasoline throughput values (for
          estimating VOC missions from sarvica
          stations) obtained fro* one of the
          following sources:  State Fuel Tax offices.
          State or Local Transportation Agencies,
          or the Federal Highway Administration
          publication Highway Statistics?

    6.2.3  If submerged filling or balance filling
          practices were assumed for tank truck
          unloading, was the prevalence of each
          filling technique derived based on local
          survey data?

    6.2.4  If truck unloading (Stage I) or vehicle
          refueling (Stage II) controls were assumed
          to be in place, was rule effectiveness
          applied in the Mission calculations?

    6.2.5  Were the estimate* of the quantity of
          gasoline transported (for use in estimating
          VOC emissions from tank trucks in transit)
          based on 1.25 times the area-wide gasoline
          throughput?
                                  I£S
                                  n
                                   a     a


                                          a

                                          a
c»o.025»
                                         5-3

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6.2.6
6.2.7
             Review the documentation  supporting the  inventory submittal  and
             determine  if one of the listed sources was  used for estimating VOC
             emissions  from asphalt paving operations.   Denote in the  comment
             column the source used, along with the report page number where
             the information is documented. If the documentation does  not
             specify  how emissions from  asphalt paving operations were derived
             check the  "no" box.  If area  source emission  estimates were  not
             developed  for asphalt paving  operations  check the
             denote in  the comment column.
                                                                  "no"  box and
             Review the  documentation  supporting the inventory submittal  and
             determine if one of the listed methodologies   was used for
             estimating  VOC emissions  from POTWs.  Denote  in the comment  column
             the method  used, along with  the report page number where  the
             information is documented.   If the documentation does not specify
             how emissions from wastewater treatment at POTWs were derived
             check the "no" box.  If area source emission  estimates were  not
             developed for POTWs check the "no" box and denote in the  comment
             column.

6.2.8        Review the  documentation  supporting the inventory submittal  and
             determine if one of the listed reference sources was used for
             estimating  VOC emissions  from pesticide application.  Denote in
             the comment column the primary reference source used, along  with
             the report  page number where the information  is documented.  If the
             documentation does not specify how emissions  from pesticide
             application were derived  check the "no" box.   If area source
             emission estimates were not  developed for pesticide application
             check the "no" box and denote in the comment  column.
        6.2.6   Was information on cutback asphalt usage
              derived fro* one of the following sources:
              State or Local higuay department, highway
              contractors, or annual reports developed by
              the Asphalt Institute?

        6.2.7   Were the industrial wastewater flow
              estimates (used for estimating VOC
              Missions fro* POTWs) determined by one of
              the following methodologies: actual survey
              of industrial contribution to POTW flow, or
              use of the default value of 16 percent of
              total POTW flow?

        6.2.3   Were VOC emission estimates from pesticide
              use based on information obtained from
              Local, State or Federal Departments of
              Agriculture?
                                                  n
32

n
                                                                COMMENTS
                                                  n     a
                                                  a     a
c»o.025«
                                        5-4

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6.3 CONSISTENCY CHECKS

            The following consistency checks are included to provide an
            overall rule-of-thumb approach to assessing the quality of the
            area stationary source inventory.  The ranges that are provided
            were developed from a national perspective and may not necessarily
            reflect conditions at any given location.  The reviewer will have
            to perform some calculations to derive the comparison indices.
            All calculated indices should be reported in the comment column.

6.3.1       Using population data and annual VOC emission estimates for
            gasoline tank truck unloading for the MSA, express VOC emissions
            on a per capita basis.  Report the per capita factor in the
            comment column, determine if the value falls within the defined
            range, and check the appropriate box.

6.3.2       Using population data and annual VOC emission estimates for
            vehicle refueling in the MSA, express VOC emissions on a per
            capita basis.  Report the per capita factor in the comment column,
            determine if the value falls within the defined range, and check
            the appropriate box.

6.3.3       Using population data and annual VOC emission estimates for
            underground gasoline storage tank breathing and emptying losses
            within the MSA, express VOC emissions on a'per capita basis.
            Report the per capita factor in the comment column, determine if
            the value falls within the defined range, and check the
            appropriate box.

6.3.4       Using population data and annual VOC emission estimates for
            gasoline tank trucks in transit in the MSA,  express VOC emissions
            on a per capita basis.  Report the per capita factor in the
            comment column, determine if the value falls within the defined
            range, and check the appropriate box.

6.3.1

6.3.2

6.3.3

6.3.4


Are annual VOC Mission estimates for tank
truck unloading between 0.1 and 6.1 Ibs/
person?
Are annual VOC emission estimates for vehicle
refueling between 0.60 and 6.24 Ibs/person?
Are annual VOC emission estimates for tank
breathing loses between 0.33 and O.S3 Ibs/
person?
Are annual VOC emission estimates for tank
trucks in transit between 0.011 and
0.017 Ibs/person?
Hi
a



a

n

IJQ COMMENTS
a 	


^—^ _____
a 	

a 	

c«o.023«
                                      5-5

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6.3.5       Using population data and annual VOC emission estimates for
            architectural surface coating in the MSA, express VOC emissions on
            a per capita basis.  Report the per capita factor in the comment
            column, determine if the value falls within the defined range, and
            check the appropriate box.

6.3.6       Using population data and annual VOC emission estimates for
            automobile refinishing operations in the MSA, express VOC
            emissions on a per capita basis.  Report the per capita factor in
            the comment column, determine if the value falls within the
            defined range, and check the appropriate box.

6.3.7       Using population data and annual VOC emission estimates for cold
            cleaning degreasing operations in the MSA, express VOC emissions
            on a per capita basis.  Report the per capita factor in the
            comment column, determine if the value falls within the defined
            range, and check the appropriate box.

6.3.8       Using population data and annual VOC emission estimates for
            perchloroethylene-based dry cleaning operations in the MSA,
            express VOC emissions on a per capita basis.  Report the per
            capita factor in the comment column, determine If the value falls
            within the defined range, and check the appropriate box.

6.3.9       Using population data and annual VOC emission estimates for
            petroleum-based dry cleaning operations in the MSA, express VOC
            emissions on a per capita basis.  Report the per capita factor in
            the comment column, determine if the value falls within the
            defined range, and check the appropriate box.

6.3.5

6.3.6

6.3.7

6.3.8

6.3.9


Are annual VOC architectural coating
estimates between 3.5 and 4.6 Ibs/
person?
Are annual VOC Mis* ions estimates for auto
body refinishing estimates between 7.55 and
17.05 I bs/parson?
Art annual VOC Mission estimates for cold
cleaning degreasers between 2.3 and 3.0 IDS/
person?
Are VOC emission estimates from perchloro-
ethylene-based dry cleaners between 0.79
and 1.05 Ibs/person?
Are VOC emission estimates from petroleum-
based dry cleaners between 0.33 and 0.45 Ibs/
person?
IES
a

a

a

a

a

82 COMMENTS
a 	

a 	

a 	

a 	

a 	

cao.025*
                                      5-6

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6.3.10      Using  population data  and  annual VOC emission estimates  for
             graphic  arts area source operations in the  MSA, express  VOC
             emissions  on a per capita  basis.  Report  the per capita  factor in
             the comment column, determine if the value  falls within  the
             defined  range, and check the appropriate  box.

6.3.11      Using  population data  and  annual VOC emission estimates  for
             cutback  asphalt paving operations in the  MSA, express VOC
             emissions  on a per capita  basis.  Report  the per capita  factor in
             the comment column, determine if the value  falls within  the
             defined  range, and check the appropriate  box.

6.3.12      Using  population data  and  annual VOC emission estimates  for
             municipal  waste landfills  in the MSA, express VOC emissions on a
             per capita basis.  Report  the per capita  factor in the comment
             column,  determine if the value falls within the defined  range, and
             check  the  appropriate  box.

6.3.13      Using  population data  and  annual VOC emission estimates  for POTWs
             in the MSA,  express VOC emissions on a per  capita basis.   Report
             the per  capita factor  in the comment column,  determine if  the
             value  falls within the defined range, and check the appropriate
             box.

6.3.14      Using  population data  and  annual VOC emission estimates  for
             pesticide  application  in the MSA, express VOC emissions  on a per
             capita basis.   Report  the  per capita factor in the comment column,
             determine  if the value falls within the defined range, and check
             the appropriate box.
    6.3.10  Are VOC emission* from the graphic arts
          industry between 0.6 and 0.8 Ibs/person?

    6.3.11  Are VOC emissions from cutback asphalt
          paving between 0.16 and 8.47 Ibs/person?

    6.3.12  Are annual VOC emission estimates from
          municipal waste landfills between 0.12
          and 0.31 Ibs/person?

    6.3.13  Are annual VOC emission estimates from
          publicly owned treatment works (POTUs)
          between 0.37 and 1.1 Ibs/person?

    6.3.14  Are annual VOC emission estimates from
          pesticide application between 0.003 and
          0.017 Ibs/person?
YES
n

n

a

a
                                                      NO.   COMMENTS
a
a
a     n
cao.025«
                                        5-7

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              6.0  LEVEL II REVIEW - AREA HIGHWAY MOBILE SOURCES
INTRODUCTION
     The purpose of this section is define Level II quality review as it
pertains to area highway mobile sources.  As with the other parts of Level II
review, the goal is to assess the highway mobile source portion of the
inventory in terms of overall completeness, compliance with procedural
requirements, and consistency.  The completeness and procedural checks for
highway mobile sources focus primarily on the usage of MOBILE4 and how input
parameters for the model were derived.  The consistency checks represent
nationally-based comparison values for the key mobile source parameters such
as vehicle miles travelled (VMT), speed, and temperature.

     The Level II checklist for highway mobile sources is given in Appendix A,
Table A-7.  These checks, as with all Level II checks, are not meant to assess
absolute data accuracy.  Instead, they should be used to probe how well
inventory values were developed, were they developed by the accepted methods,
and do the values appear reasonable relative to surrogate checks.  Level II
checks will  aid in gauging the overall soundness of how the inventory was
prepared.  This level of soundness will serve as an indicator of inventory
quality and acceptability.

INSTRUCTIONS FOR COMPLETING LEVEL II REVIEW CHECKLIST FOR AREA HIGHWAY MOBILE
SOURCES

     Instructions for completing Table A-7 are provided below.  The
instructions are keyed to the checklist numbering system found in the
appendix.  They contain text describing how to use the checklist and a copy of
the actual checklist sections being described to give the reviewer a quick
reference tool as they are reading the instructions.  If the guidelines in the
instructions are not met by the inventory, the box for that question should be
checked "No".
c*o.025*
                                      6-1

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Table A-7
Question
                      Instructions
7.1  COMPLETENESS CHECKS

7.1.1       If the MOBILE4 model was used to determine mobile source
            emissions, the reviewer should check to make sure that all  input
            parameters have been documented.  MOBILE4 requires many input
            variables. For several inputs, the guidance manual for using the
            model recommends that the user apply a MOBILE4 default value
            instead of trying to develop local data.  For all cases where
            local data were used and not MOBILE4 defaults, the reviewer should
            make sure that documentation has been provided for the
            alternative data.
7.2  PROCEDURES CHECKS
7.2.1
The reviewer should examine the MOBILE4 documentation and
determine if MOBILE4 default values for tampering rates were used
to run the model or was site-specific tampering information used.
7.2.2       If Question 7.2.1 is answered "No," the reviewer should check to
            ensure that the alternative tampering rate data were reviewed and
            approved for use by EPA.  The documentation for the MOBILE4 runs
            should describe the basis and source of the rates and if EPA has
            approved them for use in MOBILE4.
7.1
7.1.1


7.2
7.2.1
7.2.2

COMPLETENESS CHECKS
Uere all MOBILE* input valuts docunented?
Does the documentation describe the
derivation of all non-default NOBILE4
input values?
PROCEDURES CHECKS
Uere WMILE4 defaults for tampering
rates uMd? TAnfLSr
If alternative tampering rate values were
used, did EPA review and approve the survey
on which the data were based?
IES
a



a
a

N£ COMMENTS
a 	



a 	
a 	

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                                      6-2

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   7.2.3       The documentation for the mobile source inventory should contain
               VMT estimates  for each county in the metropolitan statistical  area
               (MSA)  by vehicle class.   The eight  highway vehicle classes  are:

                   -  light-duty gasoline vehicles  (LDGV)
                   -  light-duty gasoline trucks up to  6000 Ibs
                     (LDGT1)
                   -  light-duty gasoline trucks from 6000-8500  Ibs
                     (LDGT2)
                   -  heavy-duty gasoline vehicles  (HDGV)
                   -  light-duty diesel  vehicles (LDDV)
                   -  light-duty diesel  trucks  (LOOT)
                   -  heavy-duty diesel  vehicles (HDDV)
                   -  motorcycles (MC)

               If VMT data  are  missing  for  any vehicle  class, answer the question
               "No."

   7.2.4       The reviewer should  examine  the documentation  for MOBILE4 inputs
               and determine  if the MOBILE4 default values were used for annual
               mileage accumulation rates,  registration by vehicle type, and
               registration by  vehicle  age.   If default values  were not used  for
               any one of these parameters,  answer the  question "No" and indicate
               in the Comments  field which  used site-specific data.

N/7.2.5       In running MOBILE4,  the  inventory preparer should have used the
               July ASTM volatility class value for estimating  ozone season
               gasoline Reid  Vapor  Pressure (RVP).   RVP 1s one  of the key  inputs
               to MOBILE4.  If  something other than the July value was used,
               answer the question  "No"  and indicate In the Comments field what
               value  was used.   This information should be contained in the
               documentation  for the MOBILE4 inputs.






V

7.2.3 Were MSA-specific values for VMT by vehicle
type developed?
7.2.4 Were MOBILE* default values for annual
mileage accumulation rates, and
registration distribution by vehicle type;
and age used?
'7.2.5 Was the July ASTN volatility class used
for estimating ozone season gasoline RVP?
m
a
	
LJ


n
N£ COMMENTS
n 	

	


n 	
                                                                    V/vi
4
                     /)STM
  c»o.023«
                                        6-3

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  7.2.6        The reviewer should  check the MOBILE4 Inputs  documentation to
               determine if the MOBILE4 default values were  used for the vehicle
               operating mode fractions or were site-specific  values applied.
               The default values are  as follows:

               -  percent of VMT by  non-catalyst vehicles  in
                 the cold-start mode  (PCCN) - 20.6%
               -  percent of VMT by  catalyst-equipped vehicles
                 in the hot-start mode (PCHC) - 27.3%
               -  percent of VMT by  catalyst-equipped vehicles
                 in the cold-start  mode (PCCC) - 20.6%
                                                                                  H
               If any one of the defaults  was not used, answer  the question "No
               and describe the site-specific operating mode data used in the
               Comments field.                                                 •   .-—


  7.3  CONSISTENCY CHECKS

  7.3.1        The reviewer should determine from the mobile sources emissions
               documentation if the value  used for average summertime temperature
               was between 80 and 93° F.   If the  temperature used  was  outside of
               this range, answer the question "No" and enter the value used in
               the Comments field.

V7.3.2        In terms of the documentation for computing e vapor at ive-VOC-
               lossejj  the reviewer should determine if the difference between
               the minimum and maximum  temperatures used was 24° F or  less.   If
               the difference was greater  than this value, answer the question
               "No" and indicate in the Comments field what the range was and
               reasons  given for the range used.
                                               YES     Mfl   COMMENTS

     7.2.6  Were the M08ILE4 default values used to      ,—,     ,—i
           define percent of VMT by operating node?     I—I     '—'       •


     7.3   CONSISTENCY CHECKS



     7.3.1  Was the value used for average sunaertine     ,—i     .—i
           temperature between 80 and 93°F?           I—I     '—'  	

      .3.2  Were ••xiaua and Minioua temperature        ,—r     i—<
           estiaates (for conputing evaporative VOC     '—'     '—'  	
           MiMiom) within a range of 24°F or less?
  e»o.02J«
                                         6-4

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7.3.3        The reviewer should  check the MOBILE4 inputs  for  speed to ensure
             that a value of between  2.5 and 55 miles per  hour (the range of
             M06ILE4 acceptability) was used.  If a value  out  of this range was
             used, answer the question "No" and Indicate in the Comments field
             what speed was used,  the road/vehicle type combination it was used
             for, and the justification for this speed.

7.3.4        The reviewer first needs to determine the VMT apportionment by
             road type in each county on a percentage basis.   Once the
             apportionments are calculated, the reviewer should compare the
            'figures, by each of  the  eight road types, to  the  values listed in
             the checklist.  If the calculated value 1s outside of the stated
             range, answer the question "No" and indicate  1n the Comments field
             what the calculated  apportionment was.  If VMT data were not
             provided in the inventory or if they were provided but not by road
             type, answer the question "No" and indicate such  in the Comments
             field.

7.3.5        The reviewer should  calculate the ratio of VMT/person for the MSA
             or nonattalnment area reported in the Inventory.   If more than one
             county is represented in the inventory, the ratio should be the
             sum of VMT in all the counties divided by the sum of population in
             all  of the counties.  If this ratio 1s outside of the range 1505 -
             18991, answer the question "No" and enter the calculated range in
             the Comments field.   If  VMT data are not given 1n the inventory,
             answer the question  "No" and state in the Comments field that
             there were no VMT data.
    7.3.3   Was the average assumed speed between
          2.5 and 55 mph?
  ^7.
7.3.4  Was the VMT by road type apportionment
      within the following ranges?
          - Interstate: Between 13.3 and 27.7
           percent of total VMT?

          - Other Freeway and Expressway: Between
           0 and 9.7 percent of total VMT?

    7.3.5   Is the calculated index of VMT/person
          within the 1505 to 18991 range?
                                         a
                                         a
                                         a
a
a
a
cao.023»
                                       6-5

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x/7.3.6
The reviewer should calculate the ratio of VMT/registered vehicle
for the MSA or nonattainment area reported in the inventory.  If
more than one county is represented in the inventory, the ratio
should be the sum of VMT in all the counties divided by the sum of
registered vehicles in all of the counties.  If the ratio is
outside of the range 9181 - 12,426, answer the question "No" and
enter the calculated range in the Comments field.  If VMT data are
not given in the inventory, answer the question "No" and state in
the Comments field that there were no VMT data.

Vehicle registration data should be present in the mobile sources
emissions discussion of the inventory.  If registration data are
not given in the inventory, the reviewer has several options.
First, the registration data shown in Table 6-1 could be used.
The reviewer would need to prorate the state registration data
down to the county level using population.  The calculation would
be:

(nonattainment area population/state population) x
      state vehicle registration data

If this approach is not acceptable, the reviewer should contact
the individual state's transportation, motor vehicle or other
similar governmental agency to obtain county-specific registration
data.
/7.3.6 Is the calculated index of VMT/registered
vehicle within the 9181 to 12426 range?
IE!
a
Sfi
a
COMMENTS
 c»o.025*
                                       6-6

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   TABLE 6-1.  VEHICLE REGISTRATION AND GASOLINE  SALES  DATA FOR USE
               IN COMPLETING THE AREA HIGHWAY  MOBILE  SOURCES CHECKLIST
STATE
ALABAMA
ALASKA
ARIZONA
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
DELAWARE
DIST. OF COL
FLORIDA
GEORGIA
HAWAII
IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
LOUISIANA
MAINE
MARYLAND
MASSACHUSETT
MICHIGAN
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
NEVADA
NEW HAMPSHIR
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROL I
NORTH DAKOTA
OHIO
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROL I
SOUTH DAKOTA
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINA
WASHINGTON
WEST VIRGINI
WISCONSIN
WYOMING
POPULATION
1000
3989
505
3072
2346
25795
3190
3155
614
625
11050
5842
1037
999
11522
5492
2903
2440
3720
4461
1156
4349
5798
9058
4163
2598
5001
823
1605
917
978
7517
1426
17746
6166
687
10740
3310
2676
11887
962
3302
705
4726
16083
1623
530
5636
4349
1951
4762
513
REGIST.
VEHICLES
354583
357401
2417057
1444991
20293984
3033354
2612049
490494
267851
10683590
5026220
689745
947254
7662322
3707881
2699427
2188039
2720197
2891234
927815
3308621
3886852
6944666
3171781
1760866
3712428
649762
1304946
811970
874011
5519757
1284706
9592732
4870224
650458
8521397
2887478
2242656
7642206
653824
2366144
673796
4026565
12298362
1113955
442477
4627987
3828067
1193993
3096219
478085
HWY
GAS USE
10A3 GAL
2011028
191328
630561
1156660
12162124
1507967
1354917
324265
176093
5632701
3318263
339926
427876
4603363
2630466
1266997
1786738
1758715
1958296
574907
1995427
2396437
4095153
1875488
1200223
2645297
407673
700031
545083
496305
3389648
796094
5941739
3167726
327947
4797155
1583150
1262981
1452198
378088
1368446
350085
2630164
8409515
734528
269364
2905352
2125903
797486
1937922
286861
c»o.025«
                                      6-7

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7.3.7       The  reviewer  should  calculate the ratio of VMT/gallon of gasoline
            sold for  the  MSA or  nonattainment area reported 1n the Inventory.
            If more than  one county Is represented 1n the Inventory, the ratio
            should be the sum of VMT 1n all  counties divided by the sum of
            gasoline  sales in all  of the counties.  If the ratio 1s outside of
            the  range 15.9 - 20.7,  answer the question "No" and enter the
            calculated range In  the Comments field.

            VMT  data  should be present in the Inventory documentation.  If VMT
            data are  not  given in  the Inventory,  answer the question "No" and
            state in  the  Comments  field that there were no VMT data.

            Gasoline  sales or throughput data should be available in the
            inventory documentation in either the mobile sources discussion or
            the  vehicle refueling  emissions  discussion.  If gasoline sales
            data are  not  available  in the inventory, the reviewer has several
            options.   First,  the data shown  in Table 6-1 could be used.  The
            reviewer  would need  to  prorate the state gasoline data down to the
            county level  using population.  The calculation would be:

            (nonattainment area  population/state population) x
                  state gasoline sales data

            If this approach is  not acceptable, the reviewer should contact
            the  individual  state's  transportation department or other similar
            governmental  agency  to  obtain county-specific fuel sales data.
V
                                            YEJj     MQ    COMMENTS
7.3.7   Is the calculated index of VMT/gal         ,—,     ,—•
       gasolina sold, within tha range of 15.9     '—'  •   '—'
       to 20.77
c»o.025«
                                      6-8

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              7.0 LEVEL II REVIEW-AREA NON-HIGHWAY MOBILE SOURCES
INTRODUCTION
     The purpose of this section is to define Level II quality review
procedures for evaluating the area non-highway mobile source component of the
emission inventory submittal.  The Level II review is presented in a checklist
format and addresses three types of review checks: completeness, procedures,
and consistency. Blank checklists for use in performing and documenting the
Level II quality review are included in Appendix A of this document.  The
remainder of this section presents detailed instructions on how to use the
checklists in performing the Level II review.

INSTRUCTIONS FOR COMPLETING LEVEL II CHECKLIST

      This section contains detailed instructions for completing the Level II
review checklist for area non-highway mobile sources.  A blank review
checklist covering the area stationary source category is contained in
Appendix A., Table A-6.  The instructions presented in this section are keyed
to the checklist numbering system found in the appendix.  The instructions
contain text describing how to use the checklist, and a copy of the actual
checklist sections being described to give the reviewer a quick reference tool
as they are reading the instructions.  If the guidelines in the instructions
are not met by the inventory, or if documentation is insufficient to determine
if guidelines were met, the box for that question should be checked "No".

      Reviewers should utilize the comment column to describe specific
findings or to qualify their summary findings as deemed necessary.  If
additional comment space is required, reviewers should attach pages as
necessary.  The reviewer should also utilize the checklist comment column to
list the location (I.e., page number(s)) in the inventory document where a
particular item is found or discussed.  This page number accounting is
important for two reasons: 1) follow-up comments directed to the preparing
agency should be page number specific, and 2) successive reviews performed by
EPA can benefit by avoiding duplicative review efforts necessary to find the
specific item in question.
cao.025*
                                      7-1

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Table A-8
Question
AREA NON-HIGHWAY MOBILE SOURCES
8.1    COMPLETENESS CHECK
8.1.1        For a typical MSA  the area non-highway mobile source Inventory is
             expected to contain  emission sources in each of the listed
             categories.  The reviewer can quickly determine if these
             categories are  included by reviewing the  overall Inventory  summary
             tables.  To assist the reviewer in locating this information,
             Table 3-2 shows an example of a summary table generated using  PC-
             SAMs. If one or more of the categories are  not included, review
             the inventory documentation and describe  applicable explanations
             (and page numbers) in the comment column.   If emissions estimates
             were not developed for all three of the pollutants check the "no"
             box and denote  in  the comment column.
    8.1    COMPLETENESS CHECKS                 YES

    8.1.1   Doe* the inventory contain VOC, CO and
          NOX emission estimates for the following
          off-highway sources?
           Construction Equipment
           Industrial Machinery
                          NO.  COMMENTS
                         n
                         a
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                                       7-2

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8.2 PROCEDURES CHECK

8.2.1        If agricultural activities occur within the MSA boundaries,
             emission estimates should be developed for agricultural equipment.
             If the  inventory submittal states that no agricultural activities
             take place within the MSA area then the reviewer should not check
             either  the "yes" or  "no" box but instead write "N/A no
             agricultural activities" in the comment column of questions 8.2.1
             through 8.2.5 and reference the page number in the report where
             that information is documented, and the reference sources used by
             the preparing agency to reach such a conclusion.  If the report
             simply does not discuss emissions from agricultural equipment and
             does not provide rationale for why emissions should not be
             included then the reviewer should check the "no" box and write "no
             estimate/no discussion" in the comment column of questions 8.2.1
             through 8.2.5.

             If emission estimates are provided for agricultural equipment,
             review the documentation supporting the inventory submittal and
             determine if equipment populations were determined from data in
             Census of Agriculture.  Denote in the comment column the report
             page number where the information is documented.  If the
             documentation does not specify how equipment population were
             derived check the "no" box.

8.2.2        Review the documentation supporting the inventory and determine if
             an estimate of the number of cultivated acres in each of the MSA
             counties was used to apportion agricultural equipment fuel use.
             Denote  In the comment column the report page number where the
             information is documented.

8.2.3        Check the summary tables and determine if estimates of all three
             pollutants are included.
8.2
|X*.1


\s4.2.2
8.2.3

PROCEDURES CHECKS
Uaa information on the population of
agricultural equipment item* within the
MSA counties collected using data from
the Census of Agriculture?
Was the number of acres cultivated in each
MSA county determined?
Were VOC, CO and NO, emission estimates
derived for the agricultural equipment
category?
1ES
D


n
a

tjQ COMMENTS
a 	


a 	
a 	

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                                      7-3

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8.2.4
  .2.5
8.2.6
8.2.7
Review the procedures and supporting documentation and determine
if emissions were calculated separately for each of the different
equipment types and for different fuel types (diesel and
gasoline).  Denote in the comment column the report page number
where the information is documented.  If the documentation is
insufficient to determine if emissions were calculated separately
then check the "no" box.

Review the calculational procedures and documentation and
determine if emissions were adjusted to reflect seasonal
agricultural activity.  Denote in the comment column the report
page number where the information is documented, and the seasonal
adjustment factor used. (Note: EPA recommended seasonal adjustment
factor is 1.1).

Review the documentation supporting the inventory and determine if
an estimate of the number of employees in SIC 16 was used as the
basis for apportioning heavy construction equipment counts to the
MSA level. Denote in the comment column the report page number
where the information is documented.  If a different approach was
used for deriving emissions from construction equipment check the
"no" box and briefly describe the approach.
            If the report does not discuss emissions from construction
            equipment and does not provide rationale for why emissions should
            not be estimated then the reviewer should check the "no" box and
            write "no estimate/no discussion" for questions 8.2.6 and 8.2.7.
Review the procedures and supporting documentation and determine
if emissions were calculated separately for each of the different
construction equipment types and fuel types.  Denote in the
comment column the report page number where the information is
documented.  If the documentation 1s Insufficient to determine if
emissions were calculated separately then check the "no" box.

8.2.4

^.2.5

/S.2.6

8.2.7




Were Mission calculations performed
separately for combines, balers, harvesters.
general purpose Machines, and tractors?
Were Missions estimates from agricultural
equipment adjusted to reflect seasonal
activity levels?
Were local employment statistics for SIC
16 used to estimate the number of pieces
of heavy Construction equipment in the MSA?
Were emission calculations performed
separately for the following equipment types?
• Track I ay ing tractors (diesel)
- Trecklaying loaders (diesel)
IES
n

n

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a
a
Ifi COMMENTS
a 	

a 	

a 	



a 	
a 	
c»o.023«
                                      7-4

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8.2.8
8.2.9


8.2.10
8.2.11
Review the documentation supporting the inventory and determine if
an estimate of the number of employees in SIC 10-14, 20-39, and
50-51 was used as the basis for apportioning the number of
industrial engines to the MSA level. Denote in the comment column
the report page number where the information is documented.  If a
different approach was used for deriving emissions from industrial
engines check the "no" box and briefly describe the approach.  If
the report does not discuss emissions from industrial engines and
does not provide rationale explaining why such emissions do not
occur in the MSA then the reviewer should check the "no" box and
write "no estimate/no discussion" for questions 8.2.8 and 8.2.9.
Determine if emissions (VOC, CO,and NO,)  were calculated
separately for each of the listed engine types.

Review the inventory document and determine if the number of off-
highway motorcycles were estimated using the approach described in
the procedures manual.which used motorcycle registration as a
surrogate parameter.  Denote in the comment column the report page
number where the information is documented.  If a different
approach was used for deriving emissions from off-highway
motorcycles check the "no" box and briefly describe the approach.
If the report does not discuss emissions from off-highway
motorcycles and does not provide rationale explaining why such
emissions do not occur in the MSA then the reviewer should check
the "no" box and write "no estimate/no discussion" for questions
8.2.10 and 8.2.11.

Check the summary tables and determine if estimates of all three
pollutants are included.
/
'"a.z.s


8.2.9




8.2.10

8.2.11

Were local employment statistics for SIC
codas 10-U, 20-39, and 50-51 usad to
estimata tha number of industrial anginas
in usa in tha MSA?
wara VOC, CO and MO, Mission calculations
parfonasd for tha following industrial
angina catagorias?
- Haavy duty diasal
• Haavy duty gasoline
- ti^kf Pwfy &*$
Wara off-highway motorcyle count estimates
based on tha nutter of antorcyclas
registered for on- high way usa?
Were VOC, CO and NO, emission calculations
perforated for off-highway motorcycle use?
IES
n





n
n
n

n
JB COMMENTS
a 	





a
a 	
a 	

a 	
cio.023*
                                      7-5

-------
8.2.12      Determine if the NEDS Fuel Report was used to estimate the
            quantity of fuel used in lawn and garden equipment.  Denote in the
            comment column the report page number where the information is
            documented.  If a different source was used as the basis for
            estimating fuel use check the "no" box and identify the
            alternative source. If the report does not discuss emissions from
            lawn and garden equipment and does not provide rationale for why
            emissions should not be estimated, then the reviewer should check
            the "no" box and write "no estimate/no discussion" for questions
            8.2.12 through 8.2.15.

8.2.13      Determine if separate fuel use estimates were developed for
            different small engine types (2-cycle and 4-cycle). (Note: the EPA
            recommended apportionment factor is 93 percent of total lawn and
            garden fuel consumed in 4-cycle engines, the remainder in 2-
            cycle).

8.2.14      Determine if emissions (VOC, CO,and NO,)  were calculated
            separately for each of the listed engine types.

8.2.15      Review the calculational procedures and documentation and
            determine if emission estimates for lawn and garden equipment were
            adjusted to reflect seasonal activity.  Denote in the comment
            column the report page number where the information is documented,
            and the seasonal adjustment factor used. (Note: EPA recommended
            seasonal adjustment factor is 1.3).

8.2.12

8.2.13
8.2.14
8.2.15


Was the NEDS Fuel Use Report used to
estimate the amount of fuel used annually
in lawn and garden equipment?
Was lawn and garden fuel use apportioned
by snail engine type (2-cycle and 4-cycle)?
Were VOC. CO end NO, Missions calculated
for each lawn and garden engine type?
Were (Mission estimates fro* lawn and
garden equipment adjusted to reflect
seasonal activity levels?
IES
n

a
a
a

NO. COMMENTS
a

a ^
a 	
a

c»o.025»
                                      7-6

-------
8.2.16       If no privately owned,  publicly owned or military airports are
             located within the MSA  then the reviewer should   write "N/A no
             airports" in the comment  column, and reference the page number in
             the report where that  information is documented.   If the report
             simply does not discuss emissions from aircraft  and does not state
             that there are no airports in the MSA then the reviewer should
             check the "no" box and  write "no estimate/no discussion" in the
             comment column.  If  emission estimates are provided for aircraft,
             review the documentation  supporting the inventory submittal and
             determine if aircraft activity was determined from data in one of
             the two listed sources. Denote in the comment column the page
             number in the emission  inventory report where the information is
             documented, and the  aircraft activity reference  source used.  If
             aircraft activity values  were derived from another source, or if
             the documentation does  not specify how the values were derived
             then check the "no"  box and document appropriately.

8.2.17       Determine if DOE's Energy Data Reports was used  to estimate the
             quantity of fuel used by  railroad locomotives.    If a different
             source was used as the  basis for estimating fuel  use, check the
             "no" box and identify the alternative source. If the inventory
             report does not discuss emissions from railroad  locomotives and
             does not provide rationale for why emissions should not be
             estimated, then the  reviewer should check the "no" box and write
             "no estimate/no discussion" for questions 8.2.17  and 8.2.18.

8.2.18       Review the documentation  supporting the inventory and determine if
             state-wide emissions from railroad locomotives were apportioned to
             the MSA level using  either railroad track milBAPA.  fxelght
             densjLty^ or jojujjtijua,.   Denote in the comment column the report
             page number where the information is documented.   If a different
             approach was used for deriving emissions from railroad locomotives
             check the "no" box and  briefly describe the approach.
    8.2.16  WM aircraft landing and taka-off activity
          datanatnad froai FAA Air Traffic Activity or
          Airport Activity Statistics of Certified
          Route Air Carrier*?

    8.2.17  Ware eaiiaaion estiaates for railroad
          locomotives based on quantity of fuel used
          aa recorded in DOE's Energy Oeta Reoortt?

    8.2.18  Were State-wide railroad locoantive
          emissions apportioned to the MSA by rail-
          road track Mileage, freight density, or
          population?
lii

n
Mfi
n


n

a
                                                          COMMENTS
                                       7-7

-------
8.2.19      Review the documentation supporting the inventory and determine if
            state-wide recreational boat registration data were used as the
            basis for estimating fuel consumption by pleasure boats.  Denote
            in the comment column the report page number where the information
            is documented.  If a different approach was used check the "no"
            box and briefly describe the approach.

            If the inventory report does not discuss emissions from
            recreational boats and does not provide rationale for why
            emissions should not be estimated, then the reviewer should check
            the "no" box and write "no estimate/no discussion" for questions
            8.2.19 and 8.2.20.

8.2.20      Determine if recreational boat activity was apportioned to the MSA
            level based on water surface area. (Note: the EPA recommended
            approach is described in Procedures for Emission Inventory
            Preparation Volume IV. page 7-5) Denote in the comment column the
            report page number where the information is documented.  If a
            different approach was used check the "no" box and briefly
            describe the approach.

8.2.21      Determine if DOE's Energy Data Reports were used to estimate the
            quantity of fuel used by marine vessels.  If a different source
            was used as the basis for estimating fuel use, check the "no" box
            and identify the alternative source. If the inventory report does
            not discuss emissions from marine vessels and does not provide
            rationale for why emissions should not be estimated, then the
            reviewer should check the "no" box and write "no estimate/no
            discussion" for questions 8.2.21 and 8.2.22.

8.2.22      Determine if statistics on marine vessel activity by port location
            was derived from Waterborne Commerce of the U S.  If a different
            source was used as the basis for estimating fuel use,  check the
            "no" box and identify the alternative source.

8.2.19

8.2.20

8.2.21

8.2.22


Wat futl consuaption for recreational
vehicle* based on State-wide boat
registration data?
Were the nuaber of recreational boats
(State-wide) apportioned to the MSA level
based on water surface area?
Were eaiisaion estimates for Marine vessels
based on quantity of fuel used as recorded
in OOE's Energy Data Reports?
Were statistics fro* Waterborne Commerce
of the US used to aooortion marine vessel
activity by port location?
IIS
EH

a

a

a

Mfi COMMENTS
a 	

a 	

a 	

a

00.025*
                                      7-8

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8.3 CONSISTENCY CHECKS

8.3.1       Using population data and annual VOC, CO and NO, emission
            estimates for agricultural equipment 1n the MSA, express emissions
            on a per capita basis.  Report the per capita factors for each
            VOC, CO and NO, in the comment column,  determine If the values
            fall within the defined ranges, and check the appropriate box.

8.3.2       Using population data and annual VOC, CO and NO, emission
            estimates for construction equipment in the MSA, express emissions
            on a per capita basis.  Report the per capita factors for VOC, CO
            and NO, in the comment column, determine If the values fall  within
            the defined ranges, and check the appropriate box.

8.3.3       Using population data and annual VOC, CO and NO, emission
            estimates for industrial machinery in the MSA, express emissions
            on a per capita basis.  Report the per capita factors for  VOC, CO
            and NO, in the comment column, determine if the values fall  within
            the defined ranges, and check the appropriate box.

8.3.4       Using population data and annual VOC, CO and NO, emission
            estimates for off-road motorcycles 1n the MSA, express emissions
            on a per capita basis.  Report the per capita factors for  VOC, CO
            and NO, in the comment column, determine if the values fall  within
            the denned ranges, and check the appropriate box.

8.3
8.3.1


8.3.2


8.3.3


8.3.4



CONSISTENCY CHECKS
Are annual Mission estimates for
agricultural equipment:
• between and Iba VOC/parson?
Are annual Mission estiMtes for off*
highway construction equipment:
• between 1.12 and 5.35 Iba VOC/parson?
Ara annual Mission estimates for industrial
Mditnaryi
• batMaan 0.001 and 0.003 Ibs VOC/parson?
Ara annual Mission estiMtes for off-road
motorcycles:
• between and Ibs VOC/oarson?

!ES



n


a


a


en
8fl COKNENTS



a


a


a


a

c»o.023«
                                      7-9

-------
8.3.5        Using  population data  and annual VOC,  CO and NO, emission
             estimates for lawn and garden equipment in the MSA,  express
             emissions on a per capita basis.  Report the per capita factors
             for VOC,  CO and NO, in  the  comment column,  determine  if the values
             fall within the defined ranges, and check the appropriate box.
    8.3.5  Are annual mission estimates for lawn and
          garden equipment:

          •  between 0.005 and 0.051 Ibs VOC/person?
                                              iss
n     a
             COMMENTS
c»o.023«
                                        7-10

-------
            8.0   INVENTORY REVIEW SUMMARY AND FOLLOW-UP ACTIVITIES

      At the conclusion of the initial quality review process, the Region will
need to communicate its findings back to the inventory preparation agency and
the State.  Similarly, the Region will also need to provide the Office of Air
Quality Planning  and Standards (OAQPS) with feedback on the status of the
inventory review  activities.  At a minimum, this initial communication should
include a copy of the completed checklist package found in Appendix A of this
document and a transmittal memo that summarizes the deficiencies in the
inventory as identified by the Region.

      The language in the transmittal memo should be specific and directed at
the areas needing improvement.  The memo should not just list items not
contained in the  inventory or just list mistakes.  The language should
probably be more  positive and directed.  For example, the communication needs
to say specifically what is required and where in the Inventory the material
should be placed.  The comments should tell the State exactly what they need
to do to change their inventory,  how the Region wants it done, and why it
should be done this way.  The Region should refer to the guidance materials
listed in Table 1-1 to provide backup support for their comments and
requirements.

      When the Region has finished its review process, there will need to be a
coordinator of all review comments.  Someone will need to examine Appendix A,
Table A-2 and determine the extent of the reviewers and proceed to gather and
collect all comments.  If multiple people reviewed the same sections of the
inventory, the coordinator will have to assess all the comments and composite
them into a single set that represent the Region's position.  If different
people were responsible for reviewing different parts of the Inventory (I.e.,
one for point sources, one for area, etc.), then the coordinator may only have
to pull together  each set of comments and put them in a common package.  The
Region needs to make sure it provides the State with a clear set of comments
that are consistent and non-conflicting.
emo.023*
                                      8-1

-------
      Although each Inventory and each Region will be unique, an example
outline for a transmlttal memo to send a Region's quality review comments to
the Inventory preparation agency Is provided In Table 8-1.   In general, the
memo should summarize the attached checklist, summarize Inventory
deficiencies, request clarifications, summarize required actions and changes
necessary, and provide a suggested schedule for revising the Inventory.  The
memo should also provide a list of Regional contact people for specific
Inventory parts that the State can address questions to If It needs to
reconcile a comment.

      Following the submittal of Its comments, the Region should monitor the
progress of the preparing agency In revising the Inventory.  Upon receipt of
the revised Inventory, the Region will need to evaluate 1t to ensure that all
previously Identified deficiencies have been corrected to the Region's
satisfaction.  If the revised Inventory satisfies the requirements, the Region
should send some type of correspondence to the State Indicating that the State
has met the base year Inventory requirements for that nonattainiment area.
This correspondence should be copied to OAQPS.  If the revised inventory still
does not conform to the Region's requirements, additional documentation of
deficiencies will have to be made and sent to the preparing agency.  This
process should continue until all requirements have been met.
c*o.023«
                                      8-2

-------
         TABLE 8-1.  EXAMPLE OUTLINE FOR MEMO TO TRANSMIT REGIONAL
                     OFFICE QUALITY REVIEW COMMENTS TO STATES
                                 MEMORANDUM
      DATE:
        TO:  State Air Agency Responsible for Base Year Inventory
      FROM:  EPA Regional Office
   SUBJECT:  Quality Review Comments for XYZ Nonattainment Area Base
             Year Emissions Inventory

   Introduction
   -  Define purpose of the memo
   -  Identify the EPA groups involved in the review
   -  Identify the inventory addressed by the comments in terms of the
      nonattainment area, the State, and the agencies submitting and
      preparing the inventory
   -  Outline what is contained in the memo and describe any attachments
      (e.g., the Appendix A checklists)
   Summary of Review Checklist and Identification of Deficiencies
   -  For each checklist table in Appendix A, identify missing or
      incomplete data and denote instances of "No" answers to the
      checklist questions
   -  Organize the checklist summary by individual Appendix A table
   -  For each Item where a problem has been identified, provide a
      narrative describing the deficiency, why the item 1s deficient,
      and what generally is required to correct the deficiency
   -  Ideally, a summary table like that shown below would be useful
   -  Make sure comments correspond organizationally to the numbering
      system used in the inventory submittal
c»o.023«
                                      8-3

-------
     ******************************************************************
     *  Inventory                                                     *
     *  Section/Page                       Deficiency                 *
     *                                                                *
     *  2, Table 4                         VOC data not included      *
     *                                                                *
     *  p. 5-7                             rule effectiveness not     *
     *                                     applied for Acme Chemical  *
     *  etc.                                                          *
     *                                                                *
     ******************************************************************

   Required Actions/Corrections

   -  The Region should state precisely what revisions to the draft
      inventory the State should make in order to gain approval of
      the inventory

   -  The required revisions should be clearly tied to the specific
      deficiencies outlined previously

   -  The Region should state clearly what it expects to see in terms
      of content and format of the requested revisions

   -  Use examples as necessary and refer to the published guidance
      for support

   -  In cases where additional documentation is needed, provide
      specific guidance on what type of documentation is acceptable.
      Do not make vague statements simply requesting more
      documentation.

   Schedule

   -  The Region should put forth to the State a tentative schedule
      for making the revisions and responding with a revised inventory.

   Contacts

   -  The Region should identify specific contact people at their
      offices that should be called to reconcile comments on different
      parts of the inventory.  It is likely that the State may not
      understand all or parts of some comments such that clarification
      by the Region will be necessary.
c*o.023m
                                     8-4

-------
                APPENDIX A



QUALITY REVIEW GUIDELINES CHECKLIST PACKAGE
                  A-l

-------
                             APPENDIX A
       TABLE A-l.  IDENTIFICATION OF RESPONSIBLE AGENCIES AND
                   SPECIFICATION OF GEOGRAPHIC SCOPE
 1.1  AGENCY SUBMITTING THE INVENTORY
      Name 	
      Address
      Telephone
      CONTACT PERSON
      Primary - Name .
                Title
                Telephone
      Secondary - Name 	
                  Title
                  Telephone
1.2   INVENTORY PREPARATION AGENCY
      Name 	
      Address
      Telephone
      CONTACT PERSON
      Primary - Name _
                Title
                Telephone
                                A-2

-------
      Secondary - Name .

                  Title
                  Telephone
1.3   GEOGRAPHIC AREA INCLUDED IN THE INVENTORY

      MSA Name 	
      Individual  Counties/State
      Included In the Inventory                   County Population
                                A-3

-------
                              APPENDIX A
              TABLE A-2.  INVENTORY QUALITY REVIEW RECORD
2.1   Original Inventory Receipt Date
      Received By:
         Name	
         Affiliation
         Telephone _
2.2   Inventory Review Record
      Reviewer No. 1
        Name	
        Affiliation
        Date Review
          Initiated
        Date Review
          Completed
           Focus of
             Review
      Reviewer No. 2
        Name	
        Affiliation
        Date Review
          Initiated
        Date Review
          Completed
           Focus of
             Review
                                A-4

-------
Reviewer No. 3

  Name 	
  Affiliation

  Date Review
    Initiated

  Date Review
    Completed

     Focus of
       Review
Reviewer No. 4

  Name	
  Affiliation

  Date Review
    Initiated

  Date Review
    Completed

     Focus of
       Review
Reviewer No. 5

  Name	
  Affiliation

  Date Review
    Initiated

  Date Review
    Completed

     Focus of
       Review
                          A-5

-------
 Reviewer No. 6

   Name	
   Affiliation

   Date Review
     Initiated

   Date Review
     Completed

      Focus of
        Review
Reviewer No. 7

   Name	
   Affiliation

   Date Review
     Initiated

   Date Review
     Completed

      Focus of
        Review
Reviewer No. 8

   Name	
   Affiliation

   Date Review
     Initiated

   Date Review
     Completed

      Focus of
        Review
                           A-6

-------
                            APPENDIX A

  TABLE A-3.  RECORD OF CORRESPONDENCE CONCERNING INVENTORY
              QUALITY REVIEW
3.1   Correspondence From the EPA to the State Agency
      Please provide a complete photocopy record of all correspondence
      made between the EPA Regional office and the State agency(ies)
      responsible for the submittal inventory concerning the inventory
      preparation and quality review process.  The correspondence
      should be arranged chronologically.  Attach Table A-3.1 as a
      cover sheet to the front of such correspondence.
3.2   Correspondence From the State Agency to the EPA
      Please provide a complete photocopy record of all correspondence
      made between the State agency(ies) submitting the inventory and
      the EPA Regional office concerning the inventory preparation and
      quality review process.  The correspondence should be arranged
      chronologically.  Attach Table A-3.2 as a cover sheet to the
      front of such correspondence.
                                A-7

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TABLE A-3.1  CORRESPONDENCE FROM THE EPA TO THE STATE
                        A-8

-------
TABLE A-3.2  CORRESPONDENCE FROM THE STATE TO THE EPA
                         A-9

-------
                                                               APPENDIX A
                                                   TABLE A-4.  LEVEL I  QUALITY REVIEW CHECKLIST
  .1  INVENTORY OVERVIEW
                                                                 YES       NO
 4.1.1  Is the nonattainaent area to which the inventory is      i—i      i—i
        applicable defined?                                      '—'      '—'
                                                                                                             COMMENTS
 4.1.2  Are individual counties represented in the inventory
        identified?
a      a
4.1.3  Has the 25-mile inventory requirement zone outside of
       the nonattairnent area been defined and included in
       the inventory?
n      a
4.1.4  Have each of the following pollutants been included in
       the inventory for each source type where it is applicable?

                 - Volatile Organic Compounds (VOC)

                 - Nitrogen Oxides (NOX)

                 - Carbon Monoxide (CO)
4.1.5  Are summary emission totals tables provided that are
       specific to VOC, NOX, and CO?
cn
n
a
a
a

a
a
4.1.6  Are summary emission totals provided for each
       pollutant on a county-specific basis?
a      a

-------
4.1.7  Is the calendar year basis for the baseline
       inventory specified?
 A.1.8  Have each of the following source types been
        addressed in the inventory?

                  - Stationary Point Sources (SPS)

                  - Stationary Area Sources (SAS)

                  - Highway Mobile Area Sources (HMAS)

                  - Monhighway Mobile Area Sources (NMAS)
 4.1.9  Specify the percent contribution of each of the
        source types listed in 4.1.8 to the total inventory
        emissions for VOC. HO,, and CO.
voctX)
                                            co(%)
                 - SPS


                 - SAS


                 - HMAS


                 - NMAS
 4.1.10  Do the emissions estimates for VOC, NO,, and CO
         reflect seasonal and weekday adjustments?
 4.1.11  Have adjustments been made to the VOC emissions
         estimates to reflect the non-reactive compounds
         that cannot be counted as VOC emissions.for the
         purpose of SIP attainment inventories?

 4.1.12  Have all existing regulatory requirements for
         each source category type been identified?
 4.1.13  Has rule effectiveness and rule penetration been
         factored into emissions estimates where appropriate?
                                        YES

                                        n
                                                                           NO
                                                                                                          COMMENTS
                                        n
                                        n
                                        n
                                        n
                                        n


                                        n


                                        a
a
a
a
a
a

a

a

a

-------
4.2  POINT SOURCES

4.2.1   Have all VOC point sources with actual emissions
        equal to or greater than 10 tons/yr been included
        in the inventory?
YES

n
 NO

n
                                           COMHENTS
4.2.2   Have process, point, and segment level data been
        provided for all VOC point sources with actual
        emissions equal to or greater than 25 tons/yr?
CD     n
4.2.3   Have all VOC sources in the 25-mile zone outside of
        the nonattainment area with emissions greater than
        100 tons/yr been addressed in the inventory?
4.2.4   'For sources in the 10-25 tons/yr emissions range,
        were facility-specific data used to document emissions
        estimates?
4.2.5   If facility-specific data were not used to document
        sources in the 10-25 tons/yr range, was a statistical
        extrapolation procedure used to estimate and document
        emissions?
n     a
4.2.6   If Question 4.2.5 is answered yes, are the following
        documentation parameters provided?

        -  Is the statistical survey sample set of sources
           identified?

        -  For the survey set, are locations, activity
           levels, and emissions provided?

        -  Are the activity levels of the remaining 10-25 ton
           sources specified?

        -  Is the extrapolation procedure used explained?
4.2.7   Has rule effectiveness been applied in estimating VOC
        emissions for all sources (regardless of size) where
        it is applicable?
a
a
a
a
a
a
a
a
a
a

-------
4.2.8   Have all NOX and CO sources in the MSA and 25-mile
        zone outside of the nonattainment area with emissions
        greater than 100 tons/yr been addressed in the
        inventory?


4.2.9   Have all process, point, and segment level
        documentation data required for the 100 ton NOX and
        CO sources been provided?
YES
n
 NO
n
n     n
                                                                                                           COMMENTS
4.3   AREA SOURCES


4.3.1   Have each of the following major categories of non-
        oobile area source emissions been addressed in the
        inventory?


        -  Gasoline Distribution


           -  tank truck unloading


           -  vehicle refueling


           -  underground tank breathing


           -  tank trucks in transit


        -  Dry Cleaning


           -  perchloroethylene


           -  petroleum


        -  Degreesing


           -  cold cleaning


           -  open top vapor


           -  conveyorized


        -  Surface Coating


           -  architectural


           -  auto refinishing
a
a
a
a

a
a

a
a
a

a
a
a
a
a
a

a
a

a
a
a

a
           Graphic Arts
                                                                 n

-------
- Cutback Asphalt Paving
- Asphalt Roofing Kettles/Tankers
- Pesticide Application
- Coonercial/ConsuMr Solvent Use
- Waste Management Practices
• publicly owned treatment works (POTUs)
- hazardous waste treatment, storage, and
disposal facilities (TSOFs)
- Municipal landfills
- industrial wastewater treatment
- open burning
- on- site incineration
- Commercial Bakeries
- Leaking Underground Storage Tanks
- Stationary External Conbustion
- residential (coal, oil, gas, wood)
- comercial (coal, oil, gas, wood)
- industrial (coal, oil, gas, wood)
li§
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
NO COMMENTS
a
a
a
a
	

a.
a..
n_,
a.,
a
a

a....
a., , „
-


-------
                   -  Forest Fires


                   -  Structure Fires


                   -  Slash Burning


                   -  Agriculture Burning


                   -  Orchard Heaters
           4.3.2   Are all area source emissions estimates documented
                   by providing the emission factor and activity level
                   used and the sources of these data?
                                                                 n
                                                                 a
                                                                 a
                                                                 a
                                                                 a
                                                                                     NO
         a
         a
         a
         a
         a
                                                                                                                       COMHEMTS
           4.3.3   Uhere appropriate, have point sources contributions
                   been subtracted out from area source category
                   est(Bates?
                                                                 a      a
in
4.3.4   Where appropriate, has rule effectiveness and rule
        penetration been reflected in emission estimates?
a      a
           4.4   MOBILE SOURCES

           4.4.1   Have all of the following highway vehicle classes
                   been addressed in the inventory?

                   -  light-duty gasoline vehicles UDGV)
                   -  light-duty gasoline trucks up to 6000 Ibs (LDGT1)
                    -  light-duty gasoline trucks from 6000-8500 Ibs
                      (LOGT2)

                    -  heavy-duty gasoline vehicles (HDGV)
                       light-duty diesel vehicles (LDDV)
                                                                 LJ
                                                                 a
                                                                 a
                                                                 a
                                                                 a
         a
         a
         a
         a
         a

-------
Ol
- light-duty diesel trucks (LOOT)
- heavy-duty diesel vehicles (HOOV)
- motorcycles (NC)
4.4.2 Has EPA's HOBILE4 Model been used to estimate
highway vehicle nubile source emission factors?
4.4.3 Has information been provided to docunent hou
highway vehicle Mobile source emissions estimates
were determined using MOBILE4?
4.4.4 Is information provided to document how each of the
following MOBILE* inputs was derived?
- tampering rates
- vehicle miles traveled by vehicle type
- annual mileage accumulation rates and registration
distribution by vehicle type and age
- inspection and maintenance programs
- ant i- tamper ing programs
- ASTN volatility class
- minimum and naxinua daily temperature
- base Reid Vapor Pressure (RVP)
- In-use RVP and in- use start year
lil
a
a
a
a
a
a
a
a
a
a
a
NO COMMEMTS

-
a,
a.

	


	

a.
a,
a. . ., .

-
	
a,,
-
I

-------
- altitude region
- calendar year
- speed
- ambient temperature
- operating nodes .
4.4. 5 If a procedure other than the MOBILE* model
was used to generate emission factors, was
the procedure identified and documented?
4.4.6 Are estimates of vehicle •lies traveled 
-------
           4.4.8   Have all of the following nonhighuay vehicle classes
                   been addressed in the inventory?

                   -  farm equipment
                      construction equipment
                      industrial Machinery
                      lawn and garden equipatent
                      snowmobiles
                   -  aircraft
                   -  railroad locomotives
                                                                            YES      NO
                                                                                                                     COMMENTS
a
a


a
a
a


a
a
00
                      marine vessels
           4.4.9   Was M06ILE4 used to estimate emissions for non-
                   highuay mobile sources?
n
           4.4.10  If MOBILE4 was not used, are the emission
                   calculation procedures documented by
                   providing the following parameters?

                   -  the emission factor used
                   -  the source of the emission factor
                   -  the activity level used
                   -  the source of the activity level
n      a
         a

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            4.5   QUALITY ASSURANCE  PROCEDURES

            4.5.1    Uere quality assurance efforts carried out during
                    the development  of  the inventory?
                                                                 YES

                                                                 n
 NO

n
                                                                                                            COMMENTS
 i
•—•
to
            4.5.2   If  yes,  are  these efforts documented in the  submitted
                    inventory or an accompanying plan?
4.5.3   Was EPA's Personal £omputer - SIP AJr Pollutant
        Inventory Management System (PC-SANS) used to compile
        the inventory?

4.5.4   If a quality assurance program was used (Question
        4.5.1 is answered yes), were the following activities
        performed?

        -  measures taken to ensure that the point and area
           source lists were complete

        -  alternate emission estimation procedures were
           considered

        -  the accuracy of the data collected as inputs to
           the emissions estimation procedures were checked

        -  calculations were reviewed to identify errors
                                                                             n
a

a
a
a
a
                       the reasonableness of the resulting emission
                       estimates was  evaluated

                       an independent audit of the inventory was
                       conducted
                                                                 n
n
n
                       other (please specify)
                                                                             n      n

-------
                                                                         APPENDIX A

                                               TABLE A-5.  LEVEL  II QUALITY REVIEW CHECKLIST: POINT SOURCES
 i
ro
o
           5.1  COMPLETENESS CHECKS

           5.1.1   Does the inventory  include point sources
                   for VOC in the  10-25 tpy (actual) range?
5.1.2   Are the  following VOC point source
        categories represented among the 10-25  tpy
        plant  listings?

        -  Graphic Arts

        -  Connercial/institutional boilers

        -  Industrial boilers

        -  Gasoline Bulk Plants

        -  Degrees ing Operations


5.1.3   Are the  following broad source categories
        represented among the >25 tpy VOC plant
        listings?

        -  Storage, Transportation and Marketing of
          Petroleum Products and Volatile Organic
          Liquids

        -  Industrial Processes

        -  industrial Surface Coating
                                                      YES      NO

                                                      EH     EH
                                                                                             COMMENTS
EH
EH
EH
EH
n
                                                                 EH
                                                                 EH
EH
EH
n

EH
          EH
          EH

-------
                                                                  YES
                                                                            NO
                                                                                                           COMMENTS
            5.1.4   Are the following CO and NOX  source
                    categories represented among  the plant
                    listings?

                    -  Utility Boilers

                    -  Industrial  Boilers

                    -  Comnercial/lnstitutional External
                      Fuel  Combustion

                    -  Waste Disposal/Conbustion
                                                       n
                                                       a
                                                       a
          a
          a
          a
                                                                   a       a
ro
5.2 PROCEDURES CHECKS

5.2.1   Does the inventory documentation describe
        the methodology used (i.e., survey,  plant
        inspections, NEOs, permit files, etc) to
        develop the point source inventory listing?


5.2.2   Does the point source inventory reflect a
        base year of 1987 or 1988?
            5.2.3   Were sumary emission estimates adjusted
                    to reflect the ozone season and rule
                    effectiveness?
                                                                   a       a
a

a
a

a
            5.2.4   Does the inventory documentation describe
                    the Methodology used to define  the ozone
                    season?
                                                       n       a

-------
ro
ro

5.2.5











5.2.6
5.2.7.

5.2.8










Uas rule effectiveness applied to emission
estimates for the following point source
categories?
- Surface coating of Cans
- Surface coating of Metal Coils
- Surface coating of Fabric and Vinyl
- Surface coating of Paper Products
- Coating of Automobiles and Light
duty trucks in assembly plants
- Surface coating of Metal Furniture
- Surface coating of Magnetic Wire
- Tank Truck gasoline loading Terminals
- Bulk Gasoline Plants
Uas a rule effectiveness factor of 80
percent used for all categories?
Does the point source inventory
documentation include the contact person(s)
for referring questions?
Select a subset which represents at least
25X of the listed point sources (in the
> 25 TPY range) and determine if the
fol lowing data are compiled and presented
for each of these sources? (Note: Identify in
the comment column the record numbers of those
plants that were checked).
- Plant Name and Location
- NEOS Point ID
- SIC Code
YES



n
n
n
n
n
n
n
n
n
n
n








en
a
a
NO COMMENTS



a
a
a
a
a
a
a
a
a












a
a
a


-------
ro
        - Operating Schedule


        - Applicable Regulations

        - Emission Limitations (only if subject
          to SIP Reg)


        - Compliance year (only if subject to
          SIP Reg)


        - SCC Code for Process Unit

        - Daily Process Rate and units


        - Control Equipment

        - Control Efficiency

        - Emission Estimation Method

        - Emission Factor

        - Annual Nonbanked emissions

        - Rule Effectiveness

        - Seasonal Adjustment Factor

        - Ozone season daily emissions

5.3. CONSISTENCY CHECKS

5.3.1   Does the sum of emission estimates from
        small VOC point sources represent at least
        5 percent of the total point source VOC
        contribution?
                                                                   YES

                                                                    n
                                                                    n
                                                                  NO

                                                                 n
                                                                                                        COMMENTS
a
a
a
a
a
a
a
a
a
a
             5.3.2   If point source VOC emissions are attributed   i—i
                     to Organic chemicals manufacture or SOCMI,      <—'
                     •re fugitive leaks also quantified?
                     (Fugitive equipment leak emissions should be
                      1-10 times larger than emissions from vents
                      reactors etc.)

             5.3.3   Are unadjusted annual emission estimates  for   •—.
                     VOC. CO and NOX from point sources within 25X  '—'
                     of the values reported in NEOS?
a
a
a
a
a

a
a
                                                                    n       n
                                                                 a

-------
ro
TABLE A-6. LEVEL
6.1 COMPLETENESS CHECKS
6.1.1 Does the inventory contain VOC area
source emission estimates for the
following source categories.
- Service Stations: Tank Truck Unloading
- Service Stations: Vehicle Refueling
- Service Stations: Tank Breathing Losses
- Service Stations: Tank Trucks in Transit
- Architectural Coatings
- Auto Refinishing
- Solvent Metal Cleaning-Cold Cleaners
- Dry Cleaning-Perchloroethylene
- Dry Cleaning-Petroleum
- Graphic Arts
- Cutback Asphalt
- Consuaer/CoMMrcial Solvent Use
- Municipal Waste Landfills
- Municipal Wastewater Treatment
- Pesticide Application
- Stationary External Combustion
- Structure Fires
II QUALITY
n
n
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
APPENDIX A
REVIEW CHECKLIST: AREA STATIONARY SOURCES
NO COMMENTS
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a


-------
ro
tn

6.







6.
6.












6.






1.2 Does the inventory contain CO and NOX
area source emission estimates for the
following stationary source categories?
- Industrial Boilers
- Commercial Boilers
- Waste Disposal Combustion
- Open Burning
- Structure Fires
2 PROCEDURES CHECKS
2.1 Were area VOC emissions estimates for the
following categories developed using per
capita emission factors?
- Dry Cleaning
- Degreasing-Cold Cleaners
- Architectural Surface Coating
- Graphic Arts
- Commercial/Consumer Solvent
- Waste disposal combustion (including CO
and HOX estimates)
- Open burning combustion (including CO
and NOX)
- Structure fires (including CO and NOX)
2.2 Were gasoline throughput values (for
estimating VOC emissions from service
stations) obtained from one of the
following sources: State Fuel Tax offices.
State or Local Transportation Agencies,
or the Federal Highway Administration
publication Highway Statistics?
YES



a
a
a
a
a




a
a
a
a
a
a

. — .
i — i
a
a





NO COMMENTS



a
a
a
a
a




a
a
a
a
a
a

. — .
i — i
a
a






-------
ro
en
6.2.3   If submerged filling or balance filling
         practices were assumed for tank truck
         unloading, uas the prevalence of each
         filling technique derived based on local
         survey data?

 6.2.4   If truck unloading (Stage I) or vehicle
         refueling (Stage II) controls were assumed
         to be in place, was rule effectiveness
         applied in the Mission calculations?

 6.2.5   Were the estimates of the quantity of
         gasoline transported (for use in estimating
         VOC emissions from tank trucks in transit)
         based on 1.25 times the area-wide gasoline
         throughput?

 6.2.6   Were VOC emission estimates front auto-
         mobile refinishing derived using one of
         the following approaches: survey of local
         body shops or auto painting businesses, or
         use of employee counts in SIC 7531 and 7535?

 6.2.7   Uas information on cutback asphalt usage
         derived from one of the following sources:
         State or Local higway department, highway
         contractors, or annual reports developed by
         the Asphalt Institute?

 6.2.8   Were the industrial wastewater flow
         estimates (used for estimating VOC
         emissions fro* POTWs) determined by one of
         the following methodologies: actual survey
         of industrial contribution to POTU flow, or
         use of the default value of 16 percent of
         total POTU flow?

 6.2.9   Here VOC emission estimates from pesticide
         use based on information obtained from .
         Local, State or Federal Departments of
         Agriculture?
                                                                   YES

                                                                   P


                                                                   n


                                                                   a
NO
a


a


a
                                                                                                      COMMENTS
                                                                   a       a
                                                                   a       a
                                                                   a       a
                                                                   a      a

-------
                                                       YES
                                                                 NO
                                                                                           COMMENTS
6.3  CONSISTENCY CHECKS

6.3.1   Are annual VOC emission estimates for tank
        truck unloading between 0.1 and 6.1 Ibs/
        person?

6.3.2   Are annual VOC emission estimates for vehicle
        refueling between 0.60 and 6.24 Ibs/person?
                                                                   n
                                                                   n      n
 •
CM
6.3.3   Are annual VOC emission estimates for tank
        breathing loses between 0.33 and 0.53 Ibs/
        person?

6.3.4   Are annual VOC emission estimates for tank
        trucks in transit between 0.011 and
        0.017 Ibs/person?

6.3.S   Are annual VOC architectural coating
        estimates between 3.5 and 4.6 Ibs/
        person?

6.3.6   Are annual VOC emissions estimates for auto
        body refinishing estimates between 7.55 and
        17.05 Ibs/person?

6.3.7   Are annual VOC emission estimates for cold
        cleaning degreasers between 2.3 and 3.0 Ibs/
        person?

6.3.8   Are VOC emission estimates from perchloro-
        ethylene-based dry cleaners between 0.79
        and 1.05 Ibs/person?

6.3.9   Are VOC emission estimates from petroleum-
        based dry cleaners between 0.33 and 0.45 Ibs/
        person?

6.3.10  Are VOC emissions from the graphic arts
        industry between 0.6 and 0.8 Ibs/person?
                                                                   n

                                                                   n
                                                                   n

                                                                   n

                                                                   n

                                                                   n

                                                                   a
n

n

n
n

n

n

n
6.3.11  Are VOC emissions from cutback asphalt
        paving between 0.16 and 8.47 Ibs/person?
                                                                   n      n

-------
            6.3.12  Are annual VOC emission estimates from
                    Municipal waste landfills between 0.12
                    and 0.31 Ibe/person?

            6.3.13  Are annual VOC Mission estimates from
                    publicly owned treatment works (POTUs)
                    between 0.37 and 1.1 Ibs/person?

            6.3.14  Are annual VOC emission estimates from
                    pesticide application between 0.003 and
                    0.017 Ibs/person?
YES       NO
a      a

a      a

a      a
                                                                                                              COMMENTS
J»
 I
00

-------
                                                                   APPENDIX A

                               TABLE A-7.  LEVEL II  QUALITY REVIEW CHECKLIST: AREA HIGHWAY MOBILE  SOURCES
            7.1
COMPLETENESS CHECKS
ro
to
            7.1.1   Were all MOBILE* input values documented?
                    Does the documentation describe the
                    derivation of all non-default MOBILE4
                    input values?
            7.2     PROCEDURES CHECKS

            7.2.1   Were MOB!LE4 defaults for tampering
                    rates used?     -y/fl^f pi£- S '  »
                                                   Z   !
7.2.2   If alternative tampering rate values were
        used, did EPA review and approve the survey
        on which the' data were based?

7.2.3   Were MSA-specific values for VMT by vehicle
        type developed?
            7.2.4   Were MOB I LEA default values for annual
                    •ileage accumulation rates, and
                    registration distribution by vehicle type
                    and age used?

            7.2.5   Was the July ASTM. volatility class used
                    for estimating ozone season gasoline RVP?
            7.2.6   Were the MOBILE4 default values used to
                    define percent of VMT by operating mode?
            7.3     CONSISTENCY CHECKS

            7.3.1   Was the value used for average summertime
                    temperature between 80 and 93°F?
                                                       YES

                                                       n
                                                                                                         COMMENTS
                                                                      -KJO
                                                                         7*1.1
                                                                                                                TAhPLA-~t^
                                                                                                              - 7.
                                               n       n
                                                                                      MVri
                                                                                                         Mv-
                                                                                      HS^-   -ZHOU
                                                                                           }-  '   f Tilly   AST rt
                                                                           •2.0.
                                                                                                            ^7.
                                                         n

-------
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7.3.2
7.3.3
7.3.4
7.3.5
7.3.6
7.3.7
Were maximum and minimum temperature
estimates (for computing evaporative VOC
emissions) within • range of 24°F or less?
Was the average assumed speed between
2.5 and 55 nph?
Was the VHT by road type apportionment
within the following ranges?
- Interstate: Between 13.3 and 27.7
percent of total VHT?
- Other Freeway and Expressway: Between
0 and 9.7 percent of total VHT?
- Other Principal Arterial: Between 10.5
and 29.2 percent of total VHT?
- Minor Arterial: Between 11.7 and 24.3
percent of total VMT?
- Major Collector: Between 7.1 and 19.7
percent of total VMT?
- Minor Collector: Between 0.6 and 3.9
percent of total VMT?
- Local: Between 2.6 end 45.4 percent
of total VHT?
Is the calculated index of VMT/person
within the 1505 to 18991 range?
Is the calculated index of VHT/registered
vehicle within the 9181 to 12426 range?
Is the calculated index of VHT/gal
gasoline sold, within the range of 15.9
to 20.7?
IIS
n
n
n
n
n
n
o
0
n
n
n
n
NO COMMENTS
nZs ( l^av "T&t^t — fa}n Te*~p) < Z-^V
/ /-
Q-. ,


n..

a.
n.

a.,

0 ' * T° J V f
aSf^- Talle 6-}
f i \
(Mih-/Hr«:n*tt>i flirfA hf./ST/tTf far/ X ST*re \fehl tlctd
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-------
                                                                    APPENDIX A

                            TABLE A-8. LEVEL II QUALITY REVIEW CHECKLIST: AREA NON-HIGHWAY MOBILE SOURCES
           8.1

           8.1.1
 i
U)
           8.2
8.2.1
      ^ — 8.2.2
            8.2.3
            8.2.4
           8.2.5
             .2.6
COMPLETENESS CHECKS

Does the inventory contain VOC,  CO and
NOX emission estimates for the following
off-highway sources?

- Construction Equipment

- Industrial Machinery

- Motorcycles

- Lawn and Garden equipment


PROCEDURES CHECKS

Was information on the population of
agricultural equipment items within the
MSA counties collected using data from
the Census of Agriculture?

Was the number of acres cultivated in each
MSA county determined?
Were VOC, CO and NOX emission estimates
derived for the agricultural equipment
category?

Were emission calculations performed
separately for combines,  balers,  harvesters,
general purpose machines, and tractors?

Were emissions estimates  from agricultural
equipment adjusted to reflect seasonal
activity levels?

Were local employment statistics  for SIC
16 used to estimate the number of pieces
of heavy construction equipment in the MSA?
                                                      IIS
                                                                  n
                                                                  n
                                                                  n
                                                        NO


                                                        a

                                                        a
                                                       a       a
                                                                  a
                                                                  n      n
                                                                  n      a
                                                                  a
                                                                                                  COMMENTS
                                                                           h A>t»uTe
                                                                                                                 .   Fuel
                                                                                                i'p- Ty"pej»

-------
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8.2.7
8.2.8
8.2.9
8.2.10
8.2.11
Were emission calculations performed
separately for the following equipment types?
- Tracklaying tractors (diesel)
- Tracklaying loaders (diesel)
- Motor scrapers (diesel and gas)
- Scrapers (diesel)
- Off-highway trucks (diesel)
- Wheel tractors (diesel and gas)
* Rogers (diesel and gas)
- Wheel dozers (diesel)
- Miscellaneous construction equipment
(diesel and gas)
Were local employment statistics for SIC
codes 10- U, 20-39. and 50-51 used to
estimate the number of industrial engines
in use in the MSA?
Were VOC. CO and NOX emission calculations
performed for the following industrial
engine categories?
- Heavy duty diesel
- Heavy duty gasoline
- Light duty gasoline
Were off-highway motorcyle count estimates
based on the number of motorcycles
registered for on- highway use?
Were VOC, CO and NOX emission calculations
performed for off-highway motorcycle use?
YES
n
n
n
n
n
a
a
a
a
CD
NO COMMENTS
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8.2.12 Uas the NEDS Fuel Use Report used to
estimate the amount of fuel used annually
in lawn and garden equipment?
8.2.13 Uas lawn and garden fuel use apportioned
by small engine type ( 2-cycle and
4-cycle)?
8.2.14 Uere VOC, CO and NOX emissions calculated
for each lawn and garden engine type?
8.2.15 Uere emission estimates from lawn and
garden equipment adjusted to reflect
seasonal activity levels?
8.2.16 Uas aircraft landing and take-off activity
determined from'^AA Air Traffic Activity or
*)Airport Activity Statistics of Certified
Route Air Carriers?
8.2.17 Uere emission estimates for railroad
locomotives based on quantity of fuel used
as recorded in DOE's Energy Data Reports?
8.2.18 Uere State-wide railroad locomotive
emissions apportioned to the MSA by rail-
road track' mileage, freight density, or
population?
8.2.19 Uas fuel consumption for recreational
vehicles based on State-wide boat
registration data?
V&.2.20 Uere the number of recreational boats
(State-wide) apportioned to the MSA level
based on water surface area?
8.2.21 Uere emission estimates for Marine vessels
based on quantity of fuel used as recorded
in DOE'S Energy Data Reports?
8.2.22 Uere statistics from Uaterborne Commerce
of the US used to apportion marine vessel
activity by port location?
YES
n
n
a
n
n
n
n
n
n
n
NO • COMMENTS
n f
nCTr IrJ FC £-A tMM&teM &rt S* $ P f hrt 0 H ht A+*l T&f$10lr*»
'


r-n £e«5^/ XW/'«»f«,^«f fil^ U**,l >
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-------

8.3
8.3.1




8.3.2




8.3.3




8.3.4




8.3.5





CONSISTENCY CHECKS
Are annual emission estimates for
agricultural equipment:
- between 	 and 	 Ibs VOC/person?
- between 	 and 	 Ibs CO/person?
• between 	 and 	 Ibs NO^/person?
Are annual emission estimates for off-
highway construction equipment:
- between 1.12 and 5.35 Ibs VOC/person?
- between 17.42 and 83.02 Ibs CO/person?
- between 4.85 and 23.23 Ibs N0x/person?
Are annual emission estimates for industrial
machinery:
- between 0.001 and 0.003 Ibs VOC/person?
- between and Ibs CO/oerson?
- between 	 and 	 Ibs N0x/person?
Are annual emission estimates for off-road
Motorcycles:
- between and Ibs VOC/nerson?
- between 	 and 	 Ibs CO/person?
- between 	 and 	 Ibs NO^/person?
Are annual emission estimates for lawn and
garden equipment:
- between 0.005 and 0.051 Ibs VOC/person?
- between 0.047 and 0.479 Ibs CO/person?
- between 0.001 and 0.005 Ibs NO^/person?
YES



n
n
n


n
n
n


n
n
n


n
en
n


n
n
n
NO COMMENTS























. 	 .
^






n"




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-------