EPA-450/3-75-061
June 1975
SYSTEM STUDY
AND EVALUATION OF AIR
POLLUTANT EMISSIONS
REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
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EPA-450/3-75-061
SYSTEM STUDY
AND EVALUATION OF AIR
POLLUTANT EMISSIONS
REPORT
by
George E. Umlauf
Pacific Environmental Services, Inc.
1930 Fourteenth Street
Santa Monica, California 90404
Contract No. 68-02-1378
EPA Project Officer: Archibald A. MacQueen
Prepared for
ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
June 1975
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This report is issued by the Environmental Protection Agency to report
technical data of interest to a limited number of readers. Copies are
available free of charge to Federal employees, current contractors and
grantees, and nonprofit organizations - as supplies permit - from the
Air Pollution Technical Information Center, Environmental Protection
Agency, Research Triangle Park, North Carolina 27711; or, for a fee,
from the National Technical Information Service, 5285 Port Royal Road,
Springfield, Virginia 22161.
This report was furnished to the Environmental Protection Agency by
Pacific Environmental Services, Inc. , Santa Monica, California 90404,
in fulfillment of Contract No. 68-02-1378. The contents of this report
are reproduced herein as received from Pacific Environmental Services,
Inc. The opinions, findings, and conclusions expressed are those of
the author and not necessarily those of the Environmental Protection
Agency. Mention of company or product names is not to be considered
as an endorsement by the Environmental Protection Agency.
Publication No. EPA-450/3-75-061
11
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TABLE OF CONTENTS
SECTION PAGE
I. INTRODUCTION . . . . . . . . . . . . 1-1
A. BACKGROUND 1-1
B. BRIEF HISTORY OF THE AIR POLLUTANT EMISSIONS REPORT
(APER) FORM 1-1
C. SCOPE OF PROJECT . . 1-2
D. TECHNICAL APPROACH 1-7
E. EVALUATION AND RECOMMENDATIONS 1-11
II. SOURCES OF DATA II-l
A. PREPARATION OF REGIONAL QUESTIONNAIRES . II-l
B. DATA FROM QUESTIONNAIRE RESPONSES ............. II-2
III. SYSTEM REQUIREMENTS III-l
A. CHARACTERISTICS III-l
B. USES OF THE SYSTEM III-l
C. REQUIRED DATA ELEMENTS III-3
IV. ALTERNATIVE APPROACHES IV-1
A. NEW DATA IV-1
B. PERIODIC UPDATE IV-3
V. APPRAISAL OF ALTERNATIVES . . . . V-l
A. CRITERIA DESCRIPTION V-l
B. EVALUATION OF ALTERNATIVES . . . . . . V-12
VI. FINAL RECOMMENDATIONS . VI-1
A. NEW SOURCES VI-1
B. PERIODIC UPDATES ........... VI-2
APPENDICES
A. STATE OF WISCONSIN EMISSION INVENTORY SYSTEM FACILITY
UPDATE COMPUTER PROGRAM . A-l
B. EXAMPLES OF SPECIFIC INDUSTRY FORMS FOR THE STEEL INDUSTRY . B-l
C. EXAMPLES OF SUPPLEMENTS TO TYPICAL SECTION 114 LETTERS ... C-l
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LIST OF FIGURES
FIGURE PAGE
1. ESTABLISHMENT OF NADB AS MANAGER OF APER DISTRIBUTION . 1-3
2. GROUND RULES FOR APER USES 1-5
3. TRANSMITTAL LETTER TO ACCOMPANY QUESTIONNAIRE 1-9
4. QUESTIONNAIRE FOR THE EVALUATION OF THE OMB FORM 1-10
LIST OF TABLES
TABLE PAGE
I. DATA FROM EPA SOURCES II-3
2. DEFICIENCIES FOUND IN EXISTING APER SYSTEM 11-10
3. ADDITIVE WEIGHTING MATRIX . V-13
ii
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ACKNOWLEDGEMENT
Pacific Environmental Services, Inc. wishes to sincerely thank
Mr. Archibald McQueen, EPA Project Officer, for his guidance and coopera-
tion in preparation of this report.
In addition, the contributions of the following individuals is
gratefully acknowledged.
Alexander Salpeter
Leland Marshall
Richard Seraydarian
Edmund Skernolis
Barry Bolka
Don Wallgren
Jonathan Dion
Terry Stumpf
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(page iv blank)
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I. INTRODUCTION
A. BACKGROUND
The Clean Air Act has recognized the national need for a com-
prehensive program to reduce air pollution in the United States and
provides for extensive research and enforcement activities to meet
this goal. A vital part of this program is the accumulation of basic
data for a qualitative and quantitative evaluation of air pollution
emissions from point sources. This basic information is being used to
determine the sources of emissions in a given area and their impact
on air quality. Examples of relevant uses of this information are:
Emission inventories for modeling of Air
Quality Control Regions (AQCRs);
Recognition of point sources that are not
in compliance with the requirements of
State Implementation Plans (SIPs);
Enforcement activities; and
Augmentation of state programs.
The evaluation of individual sources of air pollution must con-
sider fundamental operating procedures. This area of concern requires
the knowledge of specific process data such as product, flow rates,
both types and quantities of input materials, fuel usage, time of
operation, seasonal operating time and details of air pollution control
systems design and operation. Without this type of information, the
reliability of the base line data would be greatly reduced and false
starts in curtailment efforts may be caused.
B. BRIEF HISTORY OF THE AIR POLLUTANT EMISSIONS REPORT (APER) FORM
The APER form and data collection system was designed by EPA to
be used to gather data for development of State Implementation Plans,
determine compliance with these plans, and carry out emergency powers
pursuant to Sections 110, 111, 112, 113, 114 and 303 of the Clean Air
Act. After approval of the form by the Office of Management Budget
(OMB) in early 1972, it was initially used by the Office of Air and
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Water Programs (OAWP). When this system became available, requests
for permission to use the APER were initiated by the Regional Offices
and by the Division of Stationary Source Enforcement (DSSE). As a
result of these requests, ground rules for the use of the form were
prepared establishing NADB as the group to manage its distribution.
A major concern was the duplicate use of the form. EPA wanted to avoid
situations where more than one operating unit would send the same
request to a source. The approach to avoiding this problem is detailed
in the following communications:
Figure 1 - letter from Robert E. Neligan
Figure 2 - letter from Richard D. Wilson to
Regional Enforcement Division Directors,
Region I - X
These procedures stressed the importance of reviewing previous
communications with a company to determine that a current request was
not a duplication of data asked for at an earlier time.
To date APER has been used with some measure of success as a
method for acquiring essential emission and operational data for use
in inventories, enforcement actions and compliance evaluations. In
many instances, however, supplemental data were requested either be-
cause the individual completing the form was not diligent in its pre-
paration or the questions were misunderstood. The shortcomings of the
system may best be characterized as trying to use a form for purposes
other than those for which it was designed.
C. SCOPE OF PROJECT
The primary purpose of this project was to conduct a study of the
uses of the APER form and to prepare a report regarding the areas of,
and requirements for improvement in the form. The scope of the pro-
ject was augmented during the initial stage of investigation to con-
sider the applicability of a computer based system for requesting
emission, operational and compliance data with a simplified procedure
for information update. The investigation included interviews with
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Procedures for Using EPA/OMB Approved Questionnaire (OMB
Nr. 158-R75) to Acquire Data From Individual Sources
Mr. William Megonnell
Stationary Source Enforcement Division
Early this year the attached questionnaire was approved by OBM for
use by EPA in acquiring emissions-related information directly from
facilities discharging air pollutants into the atmosphere. Originally.
it was intended that the questionnaire would only be employed by OAWP
personnel, however, we are now receiving numerous requests from EPA
Regional Offices and DSSE personnel for questionnaires to acquire
emissions-related data for sources now being constructed. Moreover, we
expect an increasing use of this questionnaire as various groups within
EPA require source data to carry out their responsibilities in monitoring
and evaluating pollution control activities and progress.
Due to the potential political complications that could arise from
needlessly contacting private sources for information, it is mandatory
that duplicate usage of these questionnaires be strictly avoided and
that all information received be routinely incorporated into the
National Emissions Data Bank (NEDB). To insure this, the National Air
Data Branch (NADB) is managing distribution of the questionnaires.
Strict control procedures are necessary to prevent unauthorized use of
these questionnaires until EPA personnel are well aware of the potential
political hazards. A list of those persons authorized to receive
questionnaires is now being constructed by NADB. Please advise NADB
(John Bosch: FTS 919-688-8491) of the name of one DSSE representative
authorized to order and receive questionnaires. The two NEDS/SAROAD
representatives in each EPA Regional Office will also be included on
this list, together with the emission inventory contact in each
Regional Office.
Administrative rules for using the questionnaires to solicit data
directly from sources are specified in the attachment. These procedures
shall be followed by all persons employing the questionnaire for data
Figure 1: ESTABLISHMENT OF NADB AS MANAGER OF APER DISTRIBUTION
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C 0 1? Y
- 2 -
acquisition. It must be emphasized that authorization for requiring
sources to complete these questionnaires is needed in each instance
and is the sole responsibility of those persons initiating the data-
gathering program.
Robert E. Neligan
Director
Monitoring and Data
Analysis Division
Enclosures
cc:
John A.S. McGlennon, Region I
Gerald M. Hansler, Region II
Edward W. Furia, Jr., Region III
Jack E. Ravan, Region IV
Francis T. Mayo, Region V
Arthur W. Busch, Region VI
Jerome H. Svore, Region VII
John A. Green, Region VIII
Paul DeFalco, Jr., Region IX
James L. Agee, REgion X
Ken Berry, SIB
EIU:JBosch:fh:rm 647:Mu:ext 491:12:19:72
Figure 1 (continued)
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COPY
Required Procedures for Using EPA/OMB Approved Questionnaire
(OMB Nr. 158-R75) for Acquiring Emissions-Related Data
From Individual Sources
To avoid duplication of effort and to insure that all collected
data are systematically entered into the National Emission Data Bank
(NEDB), the following procedures must be followed by all EPA personnel
who utilize the OMB Nr. 158-R75 questionnaire for soliciting emissions-
related data from private sources:
1. Prior to sending out any questionnaires, the project manager
must access the National Emissions Data BAnk (NEDB) to
determine precisely what is already known by EPA about the
sources to be interrogated. This query to NEDB must be
made within 10 working days of questionnaire mailing due to
regular changes in the data base. Questionnaires should not
be sent to sources for which information is already available
in the NEDB data bank.
2. After the questionnaires are returned by the sources, the
project manager should detach the green copy and transmit
it to the NEDS/SAROAD representatives in the appropriate
EPA Regional Office.
3. The assigned NEDS/SAROAD representative in each Regional
Office shall maintain a current "green copy" file of all
questionnaires used within his regional jurisdiction.
Within three weeks of receipt, the data must be transferred
to the National Air Data Branch (NADB) for inclusion into
the data bank using normal data flow procedures between
regional offices and NADB that have been established.
4. Until remote interactive and batch terminals are fully
operational in the Regional Offices for this purpose,
inquiries regarding NADB should be directed to John C.
Bosch whose address is listed below:
Figure 2: GROUND RULES FOR APER USES
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COPY
- 2 -
John C. Bosch
Chief, Source Inventory Unit
National Air Data Branch
Room 650, Mutual Building
Research Triangle Park, N. C. 27711
FTS (919) 688-8491
5. The list of process codes attached to OMB Nr. 158-R75 is
different than the NEDS Source Classification Coding System
only because OMB Nr. 158-R75 was developed prior to
finalization of NEDS. The National Air Data Branch is
correcting this situation by recontacting OMB for approval
to use SCC Codes in lieu of the present listing. In the
interim, the coding list presently attached to the form
should be used.
Figure 2 (continued)
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users of APER, the evaluation of the use of APER in conjunction with
"Section 114" letters requesting compliance related data; and a solici-
tation of any special requirements that could be inbedded in a new
system to reduce the need for multiple requests to sources that must
supply pertinent data.
D. TECHNICAL APPROACH
The approach to analyzing the existing method of gathering data
for emission inventories and compliance evaluation embodied in the
APER procedure began with an evaluation of the form. Among the fac-
tors considered were its original intended use, subsequent uses, data
elements needed and the shortcomings of utilizing this form in a
general, all encompassing, data gathering procedure. This task was
accomplished by polling and interviewing frequent users of the APER
form, obtaining descriptions of ongoing state systems, and drawing upon
in-house experience. The users contacted were EPA personnel in several
Regional Offices and in the Division of Stationary Source Enforcement;
the state systems investigated are being used in Texas and Wisconsin;
and the in-house experience related to previous project work conducted by
the staff of Pacific Environmental Services, Inc. (PES) in the following
areas:
Emission inventories;
Compliance status evaluation;
Preparation of "114" letters;
Compliance Data Systems (CDS) analysis;
Field inspections for enforcement activities; and
Source testing.
All data obtained from these sources were organized in tabular form
to enable determination of the areas of ambiguity, places where more
specific details were necessary, and information that was redundant.
The results of this evaluation process formed the basis for the con-
clusions and recommendations set forth in this report.
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1. Questionnaire
In order to quickly acquire pertinent data for
this project, a questionnaire was designed and
sent to a representative number of individuals
in the EPA Regional Offices who have relied upon
the APER as a means of accumulating air pollution
emission data and process operational factors.
The questionnaires were followed by interviews
either in person or by telephone. The transmittal
letter and questionnaire utilized are shown in
Figures 3 and 4, respectively. A discussion of
the design of the questionnaire is detailed in
Section II.
2. Interviews
With the questionnaires serving as a stimulus for
gathering opinions relative to modification or
redesign of the APER process, a series of interviews
were conducted with regional personnel to organize
the positive and negative aspects of this approach
to data acquisition. The intent of these inter-
views was to collect general as well as specific
suggestions or complaints pertaining to the system.
It was also suggested that the individuals inter-
viewed discuss areas of the system that were not
covered in the questionnaire. All of the EPA
personnel contacted were anxious to cooperate in
this program and provided PES with meaningful input
and suggestions.
3. Review of Other Systems.
In interviews with the EPA personnel, several emission
inventory data gathering systems developed by state
air pollution offices were discussed. Two of these
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Pacific Environmental Services (PES) is under contract to EPA and NADB,
Durham, to evaluate the Air Pollution Emission Report (APER) commonly
referred to as the OMB form. As a subtask of this evaluation, PES will
be conducting interviews in several EPA Regional offices with individuals
who have had experience in the reduction of data from these forms.
In preparation for these interviews, the enclosed list of pertinent
questions is being forwarded for your comments. Please enumerate the
problems encountered in the use of the OMB questionnaire so that more
efficient use of the interview time may be provided.
A convenient time and place for your interview will be arranged as soon as
possible. The interview may be conducted in your offices, in PES
offices or by telephone.
Thank you for your cooperation, and if you have any questions, please
feel free to contact me.
Very truly yours,
Arnold Stein
Executive Vice President
Director of Engineering Applications
Figure 3: TRANSMITTAL LETTER TO ACCOMPANY QUESTIONNAIRE
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QUESTIONNAIRE FOR THE EVALUATION OF THE OMB FORK
1) How extensive lias your use of the OMB form been?
2) For what type of projects has the OMB form, been used to gather
information (i.e. NEDS, compliance evaluation)?
3) Are you aware of any.more efficient methods of data collection
used by state and local agencies in your region?
4) What comments can you make concerning the instructions which
accompany the OH3 form to aid plant personnel in its
completion? Would it be helpful to have a separate set of
Instructions for each section of the form?
5) It has been proposed to design a set of forms which would be
used for information gathering from, individual industries.
Each form would acquire specific information for a particular
industry. Whould this type of form be useful in your projects?
6) If you have found the OMB form, to be insufficient for the needs of
your projects, what alternative methods have been used for
information gathering?
7) What problems have you encountered in the use of the OMB form?
In particular, what information should be added or deleted?
Please comment on the following specific problem areas.
1) Units - Often, footnotes are ignored or overlooked and the
quantity of material processed or burned is not
determinable.
»
2) Operating hours - Operating schedules are required for each
general section of the report. These operating hours may
not pertain to all of the sources within a section however.
3} Process Descriptions - Footnotes pertaining to process codes are
ignored or overlooked. Plants have sometimes used SCC
codes or, have been given verbal descriptions of processes.
Pollutant Emissions - Plants don't often heed footnote (e) on Page 7
which requires an estimation method to be shown.
5) Combining Sources Data is sometimes given for each of the
individual sources or sometimes for the entire combined source.
Figure 4.
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systems were highly recommended and were investigated by the
PES project staff.
a. The Texas Emissions Inventory Questionnaire was reviewed
as an example of an industry specific data gathering system.
In the Texas system, a specific questionnaire can be sent
to any one of 76 different industrial sources. This type
of versatility is helpful in obtaining very detailed infor-
mation for emission inventory purposes and eliminates some
of the need for sending 114 letters after the initial
questionnaire to ask for additional information.
b. The other state system studied was the Wisconsin Emission
Inventory System. The advantages of this system included
the ability to directly code the data gathered into a com-
puter useable form. This process reduces the need for com-
plex data conversion by an engineer. Wisconsin's system
facilitates data updating by providing a computer produced
report which lists the information currently known about a
source. Company personnel modify this data as required. An
example of a typical computer produced report from the Wis-
consin system is included in Appendix A.
E. EVALUATION AND RECOMMENDATIONS
The criticisms and recommendations of the regional personnel combined
with PES' own observations, formed the basis for generating the alternatives
for modifying APER and the recommendation of the option selected. Briefly
stated the goals are the development of a system to:
Provide the software to update NEDS. These programs
would be limited to producing a computer generated
form to be completed by the company requested to supply
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the revised data. There would be no actual
mechanical interface between this system and NEDS.
However, after manual review of the form by EPA
personnel, the data could be directly keypunched
for inclusion into the NEDS update program.
Forms design for new source data. Special forms
and instructions for completion of the forms will
be prepared so that the companies questioned can
provide the necessary information for each new
source. These forms will also be compatible with
direct keypunching requirements.
Validation procedure. After the software has been
tested, several validation runs 'will be performed
on actual information received by a Regional Office
to validate the system and to correct any anomalies
that may be uncovered.
1-12
(Page 1-13 blank)
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II. SOURCES OF DATA
A. PREPARATION OF REGIONAL QUESTIONNAIRES
Directors of emission inventory projects in seven of the ten
EPA regions and several individuals in the Division of Stationary
Source Enforcement were contacted for information regarding their
experiences with the form's use. A preliminary questionnaire was
sent out followed by personal interviews. The purpose of the pre-
liminary questionnaire was to allow the EPA contact to gather data
relative to the use of the APER form and to give him an opportunity
to formulate opinions regarding the problems associated with its use
before the interview.
The first part of the questionnaire was designed to assess the
uses of the APER form. Initially, it was desired to determine how much
of a background the individual contacted had in the form's use and
the type of projects for which the form was employed. This information
was primarily required to assess the present uses of the APER form.
Also, it was hoped that possible misuses of the form could be revealed
in projects for which it was not intended. Conceivably, this type of
misuse could bias the user's viewpoint.
The most important function of the preliminary questionnaire
and interview was to discuss any problems which had been encountered
by the users of the form. Comments were requested pertaining to
general problem areas as well as specific items on the form. Each
EPA contact was asked to comment on items to be added to or deleted
from the form as indicated by his particular uses. Recommendations for
modifications to the form were then based on remedying these problem
areas.
In addition, possible changes in the structure of the form were
proposed to the users and comments were requested. EPA personnel con-
tacted were asked to propose their own recommendations for alterations to
the form. The evaluation procedure employed in Section III of this
report has taken this information into account, and in this way, the
needs of the potential users of the form have been considered.
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B. DATA FROM QUESTIONNAIRE RESPONSES
All data obtained from EPA sources in response to the regional
questionnaires is summarized in Table 1. This table shows the type of
project for which the form has been utilized and the problems which have
been encountered by each region.
1. Uses of the Existing APER Form
The APER form has been or is being used in most EPA Regional Offices
as a convenient means of gathering data for emission inventory and enforce-
ment projects. However, most regions have resorted to the use of the form
only when the data gathered by these more localized entities proved unrelia-
ble or inadequate.
In a few cases, notably in Montana, the state agencies have requested
sources in their area to complete APER forms and have subsequently forwarded
the completed forms to the EPA Regional Office for evaluation. In most
other instances, state and local agencies have developed their own forms and
these are generally used for data gathering at this level.
As a source of raw data needed for completion of emission inventories
(particularly NEDS), the APER form has been used by Region II, Region III,
and Region VIII. Region II has found the form particularly unsuitable for
gathering NEDS type data from the steel industry and incinerators. Region
VIII is currently using data from APER forms supplied by the State of Montana
Air Quality Bureau to perform an update of NEDS and perform compliance analy-
ses. A few new minor sources «100 tons per year) are also being coded for
the first time from the Montana forms. In the majority of cases in these
regions, it has been found necessary to clarify or complete the information
supplied in the APER forms by sending additional Section 114 letters.
Examples of supplements to typical Section 114 letters are shown in Appendix
C.
The largest use of the APER form has been to determine the compliance
status and relative significance of sources in a particular area. The
information supplied on the form is often compared with information supplied
by NEDS or a state agency. Region VI resorted to the use of APER forms in
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Table 1. DATA FROM EPA SOURCES
i
U)
Region
. II
III
V
VIII
IX
Name of Person*
Contacted
A. Salpeter.
L. Marshall
R. Seraydarlan
E. Skernolls
B. Bolka
D. Vallgren
J. Dlan
T. Stunpf
torn Usags Problem Areas Comment* on Use of General Comment*
(Number of form aent) Encountered an Induetry-Spaclf tc
NEUS
0
0
200
100
0
Enforcement
150
35
725 '
. 400
System
II. 1) Sources don't have II. Doesn't like the con- II. Thinks that fora
necessary Informa- cept. Thinks that la fairly good.
don. each form should be The key la proper
2) Prefers verbal accompanied by a cover use - not the
process description* letter giving detailed fora Itself.
to SCC codea. instructions for that
3) Form does not provide particular source.
sufficient cross-
referencing.
*) Estimates of ami salons
are not pivpn.
5) All emission points
aren't identified.
III. 1) Have often had to III. Would like to see a III. They think the
send out "114" letters specific fora for each fora should be
after the APl'R. industry and an Instruc- more complete and
2) Data transfer to NEDS tion sheet to accompany more specific.
is too complicated. It. Specif ically, they Besides being
3) Prefer a written deacrlp- would like to see fora* industry specific.
tion of process to SCC. for the steel Industry, the torn should be
4) Sources don't got incinerators, volatile expanded to Include
units straight. organic storage and visible emission
5) Operating hours should loading facilities. . readings. They
be listed separately stated that Pennsyt
by point. van la had developed
a good system.
. u in. I
fusing and cross- developed special forma sive successful use
referencing between for steel mills. Would of the form when
sections of form is like to see forms devel- sent with a modified
difficult. oped for other Industries. set of instructions.
They also have devel-
oped supplementary
reactive hydrocarbon
basic equipment was dif- tora were developed for use ceaafully for sources
flcult to follow. In Montana. These were used which employ experienced
pollution generating like to -see forms developed mental matters. Prob-
procesaoB. for other Industries. The lens arise when the
mates were not referenced as a working exaisple of this sources which do not
as to how they were type of system. employ this type of
determined. personnel.
4) Units of quantities re-
ported wurc not designated.
IX. 1) Sources use parts of the IX. They think a system of IX. They stated that.
preaent form to circumvent re- this type would be helpful In general, the data
porting detailed information. For for small Industrie!, such aa a* elements requested In
example, in the pollutant emission asphalt batch plants, lumber the existing APES are
estimate section of the APER, they mills, and cotton gins. sufficient, and no
would like to delete the statement, They suggest that special additional data ele-
"If unknown, please do not coonlete forma.be designed for the meats are necessary
these columns..." because sources cases where there there for this type of
use this to avoid completing the «« many small coapanles svste*.
form. ln "" i"
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Louisiana when the information available from other sources proved to be
inadequate. Its use, however, was limited to those sources which had not
previously received the form. Region IX indicated that the APER form has
been used for the compliance analysis of approximately 400 sources from
which no data had previously been received. In a majority of these cases,
it has also been found necessary to follow up the APER form with a section
114 letter. Many individuals from the Regional Offices regard the data
received on the APER form to represent a company's "official position" and to
be the firmest basis from which legal action can be taken.
2. Statuatory Authority for Gathering Data
Section 114 of the Clean Air Act provides the Administrator of the
Environmental Protection Agency or his authorized representative with authority
to enter, conduct inspections or monitor emissions from any source covered
by the New Source Performance Standards (NSPS). This authority has been used
by the Regional Offices to obtain compliance information, by the National
Air Data Branch (NADB) to secure emission inventory data and by headquarters
to develop SIPs.
The APER states that:
"A. This report is to be used to obtain information for the purpose:
1) of developing or assisting in the development of any State Implementation
Plan under § 110 or 111 (d) of the Clean Air Act, as amended (42 U.S.C. 1857
et seq), any standard of performance under S 111 of the Clean Air Act, or any
emission standard under § 112 of the Clean Air Act; 2) of determining whether
any person is in violation of any such standard or any requirement of such a
plan; or 3) of carrying out | 303 (emergency powers) of the Clean Air Act.
B. Response on all applicable sections of this report is required under
§ 114 of the Clean Air Act, as amended. Compliance may be enforced under
§ 113 of the Act by an administrative order or a civil suit by the Environ-
mental Protection Agency.
C. Information provided to the Environmental Protection Agency in
this report will be available to the public, except that upon a showing
satisfactory to the Agency by any person that such information or a
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particular part thereof (other than emmission data), if made public, would
divulge methods of processes entitled to protection as trade secrets of
such person, the Agency will consider such information or particular portion
thereof confidential in accordance with the purpose of Section 1905 of title
18 of the United States Code, except that such information may be disclosed
to other officers, employees or authorized representatives of the United
States concerned with carrying out the Clean Air Act or when relevant in
any proceeding under the Act."
One class of data requested is used as the basis for material balance
calculations to evaluate emissions but the request may also take the form
of a requirement for a company to submit source test results. Compliance
data needs may include certified copies of construction contracts or pur-
chase order for new process, equipment or air pollution control systems
along with plot plans and other discipline material.
Under the provisions of this section it is also possible for the
Administrator to designate individuals to make on-site inspections to
verify any of the statements submitted by the "source" in response to a
request for emissions or compliance related data. This authority may be
delegated to the state if the procedures for carrying out this section
of the Clean Air Act are approved by the Administrator. The Act further
states that "Nothing in this subsection shall prohibit the Administrator
2
from carrying out this section in a State."
3. Problems With The Form As Presently Used
Problems encountered when using the APER form may vary depending
on the type of project and on the type of source for which data is being
gathered. During personal interviews, EPA regional personnel were able
to cite many specific problems which they had encountered. In-house
users of the form also enumerated problems they had encountered in their
use of the form. Each user of the form described specific problems
but several general problem areas were noted from all of the users.
These problem areas were ranked in importance and the areas most in
need of correction are described first in the following discussion:
Environmental Protection Agency Air Pollution Emissions Report., OMB No.
158-R75, p.l.
2
Clean Air Act, Section 114, June 24, 1974, (printed in Environment Reporter,
the Bureau of National Affairs, Inc. p.16).
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Two of the most difficult problems were the interpretation
of the process description in Section IV and the type of com-
bustion unit in Section II. In the instructions which
accompany the APER form, the company is directed to choose
an appropriate identification number (SCC code) which des-
cribes its process or combustion unit. The company is told
to use this code instead of a word description. However,
despite the instruction's warning not to use the code
unless it specifically describes the process, many companies
list "other not classified" or "general/other" type codes
and do not supply written descriptions of the process.
Although the codes are designed to include all of the
typical processes at a facility, most plants have some
operations which are unique to that particular plant, and
the SCC codes alone are inadequate for these. Small companies
especially have problems interpreting code descriptions and
hence, usually use general codes which do not accurately
describe the process. Without a complete and specific
description of a process, including flow charts, analysis
can be very difficult.
Another problem area related to process description codes
is the confusion between source codes and process codes. Each
item in Sections II, III, and IV of the form should be given
a unique section source code, such as item Ila (Section II,
first unit) or item IVc (Section IV, third process). The
purpose of the section source code is to allow the company to
relate the data in Sections V and VI to the appropriate processes
or fuel burning units in Sections II, III and IV. Many com-
panies, however, supply process identification numbers instead
of section source codes and have no means of cross-referencing
the data in the six sections of the form. In these situations,
it is impossible to match air cleaning equipment and stack and
pollutant emission data to the basic equipment source.
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A category of problem areas can be defined which is related
to the lack of experience in dealing with emission inventory
data on the part of company personnel completing the APER
form. For instance, the concept of a point source is difficult
for company personnel to define. The actual source of
emission could be the unit of basic equipment or the associated
control equipment or the exhaust stack. Multiple sources
exhausting to a common stack are especially troublesome. Not
only is it difficult to mechanically decide which sources
should be included in the data supplied, but confusion exists
about the distinction between "basic" and "control" equipment.
For example, a CO Boiler on a cracking unit at a refinery could
be coded as control equipment because it limits CO emissions,
or it could be coded as basic equipment because it burns fuel
to produce heat.
Most emission inventory systems have provisions to deal with
these problems, but, unless a company employs a trained environ-
mental engineer, the person completing the form is not aware
of these provisions and cannot complete the form correctly.
The definition of input process weight can cause some companies
more problems than others. In a rock crushing and screening
operation, for instance, the input material is well defined
and easily measurable. However, in the oil refining process,
a fluid catalytic cracking unit can be interpreted as having
input products consisting of oil, make-up catalyst, circulating
catalyst, air, or any combination of the above. Also, in a
paint spraying operation where hydrocarbons are emitted due
to solvent evaporation, solvent, paint, or the items being
applied can be interpreted as the inlet products. The ultimate
decision as to what materials should be included in the
process weight must be made by the particular agency gathering
the data. Unless specifically directed to what materials to
include, the company will usually not provide the correct
information.
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In a few problem areas, the APER form does not ask for
information which is necessary for emission inventory
projects. It is particularly difficult to provide informa-
tion about the storage and loading of organic liquids in the
current state of the form. The form is very difficult to use
for any unconfined process.
It is difficult to specify operating hours for individual
processes. The form does not specifically ask that units be
given for process weight and other production figures. This
is one of the most frustrating problems facing the inter-
preter of the data presented on a completed form.
Finally, some of the data requested on the form cannot
realistically be expected to be known by the company. The
company is asked to predict future operating levels if they
know in advance that the current data will change in a short
time. However, companies, are not prepared to make definite
predictions about their future operations until the changes
are actually implemented.
Most of the problems encountered in the use of the APER form center
around the inability of company personnel to understand the instructions
accompanying the form and their subsequent inability to correctly complete
the form. Except for a lack of requesting specific operating hours for
each process and data for tanks and other unconfined processes, a properly
completed form would provide all the information necessary for emission
inventory purposes.
Larger companies usually employ environmental specialists who have
an understanding of emission inventory needs. These organizations can
usually be expected to complete APER forms which can be interpreted with
few problems. Small companies, on the other hand, tend to be confused by the
complexity of the form and hence, the data on the form is unreliable and often
impossible to interpret.
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Table 2 summarizes the deficiencies found in the existing APER
system and the problems encountered in its use.
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Table 2: DEFICIENCIES FOUND IN EXISTING APER SYSTEM
1. Doesn't provide for accurate process descriptions.
2. Cross-referencing between basic and control equipment is difficult.
3. Doesn't provide for a precise definition of all emission sources.
4. Operating hours cannot easily be specified for individual processes.
5. Units are not easily specified for process weight and other production
figures.
6. Data transfer to NEDS is too complicated.
7. Emission estimation methods cannot easily be defined.
8. Parts of the form can be used for circumvention.
9. The system does not specifically define what materials are included in
process weight.
10. Data for unconfined processes is difficult to report.
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III. SYSTEM REQUIREMENTS
Headquarters and Regional Offices of EPA have a need for a
systematic means of obtaining information from facilities which emit
pollutants into the atmosphere. The basic use of such a system is the
maintenance of accurate and current emission inventory data. This data
will in turn be employed by various branches within EPA and by state and
local pollution control agencies for enforcement activities, modeling
work and program evaluation.
A. CHARACTERISTICS
The system must be capable of performing two general functions:
Collection of data for sources for which no emission
inventory data exists; and
Periodic updating of existing emission inventory data.
In order to achieve these objectives the system should consist
of the following components:
1. Questionnaire type forms to be completed by plants.
2. Review procedures for validating data submitted by plants
and adding the codes and identifying numbers required by
NEDS.
3. Keypunch instructions which facilitate data entry directly
from the forms after review.
4. Computer programs which can produce "completed" fascimiles
of the form containing data which currently exists in NEDS
and which the plant can readily update.
A system which embodies these characteristics will meet the goal
of providing current emission inventory data at minimum cost to EPA and
to the sources.
B. USES OF THE SYSTEM
The user of the system will be personnel in the Surveillance and
Analysis and Enforcement branches of EPA Regional Offices. They will
use the system to obtain emission inventory and operational data. Re-
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gardless of the specific purpose of a particular request to a source for
information, the data reported on the form will be used to update the
NEDS data base.
1. Surveillance and Analysis
Surveillance and Analysis personnel will be using the system
to facilitate their responsibilities for maintaining the NEDS
data base. The APER form will be sent to sources identified
as potential large emitters for which no data currently exists
in NEDS. Surveillance and Analysis personnel may make use
of the form for periodic updating of NEDS data in situations
where the state and local agencies are not adequately
maintaining the NEDS data base.
2. Enforcement
Enforcement Branch personnel frequently require data to deter-
mine compliance status of plants. A first step in gathering
the necessary information is the examination of emission in-
ventory data. The questionnaire will be used either to obtain
information on a source not in NEDS or to get more current
information. In either case data will be entered into NEDS
as well as utilized by the Enforcement personnel. It should
be emphasized that the APER form will not replace the "114"
letter currently utilized by the Enforcement Branch. Fre-
quently information of a more detailed nature than that re-
quired by NEDS is necessary to make compliance determinations.
This information is specifically related to a particular plant
and could not be covered in a generalized procedure. Hence,
some use of "114" letters is still envisioned. However, the
basic emission inventory data will be obtained via the APER
form.
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C. REQUIRED DATA ELEMENTS
The process of determining or defining data elements runs counter
to the flow of information generally depicted in an information accumu-
lation system. The objectives and data files needed must first be
established in order that the elements of information which are necessary
can be enumerated. That appears to be the principle problem with the
APER form as used for emission inventories and for compliance evaluation.
The form was designed to be employed in developing State Implementation
Plans and found subsequent uses in several other programs. If properly
completed the form will provide a significant amount of pertinent data
for inventories and compliance evaluation. The problems arise in a lack
of specificity in instructions, the need for simplified forms for indus-
trial categories where the numbers of facilities are large but the equip-
ment is mechanically simple, i.e. wood waste burners, and in a require-
ment for industry specific forms.
Data elements for compliance and inventory needs fall into several
basic categories. These are:
Descriptive
Operational
Operating times - hrs/day, days/wk, wks/yr - seasonal
Descriptive elements of data for processes which may emit or control
the emission of air contaminants pose an intricate problem. Names and
codes have been devised by many agencies to simplify the descriptive
process but the success of these efforts have been limited. In any
complicated chemical process or mechanical system, the fundamental piece
of data is the equipment location drawing which doesn't lend itself to
ready storage in most automated data retrieval systems. This is one
informational document which probably will be stored in a filing cabinet
but which is part of the descriptive data base for most facilities that
are of interest to the data system to be designed. In a large facility
the precise location of a stack may be essential for land-use planning
and air quality modeling studies. Other descriptive data elements include:
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1. SIC code
2. SCC code
3. Company identification designator, i.e. "xyz" boiler No. 3.
4. Basic equipment description including modifiers to more closely
define a process. For example, a natural gas fired reverberatory
furnace, 20' x 40' overall dimensions, 6' x 8' hearth, 3' dia-
meter stack 40' high used for secondary smelting of brass.
5. Air pollution control system description, stating specifically
the operations, equipment and processes (cross-referenced to the
company identification system) served by the control device.
6. If applicable, the name and model number of the company that
built the system or equipment should also be stated.
7. In-plant designator to identify the specific boiler, incinerator,
or process unit to which the NEDS record applies.
Operational factors affect the use, anticipated emissions, efficiency
and expected life of systems of interest to this study. Required data must
include:
1. Fuel usage
a. Rate of consumption (hourly, daily, weekly, annual)
b. Type of fuel (solid, liquid, gaseous, combination)
c. Chemical and physical characteristics (grade or
quality, sulfur content, ash content, etc.)
d. :Firing details (types of burners, stokers, preheat
requirements, % excess air, firing point on burner
locations, etc.)
2. Process weight
This area of data acquisition has proven to be very complicated.
Questions which have arisen include: where does a process begin
and end; is intermittent storage or a surge tank the end of a
process; is there such a thing as completely closed integrated
system; how do you treat parallel and series operation; and are
several systems venting to one stack considered a single or
multiple operation? These questions must be realistically
dealt with in a system for storage, retrieval and manipulation
of air pollution emissions data. The only sound approach seems
to be the setting of ground rules considering these and many
more options and fitting as many situations as possible into
the prescribed form. However, the basic information required
to evaluate process weight is:
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a. Type and quantity (exclusive of fuel and air) of all
materials introduced into a process.
b. Rate of introduction of the materials.
3. Continuous or intermittent process
a. Hours of operation
b. Explanation of why the operation may either be continuous
or intermittent (batch loading and product removal, 24-hour
per day continuous operation as in a refinery, etc.)
4. Measured or calculated emission
a. Source test data
b. Material balance calculations
c. Observation of visible emissions by a trained observer
d. Applicable state or local air pollution control regulations.
5. Anticipated modifications to equipment or change of product
may affect emissions.
Operating times, whether daily or seasonal, are important data for
air pollution control programs. These programs may contain requirements
for supplementary control strategies, emergency shut-down operations or
other curtailment plans which specify a need to know when a facility or
system is in operation. Therefore, the hourly, daily, weekly and sea-
sonal operating times for sources of interest are mandatory.
The data described will be broken down into the finest detail
necessary to support the requirements of the system to be designed. It
is also recognized that cross-referencing is essential to avoid con-
fusion among the systems reported in large intricate facilities and for
ease in handling inventory data.
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IV. ALTERNATIVE APPROACHES
There are several alternative approaches to satisfying the require-^
ments set forth above. Each alternative is described below.
A. NEW DATA
A clear cut sentiment expressed by EPA personnel surveyed was that
the current APER questionnaire was a difficult form for data entry.
Accordingly, the new questionnaire will be designed in a fashion consistent
with modern data entry requirements. The form will embody the following
features:
Verbal data to be filled in, such as name, address, plant
contact, etc. will be entered in boxes preprinted on the
form. Below these boxes, keypunch column numbers will be
printed. Hence, this data will be keypunched directly.
Numeric data which does not require interpretation by the
reviewing engineer, such as telephone number or hours of
operation, will be handled in the -same manner as the verbal
data described above.
Data elements to be added by the reviewing personnel, such
as plant and point ID numbers, SCC codes, etc, will be
placed below a broad line on the form (or in a separate
box) clearly marked "For EPA Use Only."
Many of these features were incorporated in the Wisconsin Emission
Inventory System as shown in Appendix A.
The design of the form will be such as to make it readily com-
prehendible to the plant and EPA user and will combine the source document
and keypunch form on the same physical record. This procedure will result
in reduced data entry costs, simpler review and control procedures, more
rapid NEDS update, and more accurate data reporting. This method of forms
design will be utilized in the entire proposed questionnaire.
The types of questionnaires which have been proposed by PES staff
and by EPA personnel can be summarized into four following alternatives:
Generalized form with generalized instructions;
Generalized form with specific instructions for classes
of industries;
IV-1
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Generalized form with specific sections tailored to
classes of industries;
Simple specific forms for specific industries.
Each of these alternatives is examined in detail below.
1. General Form With General Instructions
This type of form would essentially involve restructuring
the existing APER form to include the defined data elements
and redesigning the form to facilitate data entry. A
generalized form simplifies EPA's work in that only one
form would be used. The resulting questionnaire would
suffer from some of the same problems of interpretation
that the existing APER form elicits.
2. General Form With Industry Specific Instructions
The form utilized in this approach would again be a re-
structured APER type form. The significant differences
would be a set of instructions and examples particularly
tailored to a class of industry. This approach overcomes
many of the objections to the APER form involving inter-
pretation of processes and throughput. However, it
creates an additional burden on the part of EPA personnel
in ensuring that the correct sets of instructions are sent
to sources. Also, where one plant is engaged in multiple
operations, many sets of instructions would be required.
This could present an overly complex appearance to the
plant engineer.
3. General Form With Specific Sections
This approach would, in principle, be similar to the Federal
Income Tax form, where everyone completes the basic form,
and additional sections are completed as required. By
utilizing this approach, the forms would reflect the jargon
of a particular industry. For example, the section for
grain loading would request data about tons of grain conveyed,
IV-2
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rather than "process weight." This approach facilitates
completion of the questionnaire by the source. However,
EPA's responsibilities are greater in that the correct
"package" of forms must be sent to each source. Also,
if an incorrect section is sent, the source would not
be able to make sense of it (e.g., a section for grain
loading could be sent to a chemical plant).
4. Simple Specific Forms For Classes Of Industry
In this approach, completely separate questionnaires would
be designed for each identifiable class of industry.
In some cases, such as a lumber mill, the form would be
very short and simple, whereas questionnaires for oil
refineries would be quite complex. A specific set of
forms for sources in the steel industry has been developed
and used in the EPA Region V offices. Examples of these
forms are shown in Appendix B. This approach greatly
simplifies completion of the questionnaire by the source.
However, the problem of sending the right questionnaire
to the right source could be difficult. Also, if diverse
processes are operated by the same plant, more than one
questionnaire would be required. This would force the
source to repeat some common identifying information.
B. PERIODIC UPDATE
Updating data presents a somewhat different problem than the ori-
ginal data collection process. In some cases, nothing except the date
of data changes, while in other cases entirely new processes are added.
In addition, the update process requires that the NEDS update procedures
be followed. This involves the correct combination of Add, Change, and
Delete cards. Three approaches to the update process are examined below:
1. Use of Same Form As Original Data Collection
This is the simplest method. No matter which alternative
is selected, the form, or collection of forms would be sent
to plants on a regular basis. The sources would be required
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to complete the entire form. Old NEDS data would be
deleted, and the data resulting from the new form would be
added to NEDS. This is the least satisfactory approach,
since it demands redundant work on the part of EPA and
the source.
2. Use of Computer Produced Facsimile
In this approach a computer program would print a facsimile
of the original form. Old NEDS data would be printed or
output by the system and blank spaces would be printed
where the plant could fill in current data. Boxes would
be printed where sources could indicate closed facilities.
Additionally, blank forms would be included for use when
new processes are added to plants. This approach would
require the EPA reviewer to determine the required NEDS
action code (A,C, or D) when a card is to be punched. The
source's efforts are minimized, particularly where no
changes have occurred. The data entry load is minimized,
since cards are punched only when a change is indicated.
3. Automated Facsimile
This approach embodies 2 above. However, it further simpli-
fies EPA's procedures by automatically determining the NEDS
action code. It would require a computer program to compare
cards punched from the questionnaire with the existing NEDS
data base. This comparison will indicate whether a card
should have an A,C, or D code.
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V. APPRAISAL OF ALTERNATIVES
In order to appraise the alternatives and select the most desirable
one, the technique of additive weighting is being employed. Additive
weighting is a procedure that encourages the user to logically choose
among his alternatives. The process involves defining independent
evaluation criteria and evaluating the alternatives relative to the
criteria. The user defines the criteria and assigns a weighting factor
to each. The weighting factors should describe the relative importance
of each criteria.
Values are assigned to each alternative for each of the criteria.
These values have a relative importance for each alternative and criterion.
If the alternative appears favorable under the criterion it should be awarded
a high value, and vice versa for an unfavorable assessment.
The evaluation process begins with a definition of the criteria.
A. CRITERIA DESCRIPTION
1. Comprehehdibility by Plant Personnel
The plant engineer or manager must be able to readily under-
stand what data are desired and how to report them correctly.
This is considered to be the most important criteria for jud-
ging the alternative strategies because in many cases, the
plant personnel have the desired information available but
are not able to report it because of confusion over the wording
and/or structure of the reporting forms and their accompanying
instructions. The wording of the form and the instructions
can be especially helpful to the plant personnel if jargon
from the particular industry is used. Examples of correctly
reported data can also be very helpful to individuals who are
not familiar with emission inventory data.
With these factors in mind, the grading of the alternatives and
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the existing APER was performed with respect to the cri-
terion of comprehendibility by plant personnel. The existing
APER was given a grade of 1 corresponding to a very poor
evaluation. The APER suffered from the inherent drawback
of a general form with general instructions. Its wording
was required to address all sources and could not use
specific terms. Instructions which accompanied the APER were
void of even general examples of correctly reported data.
Also, footnoted instructions printed on the forms were un-
successful in helping the plant personnel and caused more
confusion.
The first alternative replacement, a redesigned general form
with rewritten general instructions, would suffer from the
same inherent drawbacks as the APER. However, the addition of
generalized examples and a clear description of the desired
data elements would improve the comprehendibility of the system,
so this alternative was given a slightly below-average grade of
4.
Comprehendibility by the plant would be greatly enhanced in the
remaining alternatives since they all would make use of industry-
specific language to request the desired data. Of the three
alternatives, the general forms with industry-specific sections
would be slightly less comprehendible than the other two al-
ternatives. Since these forms would be accompanied by general
instructions, no specific examples of correctly reported forms
would be supplied. Also, if the plant was sent specific sections
which wene not applicable to the processes being reported, the
added clarity of this alternative would be lost and comprehen-
dibility would be reduced. This alternative was assigned a
grade of 7 which is equivalent to very good comprehendibility
by plant personnel.
Alternatives 2 and 4 were both given grades of 8. They were
rated slightly higher than alternative 3 but were still not
V-2
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given excellent grades in comprehendibility. The generalized
form with specific instructions would contain specific
examples of correctly completed forms for the particular in-
dustry. Some of the confusion caused by a generalized form
would still be inherent in this system. The entirely
specific forms would be the most clomprehendible by plant managers
unless an inappropriate form was sent. In this case, the source
personnel would be very confused and not able to provide any
pertinent information.
2. Process Description
One of the most important tasks in the compilation of an emission
inventory is the estimation of pollutant emissions. Detailed
process information is important to the completion of this task
and an exact process description is the most critical piece of
information required. The need for the information is twofold.
Firstly, the process description must provide enough data to
allow the EPA reviewer to determine emission factors for the
process so that emission estimates may be calculated. Secondly,
for NEDS purposes, the EPA reviewer must be able to correctly
determine an SCC code for the process. For enforcement purposes,
a precise process description is necessary to determine applicable
air pollution control regulations for a process. This criterion
is given a slightly higher weighting factor than the other
emission estimate criteria because clear process descriptions
allow the EPA reviewer to have a good understanding of exactly
what is being done at the plant.
In the grading of the alternatives, the APER received a very
poor grade of 1. The existing system required the plant to
supply an SCC code description for each process. This was an
unrealistic request for most plants, and the resulting process
descriptions were often impossible to interpret.
A revised general system should not require SCC codes, and
therefore, would be graded higher than the existing APER. How-
V-3
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ever, without specific examples of complete process descrip-
tions, the plant could supply incomplete or confusing des-
criptions. This alternative was given a slightly below
average grade of 4.
The system of general forms with industry specific sections
and the system of entirely specific forms both suffer from the
inability to allow the source to supply process descriptions.
In the construction of specific forms, typical processes are
assumed, and data is requested for these typical processes.
The plant is not given the opportunity to describe any pro-
cesses which are not typical. Therefore, these alternatives
were both graded as slightly below average.
The alternative of using general forms and industry-specific
instructions provides the best opportunity for complete and
clear process descriptions. Examples of typical descriptions
would be included in the instructions, but the general form
would allow the source to give descriptions of atypical
processes. This latter alternative provides the best oppor-
tunity for the source to provide accurate process descrip-
tions and was rated as very good.
3. Definition of Process Weight
Another piece of necessary information supplied by plant
personnel for the determination of emission estimates is a
reasonable approximation of the applicable process weight for
each source. Using the process weight and emission factors,
the EPA reviewer can make reasonable emission estimates for
each source. Process weight is defined in most SIP regula-
tions as the material introduced to a process which causes
emissions. In a specific process, however, many varied
interpretations can exist as to what materials are included
in process weight. It is therefore very important that
in cases where ambiguous interpretations may occur, an
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approved definition of process weight is presented to the
plant personnel.
Since no explanations of this kind can be provided in a general
form, the existing APER and the revised generalized system
were both given poor grades of 2. Industry-specific systems,
on the other hand, are capable of defining these ambiguous
areas and providing accepted interpretations of what materials
should be included in process weight. The alternative of
generalized forms with specific instructions would be able
to clarify what is meant by process weight for typical pro-
cesses but would not provide this guideance for atypical
processess which could be reported on the general form. The
industry specific forms would not request data on these a-
typical processes so any ambiguous definitions in the normal
process would be clarified in the construction of the form.
The two industry specific form systems received grades of 9,
and the system utilizing industry specific instructions was
given a slightly lower, but still very good grade of 8.
Definition of Required Units
It is obvious that any numerical information, including
process weight, is meaningless unless units are clearly identi-
fied. This piece of information is particularly critical when
the preparation of emission inventory data base information is
considered. Since a standard set of units is understood for
numerical information in the data base, all reported infor-
mation must be convertible into that standard set. The
weighting factor for this criterion is no higher or lower
than any of the other emission estimation criteria since all
are needed to complete the critical inventory categories.
The specification of units in a specific system of forms is
straightforward in that the required data units are defined
on the form. The only disadvantage occurs when the source must
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convert data units from their recorded units to the system's
required units.
In specific instructions accompanying general forms, suggested
units can be indicated and the general form can provide space
for the source to specify the units of the data reported. This
system would be graded as high as the two specific form systems
except for the fact that the company's specified units may not
be convertible to the required units without further information.
The generalized system suffers from the drawbacks inherent with
general forms as presented above. Also, specific examples of
industry units would not be available to the sourcxe, so this
alternative was graded well below the other alternatives.
In the existing APER, little specification of units is requested,
so the reported numeric data is often meaningless. The existing
system is given a very poor grade based on this criterion.
5. Specification of Hours of Operation
The final emission estimation criterion is the specification of
operating hours for each piece of basic equipment or process.
This data is necessary for the completion of the NEDS hours
of operation category. Also, in many enforcement regulations,
emission limits are based on hourly operating rates, so the
operating hours are necessary to convert yearly rates to hourly
rates. Emission estimates may sometimes be given in hourly
rates and yearly estimates for NEDS may be calculated if opera-
ting hours are known. The weighting factor for this criterion
is the same as the previous emission estimation criteria since
all are equally important in the calculation of emission esti-
mates.
The grading of the proposed alternatives does not differentiate
between the four systems since all could equally satisfy the
requirements of this criterion. Whether the system is general
or specific, operating hours must be requested for each process
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which is reported. The existing APER system does not
request this information specifically so this system was
given a very poor grade of 1.
6. Cross-Referencing Between Basic and Control Equipment
This criteria also relates to the task of making accurate
estimates of pollutant emissions from equipment and processes.
Emission factors may be determined from process descriptions
and uncontrolled emissions may be estimated in this manner.
If pollution control equipment is associated with the equipment
or process, the emissions will be reduced. Therefore, it is
important that the source be able to readily report any pollu-
tion control equipment and associate it with the basic equip-
ment or process controlled. This criterion is weighted slightly
below the other emission estimation criteria since estimates
of uncontrolled emissions can be made without control informa-
tion.
In a generalized system, cross-referencing is established be-
tween the sections of the form which relate control equipment
to basic equipment. In the APER system, this was especially
confusing and difficulties arose when control equipment served
multiple sources. In a revised generalized system, control and
process information would still be reported in separate sections
and a cross-referencing scheme would have to be utilized. Any
such scheme would be confusing to source personnel so this
alternative was assigned a poor grade of 3. The addition of
specific instructions could help alleviate some of this con-
fusion but the inherent drawbacks of the general form would
still be present. This alternative was given a score of 5
corresponding to an average evaluation in this criterion.
A special section of a generalized form would address specific
control devices on particular processes or basic equipment.
This would require cross-referencing between sections, but
V-7
-------
since only specific data would be associated, confusion
would be reduced. This alternative was given a very good
score of 8 with respect to this criterion.
Specific forms would be designed to allow the source to
report pollution control equipment in the same section as
the associated basic equipment information. This would
eliminate the need for a confusing cross-referencing scheme and
would be the most accurate method of relating data items. There-
fore, it was given a score of 9.
7. Complete Identification of All Points
In order to compile a complete emission inventory, the system
used must allow the source to provide data for all pollutant
emission points. The data gathering system should include
instructions addressing the definition of a point source and
should allow plant personnel to report data for all the pro-
cesses which are in operation at his facility. In the weighting
of this criterion, its importance was regarded as being slightly
lower than the emission estimation criteria. The reasoning
for this decision was that correctly coded information for the
reported processes was more desirable than incomplete data for
all processes.
The grading of the specific form alternatives reflected an
inability of these forms to allow for complete reporting of all
emission points. In these alternatives, certain processes which
are typical to the particular industry are investigated and data
for atypical processes are not requested. The general form with
specific sections would allow some ability to report data for
these other processes, but these data could not be expected to
be complete. The entirely specific system was assigned a poor
grade of 2 while the general form with industry-specific sections
was given a slightly below-average grade of 4.
V-8
-------
The generalized system provide a better opportunity for data
reporting for all processes. These systems range in effec-
tiveness from the existing APER, which was graded as average
to the general form with specific instructions which received
a high score of 9. The industry-specific instructions could
be very effective in pointing out the particular processes
which should be included in the data report. Somewhat less
effective would be generalized instructions containing general
definitions of required point sources so this alternative was
given a score of 7.
8, Unconfined Process Data
Certain processes cannot readily be defined as having specific
emission points. These processes are identified as unconfined
processes and include such operations as storage and loading
facilities for volatile organics. Although these processes
cannot be easily defined, they may contribute significant
pollutant emissions and therefore should be included in the
emission inventory. The weighting of this criterion is signi-
ficant in relation to the other criteria, but is not as high
. as the emission estimation criteria. The rationale for this
is similar to that used in assigning a weighting factor for
the "complete identification of all points" criterion com-
plete data for reported processes is more desirable than
incomplete data for all processes.
Since unconfined processes would be determinable for parti-
cular industries, the specific systems were graded high with
respect to this criterion. Also, since these processes are
very difficult to define, less responsibility given the source
corresponds to greater success in receiving complete data. For
this reason, the entirely specific system was given a 9, the
highest grade with respect to this criterion. The system of
forms with specific sections was graded slightly lower at 8
and the .general forms with specific instructions received a
V-9
-------
grade of 7.
Neither the existing APER or the revised generalized system
could provide sufficient guidance to allow the plant to report
complete data relative to unconfined processes. Therefore,
both of these systems were assigned poor scores.
9. EPA Review
Another criterion for evaluating the alternatives is the amount
of review which will have to be performed by EPA personnel
when the completed form is received. This review will mainly
consist of analyzing the data elements reported and converting
them into suitable emission inventory data elements. Included
in the analysis will be such tasks as determining process SCC
codes and converting reported units to standard system units.
This criterion is not regarded as being as critical to the
quality of data compiled as were the previous criteria.
Accordingly, the associated weighting factor is significantly
lower than the other criteria.
The use of the entirely specific form would require the least
amount of EPA review. Since the form would request data in
standard system units, no conversion would be necessary. And
since only typical processes would be reported, SCC codes for
these processes would be previously determined. The EPA per-
sonnel would be required to check the reasonableness of the
data and so would have to be familiar with each of the specific
forms and the associated industry. This alternative received
a grade of 7.
Increasingly general systems would require more EPA review.
This is reflected in the grades of the remaining alternatives.
The generality and the confusing nature of the existing APER
make it the most difficult to review so a grade of 2 was given
to this system.
V - 10
-------
10. Implementation
In order to satisfy the emission inventory needs of EPA,
the alternative system must be able to be implemented in
a reasonable length of time. Additionally, the system
should cause minimal amounts of internal disruption to the
existing EPA data gathering activities. Although these are
necessary characteristics of an alternative system, this is
considered to be one of the least important of the evalua-
tion criteria.
The grade given to each alternative is a function of the
development which must preceed the use of the system. Naturally,
no further development would be required if the existing APER
were still used. Small changes resulting in a revised general
system would require very little development time. The
remaining systems are successively more specific and in turn are
less compatible with the existing system.
11. Ease of Data Entry
This criterion strictly refers to the ease with which data can
be keypunched from the forms. After EPA review, the data on
the forms would be keypunched into emission inventory records
which would be suitable for computer input. The weighting of
this criterion reflects that while this is a desirable charac-
teristic, it is not critical to the quality of the data and is
the least important of the evaluation criteria.
The more general alternatives were graded higher with respect
to this criterion since a simple set of keypunch instructions
could suffice for keypunching from one general form. More
complex instructions would be needed as the forms become more
specific.
V-ll
-------
B. EVALUATION OF ALTERNATIVES
Table 3 illustrates the application of the additive weighting process to
the APER situation. The criteria are listed in the first column with their
associated relative weights in the second column. The columns headed I, II,
III, IV and APER contain the evaluations for each alternative and for the
current procedure. The first number gives the relative value for the alter-
native in terms of the criterion in the same row. The number in parenthesis
is the raw score for each matrix element (criteria weight multiplied by the al-
ternative value for that criterion). The row marked TOTAL shows the sum of
the raw scores.
V-12
-------
Table 3: ADDITIVE WEIGHTING MATRIX
. . .
i\\ f rrmHirrn
Criteria ^___
1. Comprehendibility
2. Process Description
3. Process Weight
4. Units Specification
5. Hours of Operation
6. Basic and Control
7. All Points
8. Unconfined Process
9. EPA Review
10 . Implemen tab ili ty
11. Data Entry
TOTAL
Weight
12
10
9
9
9
8
7
6
3
2
2
I*
4 (48)
4 (40)
2 (18)
5 (45)
8 (72)
3 (24)
7 (49)
3 (18)
4 (12)
9 (18)
7 (14)
358
II*
8 (96)
8 (80)
8 (72)
8 (72)
8 (72)
6 (48)
9 (63)
7 (42)
4 (12)
2 (4)
7 (14)
575
III*
7 (84)
4 (40)
9 (81)
9 (81)
8 (72)
8 (64)
4 (28)
8 (48)
6 (18)
5 (10)
5 (10)
530
IV*
8 (96)
4 (40)
9 (81)
9 (81)
8 (72)
9 (72)
2 (14)
9 (54)
7 (21)
3 (6)
4 (8)
545
APER
1 (12)
1 (10)
2 (18)
1 (9)
1 (9)
1 (8)
5 (35)
2 (12)
2 (6)
10 (20)
1 (2)
141
09
00
tt>
I
!-
J>
cr
t-1
o>
*ALTERNATIVE DESCRIPTIONS
I - Generalized form with generalized instructions
II - Generalized form with specific instructions for classes of industries
III - Generalized form with specific sections tailored to classes of industries
IV - Simple specific form for specific industries
-------
VI. FINAL RECOMMENDATIONS
A. NEW SOURCES
Application of the technique of additive weighting to evaluate the
four alternative systems using eleven criteria previously described
indicates that Alternative II, the use of a generalized questionnaire
with specific instructions and examples appropriate to the operation
being investigated, is the most satisfactory. It should be noted
that Alternatives II, III, and IV are all relatively close.
The one criterion which was not included thus far is costj each
alternative's "score" was determined strictly by technical criteria.
There are two costs associated with each alternative:
1. Development Costs
Development costs for Alternatives II, III, and IV would be
approximately equivalent, since the same in-depth understanding
of specific industry operation would be required. Alternatives
III and IV would involve more work in forms design, but this is
relatively minor when compared with the technical investigation
necessary to understand a variety of different industries. While
the development costs of Alternative I are significantly lower
than the others, the lack of instructions and examples specific
to a particular operation make this alternative unacceptable,
in our opinion.
2. Operational Costs
Continuing costs incurred by using each alternative system
include time spent in deciding which forms and instructions
are to be used for each specific case, reviewing responses,
and keypunching relevant data. Again, Alternative I has the
lowest cost, because of its simplicity. Operational costs
of Alternatives III and IV would be similar since both involve
selection of specific forms, review of specific forms, and
VI-1
-------
keypunching from a variety of different forms. Alternative
II exhibits lower operational costs, since data entry personnel
would be dealing with the same form in all cases, and the
decision concerning instructions to be sent to a specific
source is easier to make than a decision regarding specific
questions to ask particular source personnel.
Viewing technical and cost factors, it is clear that Alternative
II represents the best approach to emission inventory data
gathering directly from sources. While it is not the least
expensive approach, it is the least expensive alternative
consistent with the level of detail necessary to achieve accurate
results. Additionally, the added clarity provided by specific
instructions should allow smaller companies to report data in a
useable form.
B. PERIODIC UPDATES
Recommendations for periodic updating of emission inventory data
are intimately related to the recommended procedure for gathering
data from new sources. The proposed method involves printing a
computer-produced facsimile of the generalized form with data
currently existing in the NEDS data base printed in the appropriate
blanks on the form. Sources would be asked to revise existing data
and add data for any new points. In the review process, EPA
personnel would supply the appropriate NEDS action codes for updating
the NEDS data base. This method could be utilized for any of the
proposed alternatives. Use of Alternative II's generalized form
simplifies programming and review requirements.
VI-2
(Page VI-3 blank)
-------
APPENDIX A
STATE OF WISCONSIN EMISSION INVENTORY SYSTEM
FACILITY UPDATE COMPUTER PROGRAM
-------
r
to
* 1 b C 0 N S 1 N
DEPARTMENT OF i.ATi^KAL KESOUKCEb
300001
bUREA., OF AlK POLLUTION CUNTKCL
SOLlG hAjTE DISPOSAL
EMSSION INVENTORY
FACILITY UPDATE
THE OPtnATlOi.Ai. DATA BtLO-' WAS SubHlT'ta DY Y0u(< COMPANY FOR 1973. I.R101 AND' NR 15t' KEng 1 RE' THIS iNfGRKATlUN TO b£ UPDATED' ANNUALLY
(1) P^ACE1V/1 uPtRAIIOH CnA, 31 ACKES.
THE ENCLOSED ihrCKrUTiON REPRESENTS CALENUAI< YEA« i97(_>. A«ERACJ£ NunbEK OF EMPLOYEES is c .) 1200
OF TOTAL pucuucT I ona: i _ i ZL: .* occim^ rHOi-. JANUARY THRU MARCH OPERATJN& SCHEQUI.E is t__) a HI^KS P£^ DAY
(_-) 30 o LCCUXS FRUM ApKiL THRU JUNE <_} b QAyS p£K siEiK
(__) 30 4 OCCUKS FROM JULY THRU SEPTEMBER (-_.) 2SO DAYS PER YEAK
FK THMU ^^CFnCi^.^
' f> c. .1 PARENT HAHLNT CORPORATION H7
{ ) ANACONi>A CO
IF APPLICABLE. MONITHKINi FEES ,.ILL Bt PAIJ BY ( ) PAKENT ( ) 2i bRCADviAY
(X) COMPANY ( ) hfcn YOKK,
( ) NY ( } 10UOS
3
PERSON CERTIFYING THESE FORMS
:- I 'i h A T H * £ OF P£'
-------
PA6E
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F.VRTICLE COLLECTOK (
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2
-------
30'JOUl
PAGE
PROCESS NO 31 INDUCT MELT bKASS
H5 .MUTE; 7 LINLMELTS iNUuCTlUr. hELT|N<, FURNACES STATIONS 1-7
50 DUST IS IN THE KANGE OF U TO 5 MICRONS
SCHtUuLt IS: ( __ ) 21* HUi,.KS PER UAY, (_) 5 DATS PER wEEKi ( ___ ) 260 DATS PtK Yj.AR
J, OF TUTAL PROUvJCTlON Bf SEASON: (__J 20* i,lNTEK, ( __ ) 30* SKRI^d, (__) 301 SUMMER» ( __ ) 208 FALL
{__. _____ . ) 3V3V6 TONS PEK YEAK {____._) IC'b TUNS PER HUUK MAXIMUM
TYPE OF FUEL; 1 _ I NO FUgL USED HERE _
FUEL uSEAGEI
( .) 0 NONE PER YEAR
ANALYSIS: ( ._) o.o » ASH
...I O.U NONE PER HOUR MAXIMUM
.) 0.004 SULFUR
ON« USE ONLY
PAiVTJCLE COLLECTOR 1
) ijAGHOUSE
(___) 99.9 8 DESIGN EFFICIENCY
EFC CC 0!«K UNIT SIC IPP
0 3M VV.b TONS U 0
55
STAC*. NO, 12 SERVES ( ) BOlLEKS ( ) 1 PROCESSES ( ) INCINERATORS THE ID NUMBERS ARE 32
HEIGHT ( ) 6U FEET DIAMETER ( ) 0,0 FEET OPERATES C ) 2H HOURS PEf
PART SO* NO*
2.0U C.UU U.UO
CO nc HC tXMPT
U.UO U.UO 0
( DAY AND t ) 260 OAYS PER YEAK
EAnAUST bAS VOLUME JS (
i I952uu ACTUAL CUBIC FEET/MINUTE ANU TEMPEKATURE is (
) 70 DEGREES FAHRENHEIT
-------
PA&E
60
NO 32
MELT c'KASS
7C ,-r.jTc.; / AjAX
uP£KArii.(i SC
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FUEL
TYPE OF FUEL: (
0 NONE PEK YtA_R
) NO FUEL USED
Q.O NONE Pt.R riOUK HAXIflUH
d>S>
ANALYSIS:
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-------
300001
PAGE
80
PROCESS NO 33 VA|-0?< DE&REAS1NG
90 NOTE! TRICHOhUtTHYLEUE
OPERATING SCHEDULE. IS; I ._ > 6 HOliRS PER QAYt (.) 1 PATS PER AEEK » ( ) 1BO DAYS PER YEAR
i OF" TOTAL PRODUCTION t> Y SEASON; (__) 2Ui tilNTER« (_«) 30* SKfUNGi l__) 3Ua SUMMERi (__) 2USS FALL
RATES; ( .1 ?euo GALS PER TEAR < ._> u.u GALS PLK HOUK MAXIMUM
FOEL
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( ^. 1 U NONt rtK TtAR (.___) U.U NONt PtR HOUR MAXIMUM
as ANALYSIS: ( ._) u.o * ASM <_. i o.oos SULFUR
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( ) 0.0* PRESENT EFFICIENCY
PART
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3TAC< NO 13
SERVES < )03 BOILERS {
HEIGHT ( J0165 FEET
6AS tfOLLME IS (
PROCESSES ( > INCINERATORS THE 10 NuMBEKS ARE 20 21 ii
DIAMETER t M0.5 FEET . OPERATES ( ) 24 HOURS PER HAY AND ( ) 3SO OAY5 PER YEAR
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BOILER NO 20 SpACE HEATING REQUIRES < ) BH» OF HEAT OUTPUT. RATED CAPACITY IS ( ..) 5U.O MILLION aTU'S PtR HOUR
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---
PA&E .2 OF _2
165
STACH NO IH
( )
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1
23 FEET
PROCESSES ( ) 01 iNCIr4ERATORS THE (0 NUMBERS AKc. SO
UlAHETER ( I 2.0 FEET OPERATES < ) Od HOURS PER DAY ANQ (
) 260 DAYS PER YEArt
tAnAUST uAS VOLUME
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DEGREES FAnrttNriEIT
I 7U
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A f. t-j U * j. A n a -j N T. i: >. K.'; u Ci t 1 9^0 TONS. (
(INDUSTRIAL MULTlChAMBEK
aun,\i.jia .-lATEu CAP«CITY if. ( ) iut>o POUNDS PER
. AnOv/nT'ACTUALLY busi^Eu is ( __> iuuo POUNDS PER
. A T 1 N G S C H £ i;., L ?: t__) 7 HOUR p£< JAYil I 260 PAY pEH
( ) l, 0 U u b T
< ._) 9o.o i DE-si«N EFFICIENCY
( -...) 93.3 £ P^ESEiiT EFFICIENCY
CC
6
ONLY «<
trt FAC
/rjolt: s.A3 FJK£J
vO
-------
300001
PAGE
TOXIC SOURCE 6U . 1 AXTINONY (, COMPOS
"00 '
NErt TOXIC SOURCE
TOXlCaOvKCEOtbCHlPTlON 'ALLOY PREPARATION
TiXlC SOURCE OPERATES « ( ) 260 DAYS PEN YEAR AND t ) 2t HOURS PER DAY
\AilE OF SUSiTft'^CE AS U'SED (
POUNDS OF SuoSTANCt USED (
friih A r! Y COLLECTOR TYHt (
StC'.»iD«r C A u W I VJ fl
) 2* POUNDS PER YEAR
) 8AGH.JUSE
99.9 PERCENT
) CAUHiUH
) 0 POUNDS PER YEAR
LARGE SETTLEABLE PARTICLES OR DROPLETS
SMALL SUSPENDED PARTICLES OR DROPLETS
G A ii E 0 U S FORM
PARTICIPATES OR DROPLETS AND GASES
NOT APPLICABLE (NO i M s s I o N s )
STACK TEST Of CTHEK KEASvJKEnENT
MATERIAL BALANCE
CALCULATED B* EMISSION FACTOR
ESTIMATION MC.THOD
S
«
«
*
*
*
*
,
asses
-------
FAGL 10
T'. tiC St'vitCt __ 61 __- I Af'TIi
- ? C< *
T * » i C bov\C£ U c ii C ft i f1 T I 0 '-. A L L 0
TJXlC bOv*Cc. OPLK-fib » (
Poj.Nui Of SodSTANCt. 'Jit^l (
P n I X A « Y COLLECT OH T Y P L (
S £ C 0 .'' C K * Y CCLLECTun TrPc. (
!<<'£. OF SuoSTAisCE A i EM1TTLO (
P C i, ! L' S OF S i.! 3 S T A N c c- £ C, I T T t u (
CfSrilCAL FCkn OK t.".ISSlCH (
(
£."ilbSio.\ ..AS DtfEr
-------
T
H1
NJ
30UOU1
TCxIC SOURCE __ 62 1
f 40
Tl/xIC SOURCE ^LiCKlPTiON
TOXIC SOURCE OPERATES
'. * !; t u F bUusiTANCL AS u 3 ii D
PCUNDS OF SubSTA:\C£ USED
(-«&
PrtlhArO COLLECTOR TYPE
3E.COUUARY COLLECTOR TYPE
OVERALL COLLECTOR EFFICIENCY
:» A h E OF SUBSTANCE AS EMTTE&
P U U N D 3 OF S U a S T A ,N c E E ." I T T E 0
CHEhlCAL FORM OF EMISSION
PA&£ 1 i
ANT r-.UNy 6 COMPOS NEiit TOXIC SO^CE
ALLt-Y f-KtPAKATIOi*
( J 260 DAYS PER yEAR AND ( ) 2H HOURS PER DAT
( ) LE«C
( ) 190972& POU'iUl, PtK YEAR S>
( J 99.9 PERCENT
*
J )LEiC»LcADGX!UE
( ) 15 POUNDS PER YLAK
* *
( ) 1 LARoE SETTLEABLE PARTICLES OK DKOPLETS
« (XxX> 'i SMALL SUSPEwOEO PARTICLES OR DROPLETS
( > 3 GASEOUS FORM
( IS PARlICULATES OR DROPLETS AND GASES
E* I SSI Of* .'.AS DETERMINED BY:
( ) i NOT APPLICABLE (NO E:--.issiows) *
(XxX> 2 STACK TEST QR OTnER c.EASUKEhENiT
«( )3MAT£hlALbALANCt
i ) «i CALCULATED. ..BY .EMIS.S-I-.UN.--.FA.C.T-U-H. - - - -- -- --- "
( " )'& ESTiHATlOtM KtThOa
-------
PAfcL
.roxic souses. _. &3 i
r 6 ij
T ij A I C bUUKCc. jt^c:U>TIUfj
TOxIC SOUKCe. G r> 1. 1< A T L S
NAME OF SuoilAlitE AS U i» 1 1>
POUNDS OF SUBSTANCE ust_i>
p « I K A r< Y CjLLcCTOh TYPE
SuCU:Art Y CULLcCTCK TYPE
0 V t~ * A L L CJLLtCTLK t. F F I C I £ . C Y
iMAME Ce SubSTANCE AS EMITTtC
PUUf*US OF SUBSTANCE EciITTLu
CMEMCAL KOKh Of EillSblON
EMISSION ,,AS L)ETE«:iINED t>Y:
ANTIMONY i, COdPUS * NEW TOA(C SOURCE
. riLLOY r-rtEPAKATlOw
( ) 260 DAYS PER YtAK A, JO !__» 2H nOUnS PEK OAY
*
* { 1 737H3 POu«i)S PtS YEAh 5
* *
( ) 3ASm..uSE
( ) 99.9 PEhCENT .
( ) i1A,.&ANESE lyiOXIOE
( ) 2 POuNO:, PEK YEAK
( ) 1 LAHC.E SETlLEAaLE PARTICLES OK OKOPLETb
* <*AX) 2 IALL SuSPENUEO PAKTICuES OK DKOPLETS
( )3C>ASt.UoSFOi i NOT APPLICABLE (NO EMISSIONS)
X) 2 STACK TEST OR OTHEK MEASUREMENT
( ) 3 MATE R*IAL BALANCE
{ ) S CALCULATED bY EMISSION FACTOR
( ) S ESTIMATION. MtTHOO «
-------
E
J> 30UOU1
TUXIC SC-JKCE 6t 1
hHU
T 'J t 1 C b 0 U K C E L1 c. j C * 1 P T I u '<
TCxIC bOUrtCE OPERATES
fxAMt Of- bUttSTANCE AS ubLL)
POUNJS OF SUBSTANCE USED
aflb
SECOi'vOAHr COLLECTOR TrFE
OVEKALL COLLECTOR EFFICIENCY
HAKE (jt SUBSTANCE AS EMITTED
P'J..,nOb OK SL)BST<\:iCt EnlTTcO
,190
C h £ M 1 C » L FUriM OF' EMISSION
t.".IbSION ..AS OETEKMINEO BY:
PA&E 13
» ANTIMONY t, COMPD5 NE« TOXIC SOOhCE
ALLUYP.iLPAnATION
( ) 240 DAYS PER YtAR AND ( ) 21 HOURS PER DAY
( ) 3067796 PO-JKUS PER YEAR »
( )eAdHob!>t
( )
( ) 99.9 PERCENT
« ( ) NICKtL
( ) 1 POLMDb PER YEAR
( ) I LAKC.E bETTLEAbLE PAKTICLES OR DROPLETS
2 SMALL bUSPc.'.UEi; PARTICLES On OKOPLLTS
( 3(jAbc.O!jSFC/r<:-i
( t PARTiCULATLS Orf Of
-------
/AGL fi
TOXIC i o i.. ?i C £ __ 6
AN1 i KOUY
NE* TOXIC SOURCE
T V A i C i ii J .-. C t Li t 3 C n i P I 1 0 f.
T C x I C 'i i. « x C c. J f t ;< A T t S
* » ___ J 26U iiAYS
YtAK
( __ ) 21 riOUKS PtR OAY
UAMt OF SbbSTANCE AS uStD (
POUNDS OF SUBSTANCE USED <
vo'i *
pnjriAKY COLLECTOR TYPE i
SECONDARY COLLECTOR TYPE (
;, /ERALL CCLLEcTOr* EFFICIENCY " 1
*AM£ UF SUBSTANCE AS EMITTED (
rOU'^OS OF SubSTfcfict ci-MTTEii » I
9 lU
C.-iEhlCAL FORh OF LC, ISSiOf" (
I* , I
*
E.1ISSION 4,AS OEfErthllMEO BY: (
t
)
1
2
3
. JSSIONS)
STACK TEST OK OThER MEASUREMENT
CALCULATED at EMISSION FACTOR
ESTIMATION nETrlOD
M
Ui
-------
300001
PAUL li
TOXIC SOOKCE __ 66 1 ANTIMONY & COKPCS
920
TOAlC b C 0 r. C E DESCRIPTION ALLOY FrttPAriATlON
TOXIC iOUixCE OPERATES < ) 260 CrtYS PER yEAH AND
fvA.. u ur i'jb b T A>I(_£. AS Ubfc.0 «( )TI
p.'-.il.Co CF SobSTA.NCE USED * I ) 5646|7POo'Jc!
VZB
c i I .-'A < 1 C f; L L c. C 1 -j ri 1 Y P L ( ) b A o rl
b c. .C u u u « n Y C 0 L L e. C T 'w ;! T Y P t" ( )
UvoHALl- COLLECT..'* EFFICIENCY ( ) 99.9 PERCENT
*
r.-.iE'jFbv'USTAi'iCEASEfllTTLl) ( )TI
t Ou'U'i i; F Sviti r.-,:-iCE t:'- IT TED ( ) 0 pOo'iJ
; *'j *
CHfc.-,ICAL rOK?' OF EM.lSblliN » ( ) 1 LARt,E SETTL£A5LE PA
(XxX) 2 SMALL SuSPt;->LO PA^
. ( ) 3 tiASEC'OS FOSK
( ) 4 PAK [ ICULATE.S Ort ORO
EMISblOr; .'..AS utTE^MlNLO K Y ; « 1 ) 1 " 2 T APPLlCnSLE ( :. 0
(XAX) 2 STAC.K TEiT 0* oTr.'E><
( ) 3 MATiKIAL fa A I A ,\ r E
( ) H CALLOLATcu bY LMI3S
( ) b ESTIMATION METHOD
* NEW TOXIC SOvr:CE
*
*
( ) 2H HOORS PER DAY
i PER YEAR
Jl/Sc.
,< OXIDE
S PER YtAK
;TICLES OR DROPLETS
TICLEb' OR DROPLETS
-LETS AND (jASES
1 r. I S J I 0 I-. S J
!CN FACfOK
*
s
I
*
*
*
*
*
,
-------
|6
T i. A 1 C i-JoST
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0
*NCc S'jr.S'.AKT - TOTAL FACILITY
SUBST* .'Ct CATE(,OrtY
ANTlMd.Y i, CORPUS
ARStNlC i, COiiP^S
dARlun (, CORPUS
dERYLLIU:-. 6 COi-PuS
oKUMIi'L
CADMIUM t. COriPOS
CMLOk Inf.
CHROMA TiS & AClb
(. H H 0 n I u M 0 C 0 i-. P Li S
Cu?. ALT F-J;',-; t OUST
COpPi.1 F^i-i£ i, UUST
s. Y A ;- 1 'u ^ S
I ;< o !-. , s - L. s ;. L T s
L r. A L/ , C - ! F i> S
t, A M !i ft N t S t S CORPUS
M :- H C K- Y ( A L K. Y L )
ri L>. C. J h r c, C 0 !>. P J S
n 0 L r c c. J E i J U M fr C 0 11 P 0 S
M 1 C r. t L C A K a U Y L
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f-'-ivS." -:c ACIU 6 AJJHYO
P H 0 b r « 3 =» U S (YtLLOn)
PLAT ii-.iJM, SOL SALTS
StLL-. !.? , COI'.HOS
S i; L r j -, i C i C 1 '
-------
APPENDIX B
EXAMPLES OF SPECIFIC INDUSTRY FORMS FOR
THE STEEL INDUSTRY
-------
ENVIRONMENTAL PROTECTION AGENCY
AIR POLLUTANT EMISSIONS REPORT
Plant Name:
Plant Address:
(street)
Title
Telephone
Mailing address:
(street or box number)
1 of 4
(city) (state) (zip code)
Person to contact regarding this report:
(city) (state) (zip code)
-------
Basic Oxygen Process (each furnace).
1. Average heat capacity
tons/cycle
2.
3.
4.
5.
Maximum heat capacity tons/cycle
Raw material used in furnace Ib/hr.
Final product generated by process Ib/hr.
Following information for one complete furnace cycle.
a. Time taken in charging
b. Time for oxygen blow
c. Time for furnace tap
d. Time for testing and misc.
e. Total time of furnace cycle
minutes
minutes
minutes
minutes
minutes
6. Percent yield of average heat
7. Percent slag of average heat
8. Percent loss due to other factor (i.e. oxidation, refractory losses,
material handling - not including amount collected by control
devices)
9. Effluent gas flow rate
scfm
B-3
-------
3 of A
10. Types of control equipment and collection efficiency (design and actual)
(Specify Process Controlled)
design
actual
(BOF Vessel)
(Reladling Station)
(Track Hopper)
(Flux Bin)
11.
12.
13.
14.
15.
16.
(Slag Skimmer)
Pressure drop across collection device
Inlet loading of control device
Outlet loading of control device
design
actual
design
actual
design
actual
design
actual
(inches of water)
Jb/hr
Ib/hr
Total waste product collected by each control device
Number of furnaces in melt shop
tons/day
Melt shop size (average length, width, and height - in feet)
-------
A of 4
BOF Mass Balance
17. Hot metal Ib/hr + scrap Ib/hr +
additives Ib/hr + others Ib/hr
steel Ib/hr + slag losses Ib/hr
+ oxidation losses Ib/hr +
refractory losses Ib/hr +
material handling losses Ib/hr + losses from
charging and tapping emissions Ib/hr +
ladle emissions Ib/hr
B-5
-------
COKE BATTERY QUESTIONNAIRE
ITEM
1. Annual Average Rate of Coal Input
2. Design Hourly Rate of Coal Input
3. Maximum Hourly Rate of Coal Input
4. Annual Average Coke Production Rate
5. Design Hourly Coke Production Rate
6. Maximum Hourly Coke Production Rate
7. Normal Operating Schedule
8. Number of Ovens
9. Normal Coking Time
10. Annual Average Coking Time
11. Is Staged Charging Used
12. Does Quench Tower Have Baffles
13. Date of Last Battery Rehabilitation
14. Age of Battery
15. Type of Door Sealing Mechanism
16. Stack Height
17. Stack ID At Top
18. Stack Gas Velocity
19. Stack Exit Gas Temperature
20. Stack Exit Gas Flow Rate - Average
21. ." " - Maximum
22. Fuel Used in Underfiring
23. Sulfur Content in Underfiring Fuel
24. Annual Average Underfiring Fuel Use
25. Sulfur Content in Coking Coal
26. Sulfur Content in Coke Oven Gas
UNITS
Tons/Year
Lbs./Hr.
Lbs./Hr.
Tons/Year
Lbs./Hr.
Lbs./Hr.
Hours/Year
Number
Hours/Cycle
Hours/Cycle
Yes/No
Yes/No
Month/Yr.
Years
-
Ft.
Ft.
Ft. /Sec.
Of.
ACFM
ii
-
Weight %
As appropriate
Weight %
Weight %
-------
SCARFING QUESTIONNAIRE
' ITEM
1. Rated capacity
2. Maximum capacity as percent
of rated capacity
3. Effluent gas flow rate
4. Type of control device used
on scarfer
5. Operating efficiency of above
6. Is stack test data available
for the above control device
(if "yes" enclose a copy of
most recent test report)
7. Elevations above grade of
sta'ck outlets and other
discharge points
8. Inside diameter of each stack
9. Temperature of effluent gas
stream from each stack
10. Exit velocity of each stack
effluent
UNITS
Tons/hr
%
SCF/min
%
yes/ no
feet
feet
°F
feet/sec
B-7
-------
' BLAST FURNACES (PER FURNACE) QUESTIONNAIRE
ITEM
1. Maximum Hourly Production Rate
2. Oaily Production Rate
3. Normal Operating Schedule
4. Average Heat Time
5. Average Slag Content
6. Average Ladle Capacity
7. Number of Ladles Transferred to
Melt Shop Daily
8. Average Hot Metal Supply to Melt .
Shop
9. Is Any Hot "etal Lost in Cast
House
10. If Above is "Yes" Estimate This
Amount
11. Is Cast House Enclosed For This
Furnace
12. Type of Control Device at Cast
house not "e ta i iransrer ouiuion
13. Operating Efficiency of Above
14. Is Stack Test Data Available For
Control Device Specified in Item
12 (If "Yes" Enclose A Copy of
Most Recent Test Report)
15. Date of Last Furnace Rebuild
UNITS
Lbs./Hr.
Tons/Day
Hours/Year
Hours/Minutes
%
Tons
#/Day
Tons/Day
Yes/No
Tons/Day
Yes/No
% '
Yes/No
Month/Year
i
-------
SINTER PLANT QUESTIONNAIRE
ITEM
1. Annual Averaae Sinter Production
Rate
2. Normal Operating Schedule
3. Type of Control Device on
»«. | I J J K/\i/ C nA
f
-------
ENVIRONMENTAL PROTECTION AGENCY
AIR POLLUTANT EMISSIONS DATA
Plant Name:
Plant Address:
(street)
Title:
Telephone:
Mailing address:
1 of 4
(city)(state) (zip code)
Person to contact regarding this data:
(street or DOX number)
(city) (state) (zip code)
-------
2 of 4
Electric-Arc Furnace (each furnace).
1. Average heat capacity
_tons/cycle
2. Maximum heat capacity
3. Raw material used in furnace
_tons/cycle
Ib/hr
4. Final product generated by process
Ib/hr
5. Following information for one complete furnace cycle.
a. Time taken in charging
b. Time for melt & refining
c. Time for furnace tap
d. Time for testing and misc.
e. Total time of furnace cycle
6. Percent yield of average heat
7. Percent slag of average heat
minutes
minutes
minutes
minutes
minutes
8. Percent loss due to other factors (i.e. oxidation, refractory losses
material handling-not including amount collected by control devices)
9. Effluent gas flow rate
scfm
B-ll
-------
3 of 4
10. Types of control equipment and collection efficiency (design and actual).
(Specify Process Controlled)
(Electric-Arc Direct Evacuation) design %
actual %
r-rr design ' %
(Hood or Building Evacuation)(Specify Type)
actual %
design %
(Other)
actual
11. Pressure drop across each collection device (inches of water)
12. Inlet loading of control device Ib/hr
13. Outlet loading of control device Jb/hr
14. Total waste product collected by each control device tons/day
15. Number of furnaces in melt shop
16. Melt shop size (average length, width, and height - in feet)
Electric-Arc Mass Balance
17. Scrap Ib/hr + additives Ib/hr +
others Ib/hr steel Ib/hr
slag losses Ib/hr + oxidation losses Ib/hr
refractory losses Ib/hr + material handling
losses Ib/hr + losses from charging and tapping
emissions Ib/hr + Ladle emissions Ibs
18. Type of steer manufactured
19. Maximum transformer capacity KVA
-------
4 of 4
20. Oxygen Useage
21. Power Consumption
CU FT/TON
KW/TON
B-13
-------
APPENDIX C
EXAMPLES OF SUPPLEMENTS
TO TYPICAL SECTION 114 LETTERS
-------
1 of 3
Draft Second "114" letter
Date:
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
Company Name:
Company Address:
Company Contact:
Dear Sir:
The U.S. Environmental Protection AGency is currently updating the
air pollution inventory for the State of Montana. We have been evalua-
ting the possible sources of air pollution associated with your company's
operations and find that we need additional information to complete this
evaluation. If you would supply us with replies to the enclosed questions
this will allow us to complete our analysis.
Please submit your replies as soon as possible.
Information gathered from this survey will not be used contrary
to the confidentiality provisions in Section 114(c) of the Clean Air
Act Amendments of 1970 concerning the divulgence of methods of processes
entitled to protection as trade secrets.
Pursuant to the authority granted in Section 113 and 114 of the Clean Air
Act, as amended, 42 U.S.C. 1857e-9, we hereby require you to provide the
information to the U.S. Environmental Protection Agency at the following
address, within twenty (20) days of the receipt of this letter.
U.S. Environmental Protection Agency
Region VIII
1860 Lincoln Street
Denver, Colorado 80203
If you have any questions concerning this matter please contact Mr.
Jonathan Dion, Project Officer, at (303) 837-4261.
Sincerely,
-------
2 of !3
In reference to the Air Pollutant Emissions Report (OMB form 158-R75)
that you submitted on January 14, 1975:
1. In section V of the form (enclosed) you refer to a "Bailey
Smoke Density Transmissometer and Fuel Control."
a. Is the Bailey meter installed on the Seattle Boiler
Works boiler, the York Shipley boiler or the Lausmann
incinerator?
b. Explain briefly how its efficiency of 85-95% was determined.
c. When you refer to "Fuel Control" does this refer to the
wood shavings or to any auxiliary fuel (i.e. No. 6 fuel oil)?
2. Is the No. 6 Fuel oil used solely in the York Shipley boiler?
If not, state how much is used in a) the York Shipley boiler
b) the Lausmann incinerator
c) the Seattle Boiler Works boiler
3. Apart from the Bailey meter and the Lausmann incinerator, are there
any other air pollution control devices (e.g. cyclones, scrubbers,
etc.) in use at your facility? If there are, state:
a. the type
b. the equipment it operates in conjunction with
c. its control efficiency. Explain briefly how this value was obtained
d. its installation date.
4. Give stack data for the Seattle Boiler Works boiler and for the York
Shipley boiler. For each, state:
a. Stack height above grade
b. Stack exit diameter
c. Stack exit temperature ( F)
C-3
-------
3 of 3
d. Volume of exit gas in actual cubic feet per minute.
If exact information is not available, please make your best estimate.
A simple schematic diagram, showing equipment and points of air pollutant
emissions can be drawn, if necessary, to clarify any of your responses
to these questions.
-------
Name and Address
Attention: Responsible Individual
Facility: Name of Plant
1. In the Air Emissions Inventory, dated October 1974, on pages 12-14,
is given an explanation on the product in boiling ranges. A further
description of the product (Butane, Toluene, etc.) is necessary.
2. What are the units on the vapor pressure listed in the tables
(PSIA, PSIG, etc)?
3. What is the type (floating roof, fixed roof, etc.) of each of the
tanks listed? What is the compliance status, in reference to LACC
Regulation A22.3, for each tank?
4. What is the throughput, in gal/day, of the loading facilities?
Are provisions made to prevent spillage during attachment or
disconnection of filling lines? Is the loading facility equipped
with vapor collection and disposal system or an equivalent means
as stated in LACC Regulations A22.5?
5. In reference to OMB Form 158-R75, dated November 19, 1974, pages 2
& 3, what are the units that should be applied to the quantities
of fuel given as the annual and hourly consumption rates? Does
source code CH75 consume 20,126 CF or 20,126,000 CF of natural gas
per hour? Do all combustion units burn the same amount of fuel?
6. Are the operating hours of each combustion unit (as given 8520 Hr/yr)
the same?
7. Do numerous units have a common stack? (For example, do the 8
units classified as CH74 have a common stack or do the 6 units
classified as DH74 have a common stack, etc.?)
8. Which of these combustion units are boilers and which units are
process heaters?
9. Are there any controls on the vacuum distillation unit? What is the
capacity of the distillation unit?
10. What is the capacity, in barrels, of the refinery?
11. What other refinery facilities (cooling towers, process drains,
catalytic crackers, etc.) are located at Cotton Valley Solvents Co.?
Supply operating and emission data for each.
12. State the name and mailing address of the chief executive officer of
the corporation or of the owners of the enterprise.
C-5
-------
1 of 3
Name and Address
Attention: Responsible Individual
Facility: Name of Plant
A. In reference to the power boiler:
1) Supply the average and maximum amount of fuel burned per hour.
For bark fuel state if the fuel usage is on a dry or wet basis
and supply the percent moisture of the bark.
2) Supply the BTU content of the fuel used. For bark fuel state if
this is on a dry or wet basis.
3) On subpage 6 of 11 of your April 18, 1975 permit request to the
Louisiana Air Control Commission, you submitted emission data for
the stack servicing the power and package boiler. For the hourly
average and maximum emission rates for particulate matter and
nitrogen oxides you listed the emission estimation method as actual
stack test. Supply the stack test data and provide explanations
for any deviations in the method used from those noted in the
December 23, 1971 Federal Register.
4) The stack test data supplied for the April 5, 1973 test on the power
boiler showed considerable more particulate matter being emitted
than the emission data supplied in your permit request. Explain
this discrepancy.
5) For your April 5, 1973 test you stated, "Deviations from procedure
as noted in the December 23, 1971 Federal Register:
1. Sampled 12 locations rather than the 48 specified by
Figure 1-1.
2. Only 10' from each sample port was used.
3. Dried then desiccated samples rather than desiccating
to dryness."
State the reasons for your deviations and give an explanation why
you considered the results valid.
6) What per cent reinjection do you employ in your fly-ash reinjection
system (design and actual)?
-------
2 of 3
7) Do you have any plans to conduct stack tests on the power boiler
in the near future? If so, when are they to be conducted?
8) During an EPA inspection on May 21, 1975, company personnel stated
that soot is blown in the power boiler for 20 minutes every hour.
Ringelmann numbers during this time range from number 1.5 to 2.
Do you still operate at these conditions? What are present typical
Ringelmann numbers during soot blowing? Does the smoke from the
power boiler ever exceed Ringelmann #1? If so, for what duration
does this occur?
9) What type of continuous Ringelmann monitor do you employ in the stack?
How and when do you recalibrate the instrument?
B. In reference to the package boiler:
1) Supply the average and maximum amount of fuel burned per hour.
2) What is the stack gas exit velocity servicing this stack?
C. In reference to the recovery boiler:
1) What is your current average and maximum hourly natural gas and
black liquor consumption rates?
2) The stack test data supplied for .the June 12, 1973 test on the
east and west precipitator outlets gave three deviations from the
stack testing procedures outlined in the December 23, 1971 Federal
Register. State the reasons for these deviations and give an
explanation why you considered the results valid.
3) When will the new electrostatic precipitator servicing the recovery
boiler be put into service? When will stack tests be performed
on the unit to verify compliance? What type of maintenance program
do you plan to employ with the new precipitator?
4) What is the current average and maximum hourly pulp production
rate for the recovery furnace in equivalent tons of unbleached
air-dry kraft pulp? How were these values derived?
5) What is the current average and maximum hourly pollutant emission
rates for the unit? Supply sample calculations and the latest
stack test data available.
D. In reference to the lime kiln:
1) What is the current average and maximum hourly natural gas consumption
rates?
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2) The stack test data supplied for the April 6, 1973 test on the
Peabody Scrubber servicing the lime kiln showed three deviations
from the stack testing procedures outlined in the December 23, 1971
Federal Register. State the reasons for these deviations and give
an explanation why you considered the results valid.
3) What is the current average and maximum hourly pulp production rate
for the lime kiln in equivalent tons of unbleached air-dry kraft
pulp? How were these values derived?
4) What is the current average and maximum hourly pollutant emission
rate for the unit? Supply sample calculations and the latest stack
test data for the emissions you supply. Do you plan,to run stack
tests on this unit in the near future?
E. In reference to the smelt dissolver vent:
1) What is the current average and maximum hourly pulp production
rate for the smelt dissolver tank in equivalent tons of unbleached
air-dry kraft pulp? How were these values derived?
2) Particulate emissions shown on the April 18, 1975 permit request
and the particulate emissions shown in the February 6, 1973 stack
test data are different values. Explain this discrepancy. Supply
the current average and maximum hourly pollutant emission rate for
this unit. Supply sample calculations and the latest stack test
data for the emissions you supply. Do you plan to conduct stack
tests on this unit in the near future? If so, when?
3) For your February 6, 1973 stack test on the smelt dissolver vent
what deviations, if any, did you use from the procedures outlined
in the December 23, 1971 Federal Register? State the reasons for
any deviations and an explanation why you consider the results valid.
F. In reference to the tall oil reactor:
1) Supply a complete description of the tall oil reactor showing
maximum and average hourly material flow into and out of the unit.
2) Provide average and maximum hourly emission rates with sample cal-
culations.
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Name and Address
Attention: Responsible Individual
Facility: Name of Plant
1. Supply a plot plan of the facility showing the location of all units
and emission points.
2. Provide process flow diagrams for the operations you employ.
3. List any revisions to the 11/19/73 OMB form 158-R75 submitted to EPA
which you may have.
4. Provide a short description of the blunger tank, ribbon and orbital
mixer, asphalt blending unit, and the bulk clay loading operation.
5. Provide copies of quarterly (or monthly) fuel useage reports for the
last four quarters. Indicate the sulfur content of any fuel or
mixture of fuels as % sulfur by weight. Explain and provide data for
any sulfur averaging techniques used.
6. List all units or control measures which are planned for service after
8/1/75. Include a brief description of the unit or control measure
and the anticipated date to be brought into service.
7. List all storage tanks over 40,000 gallons capacity storing organic
material. Provide the average and maximum daily throughput, true
storage vapor pressures, and vapor control devices employed.
8. Do any single or multiple compartment organic material water separa-
tors exist which receive effluent water containing 200 gallons of
organic material or more per day having a true vapor pressure of 1.5
psi or greater? If so, explain the system and the type of vapor
control device used.
9. For any organic material loading operations list the material loaded,
true vapor pressure, total daily throughput, date of installation,
and vapor control devices employed.
10. Provide stack test data and estimates of pollution emissions (as
outlined on OMB form 158-R75, page 7) for all emission sources.
11. Submit source test data available on any emission source.
12. List the procedures employed in controlling the emissions from the
asphalt oxidizers. If the emissions are burned in boilers or
heaters provide the gas composition, per cent sulfur by weight,
and the BTU content.
13. Describe any soot blowing procedures you employ.
14. Describe any procedures you employ during upset conditions.
C-9
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1. Supply a plot plan of the facility showing the location of all units
and emission points.
2. Provide process flow diagrams for the operations you employ.
3. List any revisions to the 11/19/73 OMB form 158-R75 submitted to EPA
which you may have.
4. Provide a short description of the blunger tank, ribbon and orbital
mixer, asphalt blending unit, and the bulk clay loading operation.
5. Provide copies of quarterly (or monthly) fuel usage reports for the
last four quarters. Indicate the sulfur content of any fuel or mixture
of fuels as % sulfur by weight. Explain and provide data for any
sulfur averaging techniques used.
6. List all units or control measures which are planned for service after
8/1/75. Include a brief description of the unit or control measure
and the anticipated date to be brought into service.
7. List all storage tanks over 40,000 gallons capacity storing organic.
material. Provide the average and maximum daily throughput, true
storage vapor pressures, and vapor control devices employed.
8. Do any single or multiple compartment organic material water separators
exist which receive effluent water containing 200 gallons of organic
material or more per day having a true vapor pressure of 1.5 psi or
greater? If so, explain the system and the type of vapor control device
used.
9. For any organic material loading operations list the material loaded,
true vapor pressure, total daily throughput, date of installation, and
vapor control devices employed.
10. Provide stack test data and estimates of pollution emissions (as out-
lined on OMB form 158-R75, page 7) for all emission sources.
11. Submit source test data available on any emission source.
12. List the procedures employed in controlling the emissions from the
asphalt oxidizers. If the emissions are burned in boilers or heaters
provide the gas composition, per cent sulfur by weight, and the BTU
content.
13. Describe any soot blowing procedures you employ.
14. Describe any procedures you employ during upset conditions.
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15. Describe any combustion control monitors on heaters and boilers, such
as oxygen analyzers and smoke alarms.
16. Describe any ground level monitoring equipment which exists at this
facility. Provide results of any monitoring for the past year.
17. List all units or control measures which are planned for service after
8/1/75. Include a brief description of the unit or control measure
and the anticipated date to be brought, into service.
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Name and Address:
Attention: Responsible Individual
Facility: Name of Plant
1. According to the Air Pollutant Emissions Report (OMB Form 158-R75),
the facility has two (2) combination natural gas and pitch boilers
(Source Code.IIa). Is the information given (input in 10 BTU/Hr,
annual and average fuel consumption) representative of each boiler
or does it represent the two boilers combined? Do these two
boilers use a common stack?
\
2. For each boiler listed on OMB form 158-R75, what is the maximum \
rated input capacity in 10 BTU/Hr?
3. What was the production rate in 1974 of each of the facility's
various products?
4. Do any of the raw materials or finished products emit any hydro-
carbons? If so, what type? Are they considered to be volatile
organic compounds by the Louisiana Air Control Commission? If
so, is the plant considered to be in compliance with LACC
Regulation 22.0 and A22.0? What steps have been taken and are
planned for the control of volatile organic compounds, if
applicable? Describe any air pollution control devices employed
for the control of hydrocarbons and the equipment they operate
in conjunction with.
5. Supply a flow diagram of the facility's processes. Show raw
materials in-put, air pollution control devices, loading
facilities, etc.
6. Supply best estimates of the emissions from each source within the
plant. This should include Ib/hr maximum and Ib/hr average
emissions. Also supply stack data, i.e. height above grade,
inside diameter and exit gas velocity (ft/sec), temperature ( F)
and flow rate (CFM, average and maximum). If any air pollution
control equipment is used si
and operating), inlet gas t<
and exit gas pressure (PSI)
control equipment is used state the type, efficiencies (design
and operating), inlet gas temperature ( F) and flow rate (CFM),
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7. Have the stack tests been performed on the boilers as stated
In your compliance schedule, dated November 29, 1972? If so,
supply a copy of this data.
8. Have you submitted your hydrocarbon compliance schedule? Does
this schedule contain data on all tanks, including volatility
of contents, size, working vapor pressure and type of tank?
If not, supply this data.
9. State the name and mailing address of the chief executive
officer of the corporation or of the owners of the enterprise.
State also the name and mailing address of the person respon-
sible for the operation of this facility.
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-75-061
2.
3. RECIPIENT'S ACCESSION>NO.
4. TITLE AND SUBTITLE
SYSTEM STUDY AND EVALUATION OF AIR POLLUTION EMISSIONS
REPORT
5. REPORT DATE
August, 1975 Date of Issue
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
George E. Umlauf
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Pacific Environmental Services, Inc.
1930 14th Street
Santa Monica, California 90404
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-1378, T,0. No, 13 .
12. SPONSORING AGENCY NAME AND ADDRESS
Environmental Protection Agency
Research Triangle Park
North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final Report
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT The objective of this study was to conduct an evaluation of the Air Pollu-
tant Emissions Report (APER) as a data gathering system for emission inventory and com-
pliance evaluation tasks. Users of the system in EPA Regional Offices provided infor-
mation concerning the types of projects for which the form is employed and the problems
which have been encountered in its use. Many of the problems related by APER users
were inherent to any generalized data gathering system which must apply to a wide
variety of industrial sources.
The results of this evaluation led to recommendations for modifications and im-
provements to the APER system. Several types of alternative systems were proposed and
appraised by an additive weighting technique. The evaluation criteria used in this
appraisal included 1) comprehendibility by plant personnel; 2) ability to gather
emission inventory data such as process description, process weight, hours of operation
and control equipment description; 3) ability to be coded into NEDS format; and 4)
ability to be implemented in existing EPA data gathering programs. Based on these
criteria, a system consisting of general forms and industry specific instructions was
found to be the most satisfactory alternative to the existing APER system.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS
c. COS AT I Field/Group
APER - Air Pollution Emissions Form
Point Sources
Area Sources
Collection of Source Information
18. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (ThisReport)
Unclassified
21. NO. OF PAGES
94
20. SECURITY CLASS (This page)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
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