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
                                                                                 iii
                                                                      (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
                                                                               1-1

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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
1-2

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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
                                                                                1-3

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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)
1-4

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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
                                                                              1-5

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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)
1-6

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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.
                                                                            1-7

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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
1-8

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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
                                                                                1-9

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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.

1-10

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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
                                                                                1-11

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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.
                                                                           II-l

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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
11*2

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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
II-4

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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).
                                                                              II-5

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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.
                                                                              II-9

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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:
                                                                           III-3

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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.
                                                                               III-5
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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,
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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
                                                                                IV-3

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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
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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
V-4

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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
                                                                    V-5

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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
V-6

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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

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                  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

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    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

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                  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

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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

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         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

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                                            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

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                         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)

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                 APPENDIX A
STATE OF WISCONSIN EMISSION INVENTORY SYSTEM
      FACILITY UPDATE COMPUTER PROGRAM

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                                                            EMSSION INVENTORY

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u. on

•••••*•

C.O TONS 0 0

bOA NOX
0.00 0.00
MC MC EXMPT
u. on o
^
UNR USE ONLY •»«••••••»

 .STACK fiO  15   Sc;
-------
        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
                                                            )  NO FUEL USED HERE
( 	 ^. 1 U NONt rtK TtAR (.„__•_) U.U NONt PtR HOUR MAXIMUM
as ANALYSIS: ( 	 ._) u.o * ASM <_. 	 i o.oos SULFUR
•••••••••
PARTICLE COLLECTOR ( ) NO OUST COLLECTOR ' • EFC CC
( 	 ._) 0.0 2 OtSlGN EFFICIENCY 0 0
( • ) 0.0* PRESENT EFFICIENCY •

• PART
• U.UO
• CO
• O.OO





DNR USE UNLY •
DNR UNIT S
O.U GALS

SOx NOX
O.OC 0.
HC HC
1 L' . U 0





1C JPP
0 U

00
EXMPT
0
—



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
>   U18000 ACTUAL CUBIC FFET/HINUTE  AND TEMPERATURE is (	IOHOO DEGREES  FAHRENHEIT	
SB a * = e
     BOILER NO 20  SpACE HEATING REQUIRES  <	)   BH»  OF  HEAT OUTPUT.  RATED CAPACITY  IS  (	..)    5U.O MILLION aTU'S PtR  HOUR
                                                                                        FUEL  TYPE  INFORMATION	
       FUEL TYPE NO.
       BOlLEri TYPE
                      BiTUMli.OUS
                      PULVERIZED
    COAL
    GENERAL
ANNUAL FUEL CONSUMPTION •
DAYS
MAX
AVG
THIS FOEL oSEU
HOURLY CONSOMPT
HOURLY CO N S U (•• P T
ION •
10k •
FUELHLAT CONTENT •
ASH CONTENT ( h A x - A V G ) • •
SJLFUH CONTENT (MAX-AvG) •
TYPE
COLL
1-b 2 NOTE
OF PARTICLE CULLECTC'K*
LclOfi EFFICIENCIES •
: BOILER NO i -
	 ..) 8
	 ) 300
	 ._ ) 6
) 6
OU
0.0 TONS
UAYS PER
•UOO TONS
. L/ c o TONS
...._) 21. 0
	 ._) 8 .Us
_. 	 ) l.BOi
.....
USED FOR STAi\0»Y ONLY
Oii
I •.'•
MILLION
MAX
MAX
) 'NO OUST
DESIGN
1 V7M
PER YEAR
YEAR
PER HoUR»
HER H i .. u R i
•
MAXIMUM •
AVEHAGE •
BTU'S PER TONS •
(.-..) 7. 7» AVG •
( _. ^_ ) 1 .3QSS AVG •
COLLECTOR
(__«.) 0.

02 PRESENT*
•
•
• •••00
• • DNR
• «COL
• »EST
• • P A t fc.


NOT
ust
CODE
£FF
-1



USE*
ONLY
—
v* * —
OF _

0
J


-------
                                                                                                                      PAbE
             SPACE HEATING  KE.IU1KES  <	1   B *» * Uf HEgT  UuTPUF.  RATtO  CAPACITY  IS  t	._)
50.0 MILLION oTO'S  PEK  HOUR
Fuf.L TYPE  t,0.  1
                     -  --   •  tal rUnI,.;QUS  COAL
                                                                                 NE*  FUEL TYPE  JNFOKMATION
                                                                              •                                 •
oOlLcn TYHE 	 • f
0-Yb TliiSi f'jii. ^iii_C •
"• •» X hl/L'r*LY ClJ-iiurV f I U,N •
A V 5 r, j u K L Y C. 0 .\ i •_ :-. r> T I 0 N •
•FljEL MEAT (.'JM-t,,r •
AJri CONTENT ( .-lA J.-A V a ) •
S 'J L F U K C 0 N T L N T ( C. M X - A V b ) •
TipE OF ?-i«TlCl-t. C^LLtCTOrt*
CULLtClUn LFF 1 C I E f> C I fc S •
1 5 7 f< ;; T t : t U 1 L t S (•:0 2
	 ._) SHoO.O TO«S PER r E A K
	 ) DAYS Pth Yt*R

..... ) 6.UOO To:-iS ptK H..-UK. AVEKAGE
	 ._) 24.0 MILLION 6TU«S Pcr< TO«S
	 ..J 6.U4 MAX (_.._) 7.74 AVG
....) I.SOi MAX (_.._) 1.308 AVG
) NO DciST COLLEcTOK
	 ._) Q.U* OtSJGN (__._) tl.Ofc PKESENT"
i






i
t
»


•••00 NOT USE*
• DIJK USE ONLY
•
•COL CODE.. U
•EST EFF C.Oi
•PAGE _l Or .i

-------
f
00
30CJUOI
IBS
B01LEK NO 21 SPACE HEATING H E 1. U 1 R E S
F U K L TYPE NO. 2 _ __ • « 6 OIL
AiiMUAL FUEL CuWSOf.PT l(i'- • 1 	
DAYS THIS FutL uSEli • 	 1


FUEL HEAT CONTENT • 	 ..
« b H CONTtNT ( n A A - A v i ) • ..._)
SULFUR CONTENT ( ••• A A - A v G ) • _«__>
TVFt OF PAKTICL;. C C'LLt C T U - •
COLLc-ClOK EFFIC IE..C Itb • ( — •_)


16U
bOiLER KG 22 SPACE HEATING KEQUlRES
FUEL TYPE >i 0 • 1 _ - _ • b I T U M 1
L.fIL£K TYPE. _ • PULVEH

DAYS THIS FUEL uSEi) • 	 )
•"Ax nliUi'.LY C w ,TS u •)•. H T I 0 ',. • __ .

FuEL oLAT CONTENT • 	 ._
Abfl CONTENT (:-;Ax- AVG) • _-•_)
5 L1 L F i.1 !i C U l-i T L N T ( K A X - A V G ) • _ « . _ )
TYPE OF PARTICLE COLLECTOR*
CL'LL-Ci'JK EFFICIE.'.CIES • -_.-)
! t> 1 f. 0 T E : 6 0 I L E rt NO 3

( 	 ) 8V« OF HEAT OUTPUT. RATED CAPACITY IS ( 	 ,,_j
N£rt FUEL TYPE
TANGENTIAL •
MAL SUE •
_._! 2bb.UGAL3PERYEAi •
30 DAYS PER YLAfr •
) O.bUM GAL3 PEK H.jURi nAAIKUM •
) U.2bO GAL3 PEH MOUrtt AVERAGE •
) 15M.U MILLION BTU'5 PEK GAL3 •
O.Ui MAX (__._) (J.CitAvG •
1.53* MAX (_.__) I.b3* AVG •
) NO OUST COLLECTOR •
0.04 litSIGN (__._» D.US PRESENT*


( 	 ) SH* OF HEAT OUTPUT. RATED CAPACITY IS < 	 ._)
NE« FUEL TYPE
, NO DUST COLLECTOR •
0.0» DESIGN { _. ) O.OS PRESENT*
•
PAGE 7
bO'O MILLION BTU'S PEK HOUR
INFOKMATION
|
• •••DO NOT USE*
• • UNr* USE ONLY

• »COL CODE 	 U
• *ESTE.FF U.Ui
• »PA&t .2 OF .2


5C.O MlLLIOi. faTU'S PER HOUR
INFORMATION
,
• •••CO NOT USE»
• • DNK USE ONLY
• »COL CODE 	 u
• »ESTEfF O.OS
• *FAGc. .1 OF _2

-------
                                                                                                                                     PA&t
-  16.1
        a OIL Eft  M
                SP«CE HEATING KE^OlRES ( ___ )   61* OF  HEAT OUTPUT.  RATEb CAPACITY IS  ( ____ ..)
                                                                                                                 SQ.O MILLION bTU'S PER  HOUR
                                                                                               NE* FUEL  TYPt  INFORMATION
          Fu'-L  TtPt NO.  2
                                       •  06  OIL T A ii u £ ii T 1 A L
JC. ILErt TTrE __ .*
ANNUAL FUEL CG^bur'PTION •
u A r S THIS FUEL uSLL' •
MAX M-«UKi.Y CUiOoMPT I On •
AV3 hOLKLY Cuf.SjKpT ION •
FJtL nc.AT CC.NTc.nT •
A 5 ,-i C (J M c „ T i .1 * X - A V Ci ) •
SuLruK C 0 U T £ r< T ( H A X - A v Ci ) •
TYPE OF PARTICLE COLLECTOR*
COLLEClO* EFFICIENCIES •
'NUUbTivIAL Site.
( 	 ._) 28b.O GAL3 PtR YEAR
	 ) . 90 UAYS PEM YEAR
.__. 	 ) O.aUH C.AL3 PER Hutf*. MAXIMUM
— ..) ist.o MILLION btu«s PER GALS
-_«_) U.Oe <1AX (__._) O.Ui AVCi
_•-_> I.S3S MAX (»•__) 1.53J6AVG
) NO DuST COLL£cTO«
._._) O.Oi OESICiN ( 	 ._) 0»J2 PRESENT'





»


••«00 NOT USE«
• UNH USE ONLY

•COL CUOE.. 0
•EST EFF 0.0»
• --•-
                                                                                                                                     •PA&E  .2 OF _2
   165
   STACH NO  IH
                         (   )
                 he I GMT  (
                               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
                                         ) UNKNOnii ACTUAL CuBIC  FcET/MlNUTE ANO  TEMPEKATUKE  IS  t
                                                                                                                          DEGREES  FAnrttNriEIT
   I 7U
..ASTE  i.c  tc    ojKi.i.-.c;  TYPEI_> o  -.,AST£ THAT  is (_.)  99
  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
338
u
u
0
0
0
0
0
Lj
0
u
u
u
u
u
u
u
tj
Lt
Q
U
U
U
(j
u
u
u
U
u
•J
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
i'lCKLU t bOL CthPJS
i- i T •< I C A C > 0 «'. A ,N H Y 0
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)

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                                                                      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

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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 %





















































































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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

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'  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












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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
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                     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)

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                                                                       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

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                                                                      3 of 4
10.   Types of control  equipment and collection  efficiency  (design and actual).
     (Specify Process  Controlled)
     (Electric-Arc Direct Evacuation)              design 	%

                                                  actual 	%

      	r-r——r	   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

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                                                                       4 of 4
20.   Oxygen Useage
21.  Power Consumption
CU FT/TON
KW/TON
                                                                                  B-13

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          APPENDIX C
   EXAMPLES OF SUPPLEMENTS
TO TYPICAL SECTION  114 LETTERS

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                                                                       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,

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                                                                      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

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                                                                     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.

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 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

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                                                                       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)?

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                                                                       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?
                                                                               C-7

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                                                                       3 of 3
    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 of 2
 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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                                                                       2 of 2
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.
                                                                               C-ll

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                                                                       1 of 2
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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                                                                   2 of 2
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.
                                                                           C-13

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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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