EPA-450/3-77-052 December 1977 INSPECTION OF AEROS DATA TO DEVELOP SYSTEM ENHANCEMENTS U.S. ENVIRONMENTAL PROTECTION AGENCY Office of Air and Waste Management Office of Air Quality Planning and Standards Research Triangle Park, North Carolina 27711 ------- EPA-450/3-77-052 INSPECTION OF AEROS DATA TO DEVELOP SYSTEM ENHANCEMENTS Engineering-Science 7903 ^eslpark Drive McLean. Virginia 22101 Contract No. 68-02-1894 EPA Project Officer: Arch McQueen Prepared for ENVIRONMENTAL PROTECTION AGKM.Y Office of Air and Waste Management Office of Air Quality Planning and Standards Research Triangle Park, North Carolina 27711 December 1977 ------- 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 in limited quantities from the Library Services Office (MD-35), 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 Engineering-Science, 7903 Westpark Drive, McLean, Virginia 22101, in fulfillment of Contract No. 68-02-1894. The contents of this report are reproduced herein as received from Engineering-Science. 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-450/3-77-052 11 ------- BIBLIOGRAPHIC DATA SHEET 1. Report No. EPA-450/3-77-052 3. Recipient's Accession No. 4. Title and Subtitle Inspection of AEROS Data to Develop System Enhancements 5. Report Date December 1977 6. 7. Author(s) 8. Performing Organization Rept. No. 9. Performing Organization Name and Address Engineering-Science 7903 Westpark Drive McLean, Virginia 22101 10. Project 'Task 'Work Unit No. Task Order 1 11. Contract/Grant No. 68-02-1894 12. Sponsoring Organization Name and Address U.S. Environmental Protection Agency Office of Air and Waste Management Office of Air Quality Planning and Standards Research Triangle Park. North Carolina 27711 13. Type of Report & Period Covered Final 14. 15. Supplementary Notes 16. Abstracts Data from the National Emissions Data System (NEDS) and the Storage and Retrieval of Aerometric Data (SAROAD) system were reviewed to develop enhancements to these sys- tems. Proposed Source Classification Codes (SCCs) were reviewed, and recommendations were made to the National Air Data Branch (NADB) for the adoption of new SCCs. The data records coded with ten non-specific SCCs which end in -99 were reviewed to identify more specific SCCs which could be added to the master list. Verification criteria whict could be used to identify anomalous emissions data were tested. A proposed index to quantify the quality of data in an emission inventory was evaluated. 17. Key Words and Document Analysis. 17a. Descriptors Air Pollution Emission Inventory Source Classification Code National Emissions Data System Storage and Retrieval of Aerometric Data System Air Quality Data 17b. Identifiers/Open-Ended Terms Aerometric and Emissions Reporting System Data Handling Systems 17c. COSATI Fie Id'Group 18. Availability Statement Release Unlimited 19. Security Class (This Report) UNCLASSIFIED 20. Security Class (This Page UNCLASSIFIED 21. No. of P.i^ 115 22. Prtce FORM NTis-35 (Rev. 10-73) ENDORSED BY ANSI AND UNESCO. THIS FORM MAY BE REPRODUCED USCOMM-OC 326S-P74 iii ------- INSTRUCTIONS FOR COMPLETING FORM NT1S-35 (Bibliographic Data Sheet based on COSATI Guidelines to Format Standards for Scientific and Technical Reports Prepared by or for the Federal Government, PB-180 600). 1. Report Number. Each individually bound report shall carry a unique alphanumeric designation selected by the performing organization or provided by the sponsoring organization. Use uppercase letters and Arabic numerals only. Examples FASEB-NS-73-87 and FAA-RD-~3-09. 2. Leave blank. 3. Recipient's Accession Number. Reserved for use by each report recipient. 4. Title and Subtitle. Title should indicate clearly and briefly the subject coverage of the report, subordinate subtitle to the main title. When a report is prepared in more than one volume, repeat the primary title, add volume number and include subtitle for the specific volume. 5. Report Dote. F.ach report shall carry a date indicating at least month and year. 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IO-73) USCOMM-OC 82a5.p iv ------- TABLE OF CONTENTS CHAPTER I INTRODUCTION CHAPTER II EVALUATION OF PROPOSED AND NEW SOURCE CLASSI- FICATION CODES EVALUATION OF PROPOSED CODES SCCs IDENTIFIED AS "OTHER/NOT CLASSIFIED" GENERAL CONCLUSIONS AND RECOMMENDATIONS CHAPTER III ENHANCEMENTS OF AEROS INSPECTION/ASSESSMENT PROCEDURES NEDS AUDITING PROCEDURES SAROAD AUDITING PROCEDURES GENERAL CONCLUSIONS AND RECOMMENDATIONS CHAPTER IV FEASIBILITY OF A QUALITATIVE INDEX FOR NEDS REVIEW OF PROPOSED EMISSION INVENTORY QUALITY INDEX CONCLUSIONS AND RECOMMENDATIONS APPENDIX A CODES PROPOSED BY TACB APPENDIX B CODES PROPOSED BY RADIAN Page 1-1 II-l II-2 11-33 11-42 III-l III-l 111-18 111-21 IV-1 IV-1 IV-3 LIST OF TABLES TABLE II-l SUMMARY OF CODES PROPOSED BY TACB TABLE I1-2 SUMMARY OF CODES PROPOSED BY RADIAN TABLE II-3 SOURCE CLASSIFICATION CODES (SCC) RECOMMENDED FOR ADOPTION TABLE II-4 CROSS REFERENCE TABLE FOR CHEMICALS NORMALLY IDENTIFIED BY TRADE NAMES TABLE II-5 CHEMICAL NAME CROSS REFERENCE TABLE TABLE II-6 PETROCHEMICALS NOT INCLUDED IN THE MASTER LIST II-2 II-3 II-5 11-17 11-19 11-29 ------- TABLE OF CONTENTS (CONT'D.) Page TABLE II-7 TABLE III-l TABLE III-2 TABLE III-3 TABLE III-4 "OTHER/NOT CLASSIFIED" SCCs REVIEWED NEDS POINT SOURCE INVENTORY DATA QUALITY VALIDATION CHECKS VALIDATION CRITERIA FOR STACK PARAMETERS PERCENT OF RECORDS WHICH FAILED INDIVIDUAL VALIDATION CRITERIA SELECTED MINIMUM & MAXIMUM VALUE DISCRIMINATORS FOR EPA DESIGNATED METHODS 11-35 III-3 111-13 111-16 111-19 LIST OF FIGURES FIGURE II-l SCC REVIEW FORM 11-34 VI ------- CHAPTER I INTRODUCTION The Aerometric and Emissions Reporting System (AEROS) handles vast quantities of data on air quality, pollutant emissions, meteorological information, and stack tests. AEROS data are used by the U. S. Environ- mental Protection Agency (EPA), State and local air pollution control agencies, State and Federal Legislators, and private contractors. The uses of the data are manifold and varied. The National Air Data Branch (NADB), which is charged with the super- vision of AEROS, is concerned that the individual systems in AEROS and the data handled by those systems may not be of sufficient quality to meet the needs of the various users. NADB has identified some problems with the quality of data in AEROS that may require improvements to some of the systems that comprise AEROS. To resolve some of these specific data quality problems, data were retrieved from the National Emissions Data System (NEDS) and the Storage and Retrieval of Aerometric Data (SAROAD) system to examine suspected problem areas. Little improvement was found necessary for the SAROAD system because it is operated in a fairly straight forward manner and requires few decisions for users. The NEDS system, however, had required users to make subjective decisions because of complexities stemming from the wide variety of data in the system. Attention was focussed on the following potential system improvements: 1. To define more specific Source Classification Codes (SCCs) and there- by reduce the number of point sources coded in the unclassified category. The usefulness of NEDS is impaired by the large number of sources coded with other/not classified SCCs. Numerous new codes proposed by the Texas Air Control Board (TACB) and the Radian 1-1 ------- Corporation were reviewed. Adoption of these proposed codes would reduce the number of processes now coded with the indiscriminate 99 code ending and enable coders to suppoy more specific process informa- tion to NEDS. In addition, NEDS records for ten existing 99 SCCs were reviewed with the objective to define and reassign the records specific codes. The feasibility of more specific SCCs being developed through a review of existing NEDS records was also explored. 2. To refine data by enhancement of editing procedures - MADE employs some editing routines to prevent grossly incorrect data from entering the systems and t'o identify obviously anomalous data that call for early verification. More sophisticated auditing systems are being developed. Both the existing and proposed editing procedures were reviewed, and improvements to them were recommended. Some of the validation criteria that were recommended as a result of this review were tested to determine the practicability of using such audits. Maximum and minimum values of air quality data were determined to enhance the SAROAD auditing procedures. 3. To label data for relative value. Several indices that have been proposed to aid NADB in quantifying the quality of NEDS data were reviewed to determine their feasibility. Most of these indices involve age, completeness, and correctness. Throughout this effort, established EPA methodologies found in Volumes I through IV of the AEROS User's Manual were used. For much of the work done, however, new, innovative approaches had to be developed. Each of these were reviewed by the EPA Project Officer. Compilation of Air Pollutant Emission Factors (EPA Publication No. AP-42) and Air Pollution Engineering Manual (EPA Publication No. AP-40) were the basic references used for this study in addition to the AEROS User's Manual. This report consists of three chapters; each chapter deals with one of the three main areas of this effort. In Chapter II, the review of the SCCs 1-2 ------- proposed by TACB and Radian is discussed and the codes recommended for ap- proval are listed. This chapter also discusses the feasibility study of developing new, more specific SCCs by reviewing the NEDS records of sources currently coded with other/not classified codes. Recommendations are made; if adopted, they should facilitate the development of new, more specific SCCs in the future. In Chapter III, enhancements to AEROS data auditing systems are discussed. Chapter IV reviews the feasibility of proposed emission inventory quality indices. The Source Classification Codes pro- posed by TACB and Radian are included in the appendices. 1-3 ------- CHAPTER II EVALUATION OF PROPOSED AND NEW SOURCE CLASSIFICATION CODES The Source Classification Codes (SCCs) are the basic "building blocks" upon which the National Emissions Data System (NEDS) is structured. Each SCC represents a process or process activity within a source category.. An SCC consists of four categories of codes. The Category I code is a one- digit code which designates the general type of emission source: external combustion boiler, internal combustion engine, industrial process, point source evaporation, solid waste, and miscellaneous. The next two digits, the Category II code, further subdivides emission sources in accordance with the particular industry or fuel type. For example, the industrial process category (category 3-) is subdivided into chemical manufacturing, food/ agriculture processing, primary metals manufacturing, etc. The Category III three-digit code designates a specific industry within the generalized Category II industry such as paint manufacturing, synthetic fibers, plastics, etc. The last two digits of the eight-digit SCC, the Category IV code, specify the unit operation which emits the pollutants such as a dryer, kiln, reactor, etc. The Environmental Protection Agency (EPA) publishes a master list of SCCs and associated emission factors in Compilation of Air Pollu- tant Emission Factors (EPA Publication No. AP-42). EPA has identified two problems with the SCC master list which would limit the usefulness of the system because they restrict the ability of users to identify emissions from specific processes: o EPA continually revises AP-42 providing emission factors for newly identified emission points/processes and for previously undefined sources. The SCC master list must also be revised to incorporate these new SCC emission factors. 0 At the present time, approximately 20% of all codes in the SCC master list are designated "other/not classified", i.e., they end in 99. In addressing these particular problems and in an effort to upgrade the master list, EPA initiated this contractual effort. The SCCs proposed re- cently by the Texas Air Control Board (TACB) and Radian Corporation were reviewed and the feasibility of developing new SCCs using the information in the NEDS comments field associated with the "other/not classified" codes was analyzed. II-l ------- EVALUATION OF PROPOSED CODES Early in 1976, TACB proposed that 672 new codes be added to the SCC master list. TACB identified the need for these codes when much of the source data, which were reported on plant questionnaires, had to be coded as other/not classified and, thus could not be retrieved for analysis. Codes were then developed for processes listed in Common Petrochemical Compounds (API Bulletin No. 2523) and EPA Selected High Pollution Processes (EPA Publication No. 450/3-73-006-b). Codes were also developed for the production of those chemicals not listed in the above references when the annual emissions from the production of such chemicals were found to be greater than 25 tons of any one criteria pollutant. Table II-l lists the number of codes proposed for each of ten industrial classes. (A complete list of TACB's proposed codes is included in Appendix A.) TABLE II-l SUMMARY OF CODES PROPOSED BY TACB SOURCE CATEGORY NUMBER OF CODES Chemical Manufacturing 127 Primary Metals 12 Petroleum Industry 15 Natural Gas Industry 13 Plastic Fabrication 15 Cleaning Solvents 24 Surface Coating 2 Petroleum Product Storage 17 Petrochemical Marketing/Transportation 260 Petrochemical Product Storage 187 672 As part of a study to upgrade and refine evaporative hydrocarbon emission factors related to the petroleum industry, Radian Corporation pro- posed 202 new SCCs. These were designed to accommodate new and/or revised emission factors that had been developed. These proposed codes covered the V II-2 ------- source categories of petroleum product storage, petrochemical storage, and petroleum product marketing/transportation. Table II-2 indicates the number of codes proposed for each category. Appendix B contains a detailed listing of these codes. In proposing revisions to the SCCs, Radian reviewed TAGS's proposed codes as well as EPA's existing codes and recommended several pos- sible actions. Those codes were reviewed for which Radian recommended one of the following actions: o Adoption of a proposed TAGS code without change; 0 Change of source title and emission factor for an existing EPA code; o Adoption of a proposed TACB code but with a different source title and emission factor; and o Addition of an entirely new SCC. In order to determine if the proposed additions/revisions should be incor- porated into the master list, all of the codes proposed by TACB and Radian were evaluated, except those proposed by TACB for the petroleum industry (SCC category 3-06 found in Appendix A, page 11.) TABLE II-2 SUMMARY OF CODES PROPOSED BY RADIAN SOURCE CATEGORY NUMBER OF CODES Petroleum Product Storage 92 Petrochemical Product Storage 60 Petroleum Product Marketing/Transportation 50 202 Results and Recommendations Based upon the review of the codes proposed by TACB and Radian, the adoption of the codes listed in Table II-3 is recommended. Certain modifi- cations to the codes proposed by TACB and Radian are recommended. These recommended modifications are discussed below in terms of the specific industry for which the codes were proposed rather than in general terms. II-3 ------- Chemical Industry TACB proposed 127 codes for chemical industry operations. It is recommended that 123 new codes be added to the SCC master list and that five existing codes be redesignated. These recommended codes are the same as those proposed by TACB with the following exceptions: 1. The six candidate codes proposed by TACB which were to be designated by trade names should not be adopted. A table (see Table II-4) cross-referencing trade names and chemical names should be provided with the SCC master list and should include the code 99 shown in the table for use in coding the processes. 2. Compounds should be grouped according to their chemical class. New codes are, therefore, recommended for seven chemical classes: alcohols, glycols, ketones, ethers, nitriles, chlo- rides, and amines/amides. This arrangement should help to keep the table short and compact as well as facilitate its usage while providing for future expansion. 3. The designation of two existing codes should be changed. Formaldehyde should be redesignated aldehyde so that SCCs designating the production of a number of aldehydes can be grouped. Category IV codes 01/02 should still refer to the manufacture of formaldehyde. The existing code for ethylene dichloride should be redesignated dichloroethane. The exist- ing codes refer to one isomer of the compound (1, 2 dichloroe- thane). The name change will facilitate including the second isomer (1, 1 dichloroethane). 4. The designations of six codes proposed by TACB were changed to facilitate grouping and/or to prevent confusion. Four of these six codes were proposed for compounds resulting from the chlori- nation of methane. It is recommended that these codes be grouped under the name chloromethane. In most processes these compounds are by-products. Because the unit operations involved in their manufacture are similar, fewer codes will be needed in the future to inventory these processes. The proposed general code (§) ® for Freon was redesignated "fluorocarbons" inasmuch as Freon II-4 ------- TABLE II-3 SOURCE CLASSIFICATION CODES (SCC) RECOMMENDED FOR ADOPTION1 INDUSTRIAL PROCESS - CHEMICAL MANUFACTURING PLASTICS 3-01-018-03 PVC/FAB POLYPROPYLENE/FAB BAKELITE/FAB HIGH DENSITY POLYETHYLENE HIGH DENSITY POLYETHYLENE/FAB LOW DENS POLYETHYLENE LOW DENS POLYETHYLENE/FAB MELAMINE MELAMINE/FAB POLYBUTADIENE POLYBUTADIENE/FAB POLYESTER POLYESTER/FIBERGLASS REINF FAB POLYSTYRENE POLYSTYRENE/FAB POLYSTYRENE/STYROFOAMFAB POLYURETHANE POLYURETHANE/FAB -04 -06 -10 -11 -15 -16 -20 -21 -25 -26 -30 -31 -35 -36 -37 -40 -41 PHTHALIC ANHYDRIDE 3-01-019-05 VIA NAPHTHALENE -10 AMINES/AMIDES 3-01-034-05 -10 -15 -20 -25 -30 -35 KETONES 3-01-091-01 -15 -10 -99 ALDEHYDES 3-01-120-01 -02 -10 -15 -20 -25 -99 VIA 0-XYLENE DIETHYLAMINE TERTBUTYLAMINE ETHANOLAMINE ETHYLENEAMINE HEXAMETHYLENEDIAMINE NPROPYLAMINE UREA ACETONE METHYL ETHYL METHYL ISOBUTYL OTHER/NOT CLASFD FORMALDEHYDE/SILV CAT FORMALDEHYDE/MIX OXID CAT BUTYRALDEHYDE PARAFORMALDEHYDE ACETALDEHYDE/VIA ETHYLENE ACETALDEHYDE/VIA ETHANOL OTHER/NOT CLASFD DICHLOROETHANE 1,2 DICHLOROETHANE/SILVER CAT 1,2 DICHLOROETHANE/DIRECT CHLORNTN 3,2 DICHLOROETHANE/OTHER NOT CLASS 1,1 DICHLOROETHANE/OTHER NOT CLASS 3-01-125-01 -02 -98 -99 Units are tons of product II-5 ------- TABLE II-3 SOURCE CLASSIFICATION CODES (SCC) RECOMMENDED FOR ADOPTION! (CONTD) DICHLOROETHENE 3-01-178-98 -99 ACETIC ACID 3-01-131-01 -05 -10 -99 1,1 DICHLOROETHENE/OTHER NOT CLASS 1,2 DICHLOROETHENE/OTHER NOT CLASS VIA METHANOL VIA BUTANE VIA ACETALDEHYDE OTHER/NOT CLASFD ACETIC ANHYDRIDE 3-01-132-01 VIA ACETIC ACID -05 VIA ACETALDEHYDE -99 OTHER/NOT CLASFD ACETONE CYANOHYDRIN 3-01-133-99 OTHER/NOT CLASFD ACETYLENE 3-01-134-99 ACRYLATES 3-01-135-01 -05 -10 -15 -20 -25 -30 -99 ACRYLIC ACID 3-01-136-99 ANILINE 3-01-137-99 BISPHENOL A 3-01-138-99 OTHER/NOT CLASFD CARBON DISULFIDE 3-01-139-99 OTHER/NOT CLASFD CHLOROHYDRINS 3-01-140-99 CHLOROPRENE 3-01-141-99 CYCLOHEXANOL 3-01-142-99 CYCHLOHEXANONE 3-01-143-99 DICHLOROBUTENE 3-01-144-99 OTHER/NOT CLASFD DIMETHYL TEREPHTHALATE 3-01-145-99 OTHER/NOT CLASFD ETHYL ACETATE 3-01-146-99 OTHER/NOT CLASFD OTHER/NOT CLASFD BUTYL ACRYLATE ETHYL ACRYLATE METHYL ACRYLATE BUTYL METHACRYLATE ISOBUTYL METHACRYLATE ETHYL METHACRYLATE METHYL METHACRYLATE OTHER/NOT CLASFD OTHER/NOT CLSFD OTHER/NOT CLASFD OTHER/NOT CLASFD OTHER/NOT CLASFD OTHER/NOT CLASFD OTHER/NOT CLASFD Units are tons of product II-6 ------- TABLE II-3 SOURCE CLASSIFICATION CODES (SCC) RECOMMENDED FOR ADOPTION1 (CONTD) OTHER/NOT CLASFD OTHER/NOT CLASFD OTHER/NOT CLASFD VIA EPICHLOROCHYDRIN VIA ALLYL CHLORIDE VIA ACROLEIN-HYDROGEN PEROXIDE VIA PROPYLENE-CHLORINE OTHER/NOT CLASFD ETHYL BENZENE 3-01-147-99 ETHYLENE OXIDE 3-01-148-99 FLUOROCARBONS 3-01-149-99 GLYCERINE 3-01-150-01 -05 -10 -15 -99 1,6-HEXANEDIOL 3-01-151-99 OTHER/NOT CLASFD HYDROGEN CYANIDE 3-01-152-01 VIA METHANE/AMMONIA -99 OTHER/NOT CLASFD ISOCYANATES 3-01-153-99 ISOPRENE 3-01-154-99 LACTIC ACID 3-01-155-99 METHYL ACETATE 3-01-156-99 OTHER/NOT CLASFD METHYL CHLOROFORM 3-01-157-99 OTHER/NOT CLASFD METHYLCYCLOHEXAND 3-01-158-99 OTHER/NOT CLASFD METHYCYCLOPENTANE 3-01-159-99 OTHER/NOT CLASFD NITROMETHANE 3-01-160-99 OLEFINS 3-01-161-01 -05 -10 OTHER/NOT CLASFD OTHER/NOT CLASFD OTHER/NOT CLASFD OTHER/NOT CLASFD ETHYLENE PROPYLENE BUTYLENE -99 OTHER/NOT CLASFD PERCHLOROETHYLENE 3-01-162-99 OTHER/NOT CLASFD PENTAERYTHRITOL 3-01-163-99 PHENOL 3-01-164-99 PROPYLENEOXIDE OTHER/NOT CLASFD OTHER/NOT CLASFD 3-01-165-99 STYRENE 3-01-166-99 OTHER/NOT CLASFD OTHER/NOT CLASFD "Units are tons of product II-7 ------- TABLE II-3 SOURCE CLASSIFICATION CODES (SCC) RECOMMENDED FOR ADOPTION1 (CONTD) TETRAETHYL LEAD 3-01-167-99 OTHER/NOT CLASFD TETRAHYDROFURAN 3-01-168-99 OTHER/NOT CLASFD TRICHLOROETHYLENE 3-01-169-99 OTHER/NOT CLASFD TRIMETHYLOLPROPANE 3-01-170-99 OTHER/NOT CLASFD VINYL ACETATE 3-01-171-01 -10 -99 ALCOHOLS 3-01-172-01 -05 -10 -15 -20 -25 -30 -35 -99 GLYCOLS 3-01-173-01 -05 -10 -99 ETHERS 3-01-174-01 -05 -10 -15 -20 -99 CHLORO METHANES 3-01-175-01 -05 -10 -15 -99 NITRILES 3-01-176-01 -10 -15 -20 -25 -99 VIA ACETYLENE VIA ETHYLENE OTHER/NOT CLASFD ALLYL ETHYL ISOBUTYL ISOPROPYL METHYL NBUTYL SECBUTYL TERTBUTYL OTHER/NOT CLASFD ETHYLENE 1,3 BUTYLENE PROPYLENE OTHER NOT CLASFD DIETHYL DIISOPROPYL 1,4 DIOXANE DIPROPYL METHYL PROPYL OTHER NOT CLASFD METHYL CHLORIDE METHYLENE CHLORIDE CARBON TETRACHLORIDE CHLOROFORM OTHER NOT CLASFD ACETONITRILE ACRYLONITRILE ADIPONITRILE/VIA ADIPIC ACID ADIPONITRILE/VIA BUTADIENE METHACRYLONITRILE OTHER NOT CLASFD Units are tons of product II-8 ------- TABLE II-3 SOURCE CLASSIFICATION CODES (SCC) RECOMMENDED FOR ADOPTION1 (CONTD) CHLORIDES 3-01-177-01 ALLYL CHLORIDE -05 ETHYL CHLORIDE -10 NBUTYL CHLORIDE -15 VINYL CHLORIDE -99 OTHER/NOT CLASFD Units are tons of product II-9 ------- TABLE II-3 SOURCE CLASSIFICATION CODES (SCC) RECOMMENDED FOR ADOPTION1 (CONTD) INDUSTRIAL PROCESS - PRIMARY METALS ALUMINUM ORE - ELECTRO REDUC 3-03-001-06 INGOT CASTING/ALLOY2 -07 ALUMINUM FLUORIDE RECOV -08 CRYOLITE RECOV IRON PRODUCTION 3-03-008-09 INGOT CASTING2 MAGNESIUM - ELECTROLYTIC 3-03-035-01 MAGNESIUM OXIDE KILN -03 MAGNESIUM CHLORIDE DRYER -05 MAGNESIUM CASTING/ALLOYING2 -99 OTHER/NOT CLASFD Units are tons of product o Units are tons of metal 11-10 ------- TABLE II-3 SOURCE CLASSIFICATION CODES (SCC) RECOMMENDED FOR ADOPTION (CONTD) INDUSTRIAL PROCESS -NATURAL GAS IND. COMPRESSION 3-01-001-01 SLOWDOWN -02 SEALS DEHYDRATION 3-10-002-01 DRYING/ETHYLNE GLY -02 DRYING/OTHER -10 REFRIGERATION -20 ADSORPTION GAS DESULFURIZATION 3-10-002-01 MEA PROG W/FLARE -02 MEA PROC W/INCIN -99 OTHER/NOT CLASFD NATURAL GAS LIQUIDS 3-10-004-01 REFRIGERATION -02 ABSORPTION -03 FRACTIOXATION -04 ADSORPTION FLARES/INCINERATION 3-10-005-01 WASTE GAS Units are million cubic feet processed 2 Units are 1000 gallons of product 3 Units are million cubic feet 11-11 ------- TABLE II-3 SOURCE CLASSIFICATION CODES (SCC) RECOMMENDED FOR ADOPTION (CONTD) POINT SC EVAP FIXED ROOF 4-03-001-30 -31 -32 -33 -34 -35 -40 -41 -42 -43 -44 -45 -70 -71 -72 -73 FLOATING ROOF 4-03-002-30 -31 -32 -33 -34 -35 -40 -41 -42 -43 -44 -45 -70 -80 t - TANK CAPACITY < * - tank capacity > - PETROL PROD STG BREATH-GASO # BREATH-CRUDE # BREATH-JP-4 # BREATH-JET KERO # BREATH-DIST NO. 2 # BREATH-REAID NO. 6 # BREATH-GASO * BREATH-CRUDE * BREATH-JP-4 * BREATH-JET KERO * BREATH-DIST NO. 2 * BREATH-RESID NO. 6 * WORK-JP-4 WORK-JET KERO WORK-DIST NO. 2 WORK-RESID NO. 6 STAND STG-GASO # STAND STG-CRUDE # STAND STG-JP-4 # STAND STG-JET KERO # STAND STG-DIST NO. 2 // STAND STG-RESID NO. 6 # STAND STG-GASO * STAND STG-CRUDE * STAND STG-JP-4 * STAND STG-JET KERO * STAND STG-DIST. NO. 2 * STAND STG-RESID NO. 6 * WORKING-GASO i WORKING-GASO * 100,000 BBL 1000,000 bbl Units are 1,000 gallons of storage capacity for breathing and standing storage losses and 1,000 gallons of throughput for working losses. 11-12 ------- TABLE II-3 SOURCE CLASSIFICATION CODES (SCC) RECOMMENDED FOR ADOPTION (CONTD) POINT SOURCE EVAPORATION - PETROCHEMICAL STORAGE FIXED ROOF 4-04-002-13 METHYL ACRYLATE METHYL METHACRYLATE TETRAHYDROFURAN VINYL ACETATE NBUTYL CHLORIDE ETHYLENE DICHLORIDE METHACRYLONITRILE METHYL ALCOHOL METHYLCYCLOPENTANE METHYL ETHYL KETONE ISOPROPYL ALCOHOL -14 -18 -19 -25 -26 -27 -28 -29 -30 -31 -32 -99 OTHER/NOT CLASFD 4-04-999-99 1, 1, 1-TRICHLOROETHANE OTHER/NOT CLASFD SPECIFY IN REMARKS Units are 1,000 gallons of storage capacity. 11-13 ------- TABLE II-3 SOURCE CLASSIFICATION COljJES RECOMMENDED FOR ADOPTION (sec) (CONTD) POINT SOURCE EVAPORATION - PETROL MRKT TRANS TANK CARS/TRUCKS 4-06-001-40 LD-SUBMR-NORM GASO LD-SUBMR-NORM CRUDE LD-SUBMR-NORM JP-4 LD-SUBMR-NORM JET KERO LD-SUBMR-NORM DIST NO. 2 LD-SUBMR-NORM RESID NO. ( LD-SPLSH-NORM GASOLINE LD-SPLSH-NORM CRUDE LD-SPLSH-NORM JP-4 LD-SPLSH-NORM JET KERO LD-SPLSH-NORM DIST NO. 2 LD-SPLSH-NORM RESID NO. ( LD-SUBMRG-BAL GASOLINE LD-SUBMRG-BAL CRUDE LD-SUBMRG-BAL JP-4 LD-SUBMRG-BALJET KERO LD-SUBMRG-BAL DIST NO. 2 LD-SUBMRG-BAL RESID NO. ( LD-SPLSH-BAL GASOLINE LD-SPLSH-BAL CRUDE LD-SPLSH-BAL JP-4 LD-SPLSH-BAL JET KERO LD-SPLSH-BAL DIST NO. 2 -41 -42 -43 -44 -45 -60 -61 -62 -63 -64 -65 -70 -71 -72 -73 -74 -75 -80 -81 -82 -83 -84 -85 MARINE VESSELS 4-06-002-06 -07 -08 -09 -10 -11 -12 -13 LD-SPLSH-BAL RESID NO. 6 LOADING JP-4 LOADING JET KERO LOADING DIST. NO. 2 LOADING RESID NO. 6 LD CLEAN SHIP/GASO LD DIRTY SHIP/GASO LD CLEAN BARG/GASO LD DIRTY BARG/GASO Units are 1,000 gallons transferred. 11-14 ------- TABLE II-3 SOURCE CLASSIFICATION CODES (SCC) RECOMMENDED FOR ADOPTION (CONTD) POINT SOURCE EVAPORATION - PETROCHEMICAL MARKETING & TRAN TANK CARS/TRUCKS - LOAD 4-10-001-01 ACETALDEHYDE -02 ACETONITRILE -03 ACRYLONITRILE -04 BUTADIENE (TC) -05 CARBON TETRACHLORIDE -06 CHLOROFORM -07 DICHLOROETHANE (TC) -09 DIETHYLAMINE (TC) -11 ETHYLENE OXIDE (TC) -12 ISOPRENE -13 METHYL ACRYLATE -14 METHYL METHACRYLATE (TC) -16 NPROPYLAMINE (TC) -17 PROPYLENE OXIDE -18 TETRAHYDROFURAN -19 VINYL ACETATE -20 VINYL CHLORIDE (TC) -21 VINYLINDENE CHLORIDE (TC) -99 OTHER/NOT CLASFD Units are 1,000 gallons transferred. 11-15 ------- TABLE II-3 SOURCE CLASSIFICATION CODES (SCC) RECOMMENDED FOR ADOPTION (CONTD) POINT SOURCE EVAPORATION - PETROCHEMICAL MARKETING & TRANSPORT MARINE VESSALS - LOAD 4-10-005-01 ACETALDEHYDE -02 ACETRONITRILE -04 BUTADIENE -07 DICHLOROETHANE -08 DIETHYL ETHER -10 ETHYLENE -11 ETHYLENE OXIDE -13 METHYL ACRYLATE -14 METHYL METHACRYLATE -15 PROPIONALDEHYDE -17 PROPYLENE OXIDE -19 VINYL ACETATE -20 VINYL CHLORIDE -21 VINYLIDENE CHLORIDE -99 OTHER/NOR CLASFD Units are 1,000 gallons transferred. 11-16 ------- TABLE II-4 CROSS REFERENCE TABLE FOR CHEMICALS NORMALLY IDENTIFIED BY TRADE NAMES TRADE n, NAME CHEMICAL NAME SUGGESTED SCCU' Cellosolves Ethylene Glycol Ethers 3-01-174-99 Hydan Hydroxymethionine 3-01-999-99 (Used in the production of Methyionine an amino acid) Hypalon Chlorosulfonated Polyethylene 3-01-026-99 (A vulcanizable elastomer or specialty rubber) Voranol R Polyether Glycols 3-01-173-99 (An intermediate in the manufacture of rigid urethane foam. There are two other classes of Voranols: CP and P) Triton Specialty Cleaning Agents 3-01-009-99 (There are 20 different types of Triton(R)) In the comments field on NEDS Card 6, the specific chemical name or variation of the trade name should be as specified, e.g., hydroxy- methionine, Triton CF-54, Voranol F, etc. 11-17 ------- can refer to various flurocarbon compounds. The proposed code designation for dimethyl terephthalate plus terephthalic acid should be changed to dimethyl terephthalate to avoid con- fusion with the existing code for terephthalic acid. Although some processes produce both chemicals together, most processes produce one or the other alone. 5. Six compounds should be exempted from being grouped according to chemical class: aniline; tetrahydrofuran; pentaerythritol; cyclohexanol; cyclohexanone; and 1,6 hexanediol. These com- pounds should each be given separate codes. 6. A table (see Table II-5) cross-referencing common chemical names with the nomenclature used in the SCC master list should be provided to NEDS users. This table should aid users greatly in locating compounds for which there are more than one common name. 7. Although none of the proposed codes had a process description of "other/not classified, i.e., ending in 99", a substantial number were described as "general". All such codes which can- not be included in a chemical class should be redesignated as "other/not classified" and given a code ending in "99". Such a designation requires the coder to make a comment on NEDS Card 6 before the data can be processed into NEDS. These com- ments may be useful at a later date in defining more specific codes. Plastic Fabrication TACB proposed 15 new codes dealing with the fabrication of plastics. These proposed codes were to be included in a Category II series separate from the chemical manufacturing series. Most of the proposed codes had a "general" designation. It is recommended that these codes be included in the present plastics group under chemical manufacturing. Thus, all codes dealing with resin manufacturing and plastic fabrication could be found in one section. Fewer 99 codes would be created, and users would be less likely to select 99 codes because the other codes could be more easily found. Under chemical 11-18 ------- TABLE I1-5 CHEMICAL NAME CROSS REFERENCE TABLE CHEMICAL NAMES NAME AS APPEARING IN SCC LIST Die thylene diamine Piperazidine Piperazine Ethylene Chloride Ethylene Bichloride Ethylidene Chloride Ethylidene Bichloride Vinylidene Chloride Pimelin Ketone 1, 2 Epoxyethane Hexamethylene Glycol Hydrocyanic Acid Formonitrile Prussic Acid a-Trichloroethane 1, 1, 1 Trichloroethane Hexahydrotoluene Ethene Propene Methyl Ethylene Butene Tetrachloroethylene Tetramethylol Methane Carbolic Acid Benzenol Hydroxybenzene Ethyleneamine 1, 2 Bichloroethane 1, 1 Dichloroethane 1, 1 Bichloroethene Cyclohexanone Ethylene Oxide 1, 6 Hexanediol Hydrogen Cyanide Methyl Chloroform Methyl Cyclohexane Ethylene Propylene Butylene Perchloroethylene Pentaerythritol Phenol 11-19 ------- TABLE II-5 (CONT'D.) CHEMICAL NAME CROSS REFERENCE TABLE CHEMICAL NAMES NAME AS APPEARING IN SCC LIST Ethenyl Benzene Phenylethylene Vinylbenzene Butylene Oxide Diethylene Oxide Tetramethylene Oxide 1,4 Epoxy Butane Ethylene Trichloride 2-Propanol Ethyl Ether Ethyl Oxide Ethylic Ether Isopropyl Ether Chloromethane Dichloromethane Tetrachloromethane Trichloromethane Ethane Nitrile Methyl Cyanide Vinyl Cyanide 3-Chloropropene Chloroethane Hydrochloric Ether Monochloroethane Muriatic Ether Chloroethene Chloroethylene Styrene Tetrahydrofuran Trichloroethylene Isopropyl Alcohol Diethyl Ether Diisopropyl Ether Methyl Chloride Methylene Chloride Carbon Tetrachloride Chloroform Acetontrile Acrylonitrile Allyl Chloride Ethvl Chloride Vinyl Chloride 11-20 ------- manufacturing, TACB proposed codes for the manufacture of five resins (including high and low density polethylene). These codes should be added to the list except for the general code for polypropylene manufacture for which a code already exists. Codes should be created for the fabrication of those resins for which a manufacturing code exists or is proposed. Primary Metals Industry It is recommended that the codes proposed by TACB be adopted with the following exceptions: 1. Codes proposed for manufacturing alumina and iron ore calcining should not be adopted because there are existing codes for these processes. 2. The designation of the codes proposed for aluminum floride and cryolite manufacture should be changed to recover because these processes recover aluminum floride and cryolite rather than manufacture these compounds. 3. The proposed codes for magnesium chloride neutralizers and cells should not be included in the SCC table. The toxic nature of the raw materials and products of these processes requires that good engineering practice be used at all times, so that emis- sions are strictly controlled. In fact, the cells are sealed systems and, thus, have no emissions. Natural Gas Industry It is recommended that 14 new codes be adopted to cover sources in the natural gas industry. These codes are the same as those proposed by TACB with the following exceptions: 1. The designation of a code for fugitive losses from the com- pression process should be redesignated as emissions from seals in order to more accurately identify the source of emissions. 11-21 ------- 2. Four codes should be added for dehydration to reflect the four processes used, i.e., drying/ethylene glycol, drying/other, refrigeration, and absorption. The proposed 99 code is not recommended. 3. The designation gas sweetening proposed by TACB should be changed to desulfurization. 4. Because a code has been proposed for each of the processes used in natural gas liquid by-product recovery, no 99 (other/ not classified) code is recommended for this process. Cleaning Solvents None of the 23 codes proposed by TACB to cover surface wiping should be approved at this time. If the wiping operation is involved in the degreasing process, new codes could be added to that series. However, if surface wiping is an operation in another process, such as paint stripping, codes specifically identifying such an operation should be added at a later date. Petroleum Product Storage TACB proposed new codes for breathing and working losses from fixed roof storage tanks and for standing storage losses from floating roof tanks for five petroleum products: (1) liquified petroleum gas (LPG), (2) naphtha (3) reformate, (4) alkylate, and (5) gas oil. Radian included these TACB codes in its list of proposed codes without change. None of the proposed codes for these five petroleum products should be adopted for the following reasons: 0 Because LPG is normally stored in pressure vessels under an inert gas blanket, emissions are not considered to be signi- ficant. (Only fixed roof working and breathing codes were proposed for LPG storage.) 0 The term "naphtha" also refers to light oil products (solvents) and could cause confusion with petrochemical storage codes that might be adopted later. Normally naphthas have boiling points 11-22 ------- ranging between gasoline and kerosene. Industry should be surveyed to determine normal storage methods for these pro- ducts. ° Reformate is a broad term used to identify products from the thermal or catalytic reforming processes which are used to increase the octane number of gasoline. SCCs already exist for gasoline and other typical products of the reforming pro- cess such as toluene. ° Alkylation is a refinery process for chemically combining iso- paraffins with olefin hydrocarbons. Codes already exist for specific alkylates such as isooctane. ° Gas oils are petroleum distillates such as kerosine, diesel fuel, heating oils, and light fuel oils with boiling points within the 232-426°C range. The inclusion of these proposed codes in the master list could cause double counting or the inclusion of the same emissions in NEDS twice because more de- tailed codes for this class of petroleum products exist or may be adopted in the future. In addition to incorporating the TACB codes discussed above, Radian proposed substantial changes to the existing codes for fixed roof, floating roof, and variable vapor space storage tanks. Radian's proposed changes, a total of 92 codes (48 for fixed roof tanks, 29 for floating roof tanks, and 15 for variable vapor space tanks), were made to replace the existing 61 codes (30 for fixed roof, 17 for floating roof, and 14 for variable vapor space). With the exceptions noted above, most of the new codes (see Table II-3) should be adopted in a format similar to the one proposed by Radian, albeit with certain changes in the Category IV codes to reduce confusion. There are some important precautions that must be taken, however. Code de- signations should not be lightly changed. Sources which emit thousands of tons of hydrocarbons have been coded into NEDS already, using the old codes. Were all of these sources to be recoded, the effort could take years. If a code is poorly delineated, it should be dropped from the listing so that its use can be discontinued. It should be recognized, however, that there has been considerable recent interest in verifying the adequacy of emission factors for losses from fixed and floating roof tanks. A number of on-going 11-23 ------- studies for industry and government evidence this interest. And, althoug i the emission factors Radian proposed were not reviewed, these new data should be reviewed by EPA and incorporated into AP-42 and the SCC master list. To reduce the likelihood that coders will use incorrect codes, a guideline docu- ment to more fully explain how to use the codes is needed. In these guide- lines the following points should be emphasized: 0 For fixed roof tanks, "working losses" include both filling and emptying losses. ° In the comments for the Category IV codes 98/99, the coder should specify both the liquid stored and the tank capacity. These comments should be standardized. ° A distinction should be drawn between the old general codes such as 4-03-001-01, "breathing-gasoline", and new more speci- fic codes such as 4-03-001-30, "breathing-gasoline <100,000 bbls", so that a coder will be able to determine which one to use. ° The terminology used to describe petroleum products should be defined. These explanations should eliminate some of the con- fusion that may arise from adopting codes specifically for such products as JP-4, No. 2 distillate, or No. 6 residual. o Spheres and other pressurized tanks are not included as fixed roofs. ° The differences between floating roof and variable vapor space tanks should be explained and examples given of each major type. ° Wetting losses (working losses from floating roof tanks caused by the exposure of a wetted wall to the atmosphere) are usually negligible. If a source has considerable wetting losses, the 99 code should be used and a comment noting that the source has substantial wetting losses should be made. (1) The American Petroleum Institute is currently sponsoring a source testing study to determine emission factors for losses from storage tanks. 11-24 ------- Petroleum Product Marketing/Transportation There are presently four series of Category III codes for petroleum product marketing/transportation, i.e., tank cars/trucks, marine vessels, underground gasoline storage, and filling vehicle gasoline tanks. TACB pro- posed no new codes for these sources. Radian did not propose new codes for underground gasoline storage or filling vehicle gasoline tanks although they did propose modified emission factors for the latter series. Radian proposed 25 new codes covering the loading of tank cars/trucks to replace the existing 18 SCCs which cover loading and unloading operations. The existing 12 codes for loading and unloading marine vessels were to be re- placed by a new series covering loading and transit operations. Each of these new proposed series represents a significant departure from the existing codes. For the tank car/truck loading series, Radian proposed a format for code designation which differentiates between loading methods, i.e., splash and submerged, and types of "carrier service", i.e., normal and balance. A cargo carrier in normal dedicated service transports only one pro- duct. Inasmuch as the carrier tank is not cleaned or vented between trips, the empty tank retains a significant concentration of vapors generated by the evaporation of product retained on the tank surfaces. These vapors are emitted during a subsequent loading operation along with any new vapors that may be generated. On the other hand, a cargo carrier in dedicated balance service accumulates vapors displaced durir.g unloading operations and transports these vapors back to the truck loading terminal. Thus, a cargo carrier in dedicated balance service normally contains hydrocarbon saturated vapors. It is recommended that the following actions be taken on these proposed tank car/truck codes: 1. The new codes should not replace the existing codes but should be incorporated in a format consistent with the present designations. Too much effort would be needed to recode the existing inventory if the codes were replaced. 2. Some explanation of the new codes will be necessary because often they are much more specific than the old ones. For (1) Balance refers to a loading system which returns the displaced vapors to the loading vessel, thus avoiding any emission to the air. 11-25 ------- example, some of the new codes refer to "JP-4" rather than "jet fuel". Some distinction must be drawn so that a coder may know when and how to use the new codes. 3. The existing 99 code should be retained. Standardized comments should be developed for this code so that a distinction between balance and normal carrier service could be drawn. With the adoption of these codes, the unused numbers available in the master list for codes dealing with unloading operations is rather limited. Thus, the ability to create new unloading codes is being restricted. For the marine vessels series, Radian made a distinction between loading clean ships and barges with gasoline and loading dirty ships and barges with gasoline. For each of the other petroleum products considered, i.e., crude oil, JP-4, jet kerosene, No. 2 distillate oil, and No. 6 residual oil, Radian proposed a code designated "loading general". A separate transit code was proposed for each of the six products. It is recommended that the following actions be taken on these proposed codes: 1. The existing codes should not be deleted because of the extensive effort that would be necessary for receding. 2. The transit codes should not be adopted because emissions during transit are area source emissions, which are not included under SCCs. 3. The remaining codes should be incorporated into the master list except for the one for loading crude oil because there is an existing code for this product. 4. In the guideline document, the term "loading general" should be defined. A clear distinction should be drawn also between the old and the new codes so that a coder can readily determine which one to use. Petrochemical Product Storage TACB proposed two series of codes, i.e., one for breathing losses and another for working losses, for emissions from the storage of 61 petro- 11-26 ------- chemicals in fixed roof tanks. Radian developed emission factors for 15 of these petrochemicals. Codes should be adopted for twelve petrochemicals: n-butyl chloride; ethylene chloride; methacrylonitrile; methyl aerylate; methyl alcohol; methyl cyclopentane; methyl ethyl ketone; methyl methacry- late; isopropyl alcohol; tetrahydrofuran; 1, 1, 1 trichloroethane; and vinyl acetate. No distinction should be made in the code listing betveen breathing and working losses. These petrochemicals are costly products; they are often toxic, corrosive, flammable, reactive or volatile or are an irritant, and are marketed on the basis of concentration and quality or reagent grade. There- fore, one would expect that vapor control devices would be commonly used to minimize emissions. To differentiate between breathing and working losses may not be as important as to distinguish between controlled and uncontrolled sources. Coders should be asked to use the 99 code to identify breathing losses if they exist, and use the specific code for working losses. Other recommendations include: 1. Qualifying criteria should be developed to identify petro- chemicals for which storage codes should be developed. In this effort, criteria were developed to identify petrochemicals which would have a limited emission potential when stored. A better approach would be to establish criteria which would identify petrochemicals with a high emission potential when stored. 2. There is little information on the storage of petrochemicals. EPA should undertake a comprehensive investigation and docu- mentation of industrial petrochemical storage practices. 3. A guideline document is needed to briefly explain the use of each code in the master list. For these petrochemical storage codes, a coder should be asked to identify working pressures, control devices, type of tank, and the chemical stored. To facilitate future code development, standard comments including abbreviations should be developed to systematize the informa- tion given for the 99 code. Such coirjnents could take the fol- lowing format: Type of tank - chemical stored - working pressure - control device. 11-27 ------- 4. All sources presently coded using "Miscellaneous Organic Storage - Other/Not Classified" (4-04-001-99) should be re- coded using these new codes for petrochemical storage. 5. The adoption of these codes should be considered experimental because it is not clear at this time how much, if any, benefit will be derived from their inclusion in the master list. One cannot determine at this time what type of hydrocarbon data EPA needs in the NEDS data base to successfully complete future hydrocarbon studies. All of the compounds for which codes were developed have boiling points higher than 60°C at 760 mm Hg and have been identified as irritants or as causing narcosis. Thus, it is questionable whether the storage of these petro- chemicals is an appreciable air pollution source. The following categories of petrochemicals were eliminated from the list: 1. Organic chemicals with an absolute vapor pressure less than 1.5 psia at 70 F. Emissions from these categories should be grouped together. There is no technology currently available to control emissions from these sources. Such organics were considered to have too low and emission potential. 2. Those compounds with a boiling point below 25 C at 760 mm Hg. Normally, any compounds with such a low boiling point would be stored in pressure vessels or refrigerated tanks. 3. Any petrochemical with a boiling point below 60 C at 760 mm Hg. These chemicals would probably be stored under working pressures that would preclude any emissions. In most cases these compounds have been also identified as health hazards and, thus, cannot be emitted to the atmosphere. 4. All compounds known to be health hazards. The toxic nature of these chemicals would necessitate the prevention of any atmos- pheric emissions. Some of these chemicals are so reactive that they must be stored in tanks which protect them from oxygen and/or atmospheric moisture. Table II-6 lists each compound eliminated using these criteria and which criterion caused the 11-28 ------- TABLE I I- 6 PETROCHEMICALS NOT INCLUDED IN THE MASTER ABSOLUTE VAPOR PRESSURE < 1.5 psia @ 70°F BOILING POINT BELOW 25°C @ 760 mm Hg BOILING POINT BELOW 60°C @ 760 mm Hg TOXICITY Acetic Acid Acetic Anhydride Allyl Alcohol Sec Butyl Alcohol Iso Butyl Alcohol Tert Butyl Alcohol Cumene Cyclohexane 1, 4 Dioxane Ethyl Benzene Ethyl Acetate Methylcylohexane Nitromethane Phenol Styrene Xylene Acetaldehyde Butadiene Ethylene Ethylene Oxide Vinyl Chloride Freon 11 Allyl Chloride (2) Diethyl Ether (2) Isoprene Methylene Chloride (2) Prop ionaldehyde Methyl Propyl Ether n-Propylamine Propylene Oxide Vinylidene Chloride Acetone Chloroprene Diethylamine Methyl Acetate (2) Acetonitrile Acrylonitrile Carbon Tetrachloride Chloroform Diisopropyl Ether Dipropyl Ether Trichloroproylene Trichloroethylene (1) (2) The table shows those chemical compounds suggested by TACB and Radian which were not included in the SCC master list because the vapor pressure, boiling point or toxicity would preclude the storage of these compounds in this fashion. These chemicals are so reactive that they must be stored in tanks which wliminate exposure to atmospheric moisture and/or oxygen. 11-29 ------- elimination. The following changes in nomenclature and deletions were also necessary: o Ethyl alcohol was eliminated because its value as a chemical and strict government regulations pertaining to its pro- duction and marketing would tend to preclude emissions. o Because there was not enough data to characterize the storage of isocyanates, they were deleted from the list. o TACB proposed petrochemical product storage codes for "dichloroethane" and "1, 2-ethylene dichloride". There are two isomers of dichloroethane: 1, 1 dichloroethane and 1, 2 dichloroethane which is commonly known as ethylene dichloride. Ethylene dichloride was included in the list but 1, 1 dichloroethane was excluded because its boiling point is less than 60 C at 760 mm Hg. o Dichloropropane and dichloropropylene were eliminated because each nomenclature designates a group of isomers which have differing characteristics. TACB also proposed floating roof standing storage codes for the 61 petrochemicals for which they proposed fixed roof working and breathing loss codes. Radian developed emission factors for 15 of these compounds and also proposed variable vapor space storage tank codes for the same 15 chemicals. None of these codes should be adopted at this time because there is not suf- ficient evidence to indicate that any of these chemicals are actually stored in floating roof and variable vapor space tanks. Indeed, there are good reasons for suspecting that they are not. Because most of these petrochemi- cals are toxic or are rather costly products, most are probably stored under sufficient working pressures to minimize emissions. EPA should survey indus- try to determine which storage methods are used for these common petrochemicals, what typical working pressures are normally applied, and what type of control devices are in common usage. Petrochemical Marketing/Transportation TACB proposed codes for each of 51 petrochemicals to cover five different marketing/transportation operations: (1) tank cars/trucks-splash 11-30 ------- loading, (2) tank cars/trucks-submerged loading, (3) tank cards/trucks- unloading, (4) marine vessel loading, and (5) marine vessel unloading. Radian did not propose any codes for petrochemical marketing/transportation. The adoption of codes for 18 of these petrochemicals for tank cars/trucks- loading and marine vessel-loading is recommended. The series for tank cars/ trucks-loading should not be divided into separate series for splash loading and submerged loading because the distinction between loading methods may not be significant. Most of these chemicals are sufficiently toxic or valuable that one would reasonably expect industry to employ some form of air pollu- tion control to minimize losses to the atmosphere. Thus, the distinction between controlled and uncontrolled emissions may be more important. The pro- posed codes for tank cars/trucks-unloading and marine vessels-unloading are not recommended, either, because unloading losses are best handled as storage tank working losses. For the series that are recommended, only those petro- chemicals are listed for which the recommended mode of transportation could be identified. In come cases, "TC" is used to identify those products which are normally shipped only in tank cars. However, EPA should survey industry to determine the transportation mode commonly used for each of the originally listed petrochemicals as well as any others that may be of interest. Review Methodology It is incumbent upon the National Air Data Branch (NADB) to review all proposed codes and to determine whether the proposed additions/changes are necessary. NADB has established general guidelines which apply to all pro- posed SCC revisions. SCCs may be added for new emission categories incor- porated into AP-42 if there are no existing specific SCCs and for existing source categories if none of the present specific SCCs are applicable. Other SCCs may be added to account for the use of in-process fuels, if such consideration has not been already made, or to make NEDS compatible with other data systems. SCCs may be expanded if a more sophisticated determin- ation of emission factors for a process is possible. There are four methods for expanding codes and defining new emission factors: 1. As a function of process throughput; 2. As a function of variation in equipment; 3. As a function of operating mode; and, 11-31 ------- 4. For a specific sub-process within a given process. These guidelines were used to review the codes proposed by TACB and Radian. Because NADB's guidelines are general, more specific technical criteria were developed to enhance the guidelines. These six specific criteria were utilized to develop the recommendations discussed earlier: 1. Because the current SCC master list is rather lengthy, new codes should not be adopted unless (1) the process to be inventoried using the new SCC emits a criteria pollutant, (2) the new SCC identifies major sources of emissions (more than 100 tons/year), (3) the process is associated with a major industry and is not obsolete, and (4) a significant number of potential sources can be identified by the candidate SCC. 2. A code proposed for product storage/marketing should identify the product which can actually be stored in the designated manner. For example, some codes were proposed for petrochemical products to be stored in floating-roof tanks which could not possibly be so stored because of their low boiling points. To evaluate the appropriateness of proposed product storage/marketing codes, the phy-jical/chemical properties for each product to be stored were reviewed: boiling point range, true vapor pressure, reactivity, toxicity, hazardous nature of the chemical, etc. 3. Because various systems of nomenclature are used for organic chemicals, the designation of the proposed SCC should be consistent with the nomenclature used in the existing table. 4. A proposed code should be in the same format as the existing codes. 5. A candidate code should not duplicate existing codes. 6. Because each SCC should be associated with an emission factor, the process units (the mass or volume quantity of process throughput or product) associated with a candidate code must correspond to the process parameter required by an emission factor. If no emission factor exists for a candidate code, the process data1 that is required should be reasonably available and should be adequate for estimating emissions when a factor is developed. 11-32 ------- To aid in systematizing the evaluation of each candidate code, a sum- mary similar to that presented in Figure II-l was used. These summaries also serve to document the analysis of candidate codes. SCCs IDENTIFIED AS "OTHER/NOT CLASSIFIED" Because specific SCCs have not been defined for all polluting processes, the master list contains codes for processes labeled as "other/not classified" and end in 99. The high percentage of code 99 usage limits the usefulness of the SCC emissions report. The solution to this problem lies in the adoption of codes proposed by users such as TACB and Radian and in continuously re- viewing the processes found in code 99 to identify those processes for which codes can be developed. Ten of these type 99 codes were reviewed as part of this effort. Code Selection Three criteria were used to select the ten codes which were reviewed: o Source emission ratio. The ratio of the annual average emissions for any one criteria pollutant to the number of sources in each code 99 was developed from summaries of data in the NEDS file. o NEDS Card 6 comments. Codes for which a large quantity of informa- tion was available from the comments field on Card 6 were considered most suitable for analysis. o Category of source. Priority was given to those codes associated with a major industry. Table II-7 lists the ten codes selected for review and the number of NEDS records reviewed. Results and Recommendations Based upon a review of the NEDS records of ten common "other/not classi- fied" SCCs, general observations and recommendations can be made: 1. Many of the records were incorrectly coded. Although the specific reason for miscoding sources varied in accordance with the specific other/not classified code used, there appeared to be a general need for EPA to identify the sources included in some of the codes. It is recommended that EPA publish a guideline document which will more specifically define the sources and operations included in SCCs. 11-33 ------- -sisiacor Agency 2a::a PSCPCSZ2 SCC CATISQSY 3IG"S N'A-MZ DSSZ^.'AIICN SCO Caisgory Z SCC Category II SCC Cacagory III SCC Cacagorv IV NO s HC CO PXCCSS3 2G3S1CS iCLUCi PROCZSS DIAG?AX ^:CLOSc3 Yes Mo MO Figure II-l SCC review form. 11-34 ------- TABLE II-7 "OTHER/NOT CLASSIFIED" SCCs REVIEWED SOURCE CATEGORY Paint Manufacturing Plastics H.SO, Contact Chemical Manufacturing Waste Gas Flares Ferroalloy Open Furnace Petroleum Industrial Flares Inprocess Fuel-Residual Oil (1) Inprocess Fuel-Process Gas Surface Coating Industrial Boiler Bituminous Coal sec 3-01-014-99 3-01-018-99 3-01-023-99 3-01-900-99 3-03-006-99 3-06-009-99 3-90-004-99 3-90-007-99 4-02-999-99 1-02-002-99 NEDS RECORDS REVIEWED 95 326 41 161 47 81 479 197 2,623 112 ^ ' Even though the NEDS does not handle emissions separately for in- process fuel, there are a number of other uses for the fuel informa- tion. Therefore a definite need exists to improve the quality of that kind of data. Determining area source emissions from fuel usage depends on developing a complete fuel balance for a county. In these cases, accurate in-process fuel data are. essential. 2. New codes should be developed in response to a definite need, i.e., there are a significant number of sources emitting a sub- stantial amount of one of the criteria pollutants which the present codes inadequately handle. It is important, therefore to identify the number and the emission potential of sources which have been coded with 99 codes. The wide variety of comments used on NEDS Card 6 for code 99 made it difficult to identify the number of specific unit operations or processes that have been included in code 99 by coders. If EPA were to standardize the comments that a coder can use for code 99, the definition of specific SCCs in the 11-35 ------- future would be facilitated. EPA's edit program could be more effectively used to summarize NEDS data for analysis prior to the development of new SCCs. 3. Because the records spanned a five-year period, it was difficult to determine the magnitude of annual emissions from sources that have been coded using these ten particular 99 codes. A continuing effort to update the NEDS data file will be essential if SCCs are going to be more accurately defined. These problems prevented the development of more specific codes as a result of this review. 4. The adoption of the codes recommended as a result of the review of TACB's and Radian's proposed codes will reduce the number of records coded with 99 SCCs. Such revision of the master list, however, will not eliminate all of the problems associated with code 99. 5. Because of the difficulties encountered, no new codes are proposed as a result of this analysis at this time. For each of the ten 99 codes reviewed, certain specific steps are recommended that EPA can take to further the effort of reducing the number and importance of 99 codes. Most of the following specific recommendations amplify these general recommendations. Paint Manufacturing (3-01-014-99) Nearly half of the records reviewed for this 99 code were miscoded. Most of the mistakes in coding appeared to result from the inclusion of a code for pigment kilns (3-01-014-02) under pain manufacturing. It is recom- mended that this code be suppressed. The existing series of codes for inorganic pigments should be adequate to handle the records previously in- cluded under this SCC. About 6% of the records could not be analyzed because of missing comments or Standard Industrial Classifications (SICs). Most of the remaining records could be grouped into one of the following operations: 1. Material handling/grinders/loading-unloading operations; 2. Mixers/thinners/blenders; 3. Fugitive losses/water-base paint; 11-36 ------- 4. Fugitive losses/non-water-base paints; 5. Lacquer manufacturing; and, 6. Industrial coating manufacturing. EPA should instruct coders to use standard descriptions for these six oper- ations and any others that might be appropriate in making comments on NEDS Card 6. The first two operations listed were the most frequently occurring operations. The last two operations, i.e., lacquer and industrial coating manufacturing, belong properly to the "other/not classified" chemical manu- facturing code (3-01-999-99). If EPA prepares a guideline document as re- commended, brief explanations of those operations for which standardized comments are provided should be included. Plastics (3-01-018-99) A large number of the records (62%) for this code could not be adequately reviewed because there were no comments. Of the remainder, 11% will be included under new codes which were recommended as a result of the analysis of codes proposed by TACB and Radian. No new codes could be developed from an analysis of the remaining records because the comments were too vague. Coders should be asked to specify in their comments a fabrication method, the resin used in plastic fabrication, or the monomer or resin manufactured. To assist the coder, EPA could provide a reference table in the proposed guideline from which abbreviations could be selected for com- binations of solvents, resins, and monomers, e.g., methyl methacrylate (monomer)/ acrylic resin/solvent "X". Sulfuric Acid Manufacturing - Contact Process (3-01-023-99) There are two main problems that coders are encountering in coding sulfuric acid manufacturing sources: 1. All other sulfuric acid manufacturing codes are based on the conversion efficiency. Because the coders have no idea which unit operations are included in each SCC nor the degree of control and type of control equipment used, they are including under the 99 code such emission points as fugitive losses, acid mist, adsorbers, etc. which properly should be assigned specific codes. 11-37 ------- 2. Coders are using this 99 code for acid reclaiming sources and sources related to the production of raw materials such as elemental sulfur, spent acid, hydrogen sulfide, sulfide ores, and smelter gas which are used to produce sulfuric acid. The recommended guideline document should incorporate a condensed version of the discussion of acid manufacturing found in AP-42, as well as a dicussion of acid reclaiming and raw material production. Over 60% of the records re- viewed could not be analyzed properly because of missing or incorrect SICs and/or comments. Chemical Manufacturing Waste Gas Flares (3-01-900-99) Two-thirds of the records reviewed were incorrectly coded. Flares used in oil and natural gas production and extraction and in the metallurgi- cal industry were incorrectly coded using this SCC. Only 10% of the records indicated the substance being flared. It is recommended that standardized comments be established for the following types of waste gas streams: o Streams rich in sulfur, nitrogen, or carbon monoxide; o Streams which contain acids or toxic compounds; ° Streams which contain solvents (the solvent should be specified); and, o Streams which contain chemicals in certain chemical classes such as ketones, aldehydes, etc. The proposed guidelines, by identifying the proper SCCs for those types of flares, could eliminate the problem evidenced by the large number of incorrect]y coded sources. Petroleum Industry Flares (3-06-009-99) It is important that a standardized comment be developed to identify waste gas streams rich in hydrogen sulfide acid gas, and mercaptan. Reference should be made to alternative names for these streams such as sour gas. Over one-quarter of the records reviewed referred to such waste streams. Other flares could be grouped in accordance with the type of fuel burned, i.e. clean fuels (hydrocarbons), chemical wastes, and process wastes. Unless EPA intends to create a series of codes for petrochemical manufacturing as part of the 11-38 ------- petroleum manufacturing series, coders should be encouraged to use the SCC for chemical manufacturing waste gas flares for waste streams from petro- chemical operations. Surface Coating (4-02-999-99) The main problem with the records reviewed for this 99 code was that the process or unit operation was identified in the comments rather than the ^•a type of surface coating such as primer, enamel, etc. This type of comment does not conform to the format established for the surface coating series. Approximately 20% of the records should be receded because: (1) there are existing specific codes, (2) new specific codes have been developed, or (3) new codes are being developed. It is recommended that the proposed guidelines require the coder to specify the solvent used. Unit operations can be identified in the comments fields for existing specific codes. Some discussion of commonly used terms such as sealers, dyes, stains, glazes, and fillers should be presented so that this terminology can be related to the technical classifications used to define specific SCCs. Bituminous Coal Industrial Boiler (1-02-002-99) Nearly one-third of the records reviewed were improperly coded be- cause the coder did not recognize that the existing specific codes can apply also to chain grates, traveling grates, and underfired stokers. One-third could not be analyzed because the comments were omitted. The comments for the remainder were not useful because they were too vague, e.g., "coal boilers". The proposed guidelines should emphasize the equality of various terms for the same basic piece of equipment. States should be encouraged to request more specific information about process equipment on permit application forms so that specific comments can be made on NEDS Card 6. Ferroalloy Open Furnace (3-03-006-99) Apparently, coders are having difficulty in correctly using this 99 code because the other codes in the series are designated for differing alloys, e.g., 50% FeSi, 75% FeSi, etc., rather than unit operations. Thus, a coder may not know that each of the codes in the series pertains solely to emissions from submerged-arc open type electric smelting furnaces. These are 11-39 ------- reduction-type processes, and emissions from other unit operations such as crushing, charging, or raw material handling are not included under any of these SCCs. It is recommended that the existing SCC for screening be ex- panded to include crushing and other handling operations because nearly 35% of the records reviewed referred to such operations. Standardized comments should be developed for other ferroalloys such as chrome-silica, stainless steel, silicomanganese, and for certain miscellaneous operations such as slag disposal and tapping. Approximately 35% of the records could not be reviewed because there were no comments. Inprocess Fuel - Process Gas (3-90-007-99) Approximately 85% of the records reviewed were incorrectly coded because sources burning coke oven gas, blast furnace gas, natural gas, or solid waste had been coded using this code although other SCCs are more applicable. The remainder of the records could not be analyzed because the comments were missing. The guidelines which have been recommended could be useful in correcting some of these problems by clarifying the difference between a process gas and natural or liquified petroleum gas used in a pro- cess. Standardized comments could be developed to better identify the type of process gas burned. Because waste gas streams are often used for inpro- cess fuel, probably the comments should be similar to those developed for chemical manufacturing and petroleum industry flares. The use of this code to identify sources in the petroleum industry which may burn process gas and oil must be corrected. SCCs dealing with inprocess fuel have no associated emission factors. Thus, emissions are estimated using the factor associated with the inprocess fuel code's "parent" SCC. Before this SCC or any other SCC dealing with inprocess fuel is expanded, careful consideration must be given to the "parent" SCC, i.e., a manufacturing SCC (with which an emission factor is associated) that can be used to estimate emissions from inprocess fuel combustion as well as from the process itself. There must be a parent SCC for each inprocess fuel SCC. Inprocess Fuel-Residual Oil (3-90-004-99) Approximately 65% of the records could not be adequately reviewed because of blank or useless comments or missing SICs. A tenth of the re- cords were apparently incorrectly coded because this code was used to identify 11-40 ------- grain dryers, incinerators, glass furnaces, etc. There is a definite need for guidelines to clarify the use of this code and others in this series. The inprocess fuel codes for metal melting, food-drying/cooking/etc., feed/ grain drying, lime kilns, kaolin kilns, perlite furnaces, glass furnaces, frit smelters, and asphalt drying are in particular need of definition. It is not clear whether metal melting includes open hearths, electric arc fur- naces, etc. or just melting for molding and casting operations. No distinc- tion is made for primary and secondary metal operations. An explanation should be provided for such operations as slab furnace, hot strip mill fur- nace, heat treating furnace, and annealing oven which are normally included in the basic casting and molding operations. The codes for food-drying/ cooking and feed/grain drying should be defined in the guidelines so that a coder will know if such operations as wet corn milling/pulp drying and bagasse drying are included. Based upon the records reviewed, there appears to be some confusion among coders as to the relationships between limestone drying and lime kilns, between clay and kaolin, perlite and glass, frit and ceramics, etc. The proposed guidelines should also explain what processes are covered by the code for asphalt drying. Standardized comments should be identified in the guideline recommended document which can lead eventu- ally to defining new SCCs. Coders should be required to identify process units. There are a number of processes which could be identified in these comments: ore roasting/drying; anode baking; ovens used for ornamental metal work; processes in the textile industry; dryers, kettles, heaters, stills, etc. used in the plastics and petrochemical industries; and drying operations for mineral products such as salt/asbestos that are not currently specified in this code series. Comments such as "residual oil" or "^6 oil" should not be used. Methodology The following steps were taken to review the records from each 99 code selected: 1. EPA extracted all the records for the SCC from the NEDS data bank. Each of these records were reviewed manually. 2. The comments for each SCC were summarized. Similar comments were grouped in the summary so that the number of sources which had the same or similar characteristics could be identified. 11-41 ------- 3. The SCCs were cross-checked with the SICs to determine if any process was incorrectly coded, considering the nature of business of a specific four-digit SIC. This review, in some cases, identi- fied probable miscoding in that some of the sources coded with a specific 99 code belonged to SICs in which such sources would not be expected. 4. An effort was made to determine the total emissions which could be grouped according to specific comments and the emissions from repre- sentative sources within this group. Any new SCC developed should categorize a significant number of major sources, i.e., sources with potential emissions greater than 25 tons/year, with a substantial emission potential. This effort was unsuccessful because there was no common baseline year for much of the data. 5. After reviewing a number of records, a number of problems with the methodology were discovered. To solve these problems, a number of recommendations were identified which held promise of enabling EPA in the future to better identify new SCCs from records coded with code 99. One major recommendation was to provide standard- ized comments and abbreviations which could be selectively retrieved by computer. Once this recommendation was identified, the comments were again reviewed in order that standardized comments could be suggested. This methodology which could be utilized for reviewing records to identify new more specific SCCs and thus minimize the number of sources with code 99, was developed from the rather general methodology for developing new SCCs found in the NEDS User's Manual. GENERAL CONCLUSIONS AND RECOMMENDATIONS A number of general conclusions can be drawn from this effort to evalu- ate codes proposed by TACB and Radian and to develop new codes from 10 speci- fic codes 99: 1. There is considerable room in the SCC master list for the addition of new codes. The list of new codes recommended as a result of this evaluation is by no means exhaustive but it is based on the best 11-42 ------- information available at this tiae. Indeed, many of the codes not recommended may prove in the future to have merit. 2. If the master list is to be updated, EPA needs to develop a better procedure than is currently available. State and local agencies as well as Government contractors must be involved in the process because they are the primary developers of data that are entered into NEDS. EPA, however, has a major responsibility in the process in that EPA must evaluate all proposed codes and make the final decision as to adoption or rejection of proposed codes. This process and each participant's role in it must be adequately defined and systematized. 3. The number of codes 99 and the emission potential of sources with such codes limit the effectiveness of NEDS. This problem cannot be fully resolved using EPA's anticipatory approach, i.e., anticipating major source categories and developing emission factors and SCCs for these source categories. The population of major air pollution sources is too large and complex to rely solely on such an approach. 4. A significant problem identified during the review of codes 99 was the large number of sources which were coded with apparently incor- rect SCCs. EPA should seriously consider 'further steps that can be taken to eliminate this problem. 5. The present state of the NEDS file is such that it is difficult to identify new SCCs by reviewing the records of sources with codes 99. Some recommendations have been made in the review of codes 99 and expanded upon in the discussion of the 10 specific codes which could make this file more useful. It must be stressed that this effort may prove to be more useful because of the general recommendations made to enhance EPA's method of identifying and evaluating new SCCs rather than for the specific new SCCs recommended for adoption. 11-43 ------- A major recommendation, however, is that the new SCCs recommended in Table II-3 be adopted expeditiously. Their adoption could prove to have immediate benefit both for EPA and NEDS users. In the long term, EPA should continually review SCCs for such industries as chemical manufacturing because of the technological changes that characterize these industries. Care must be taken to avoid encumbering the SCC master list with revisions that confuse the NEDS users rather than enhance the system. EPA can define more specific guidelines for the expansion of the list. Many of the specific recommendations made earlier and the methodology developed for the evaluation of codes proposed by TACB and Radian can be used to develop these guidelines. The requirement that any agency proposing new codes assess the applicability of the new code, i.e., the number of sources and the emission potential of those sources covered by the proposed code within a given state, would aid in the evaluation of such proposed codes. Based on the fact that the master list is becoming so long and complex, consideration should be given to instituting training programs for NEDS coders. As a minimum, the guidelines suggested earlier to define codes and their usage should be developed. These guidelines could be incorporated into the existing discussion of processes given in AP-42. In any case, these guidelines must be kept brief, clear and simple to avoid confusion. They should answer questions that can cause miscoding. While these recommendations will not, in and of themselves, solve all the problems involved in using the SCC master list, they should considerably enhance the usefulness of the NEDS. ------- CHAPTER III ENHANCEMENTS OF AEROS INSPECTION/ ASSESSMENT PROCEDURES Data submitted to the National Air Data Branch (NADB) should be reviewed by a data auditing system to ensure the integrity of data entered into the National Emissions Data System (NEDS) and the Storage and Retrieval of Aerometric Data (SAROAD) System. If the submitted data cannot pass a computerized editing routine included in such an auditing system, they should be rejected and returned to the originator for correction and re-submittal. Data accepted into NEDS or the SAROAD System should be also subjected to validation checks to identify data anomalies. These anomalies should be noted, and the originator should be asked to verify the data. As part of this effort to enhance the Aerometric and Emissions Reporting System (AEROS), the editing and validation criteria that were proposed for inclusion in a computerized auditing system were reviewed and tested by actually validating NEDS data from two states: North and South Carolina. As a result of this review, enhancements to the proposed auditing system were identified and recommended. In addition, validation criteria were developed to audit SAROAD data to ensure that the data lie within an acceptable range of maximum and minimum values. NEDS AUDITING PROCEDURES Two auditing routines for NEDS were reviewed: o NE061 - A computerized editing routine used by NADB and recently modified to reduce the number of error messages. As an editing routine, its primary purpose is to identify format errors of the data submitted into NEDS. The program was not designed to evaluate the quality or validity of data. However, a few validation checks are included. The violation of these validation criteria triggers the issuance of warning messages but does not prevent the incorpor- ation of the data from getting into the NEDS master file. III-l ------- o A computerized validation routine under development by NADB. This proposed validation module is a comprehensive data auditing program. The version reviewed in this effort was preliminary, and, thus, some of the recommended enhancements may not be applicable. These two data auditing systems were reviewed to determine their usefulness and to determine if enhancements to both or either system were desirable. It is recommended that these two systems be combined. This combination of the two systems could produce some economies of scale in that both programs in various instances edit similar data fields. If they are combined, two audit messages must be used: error and warning. Format errors in certain key fields should cause the rejection of submitted data. The review of other fields should be used to identify data anomalies which would not cause a re- jection of the data but, rather, the issuance of a "warning" which would require the originator to verify the accuracy of the data in these fields. Such an auditing system could be used to fulfill two purposes: 1. To edit input transactions so that erroneous data would not be entered into NEDS. 2. To validate data already in NEDS so that existing data could be improved. No determination of the economic feasibility of developing the software requited or of implementing and maintaining the system once developed was made. Recommended Enhancements Enhancements to the auditing module are recommended. These enhancements, as well as brief discussions of the validation criteria included in the module, are listed in Table III-l. No enhancements are recommended for NE061 because the two systems should be integrated. No enhancements are recommended for the format edits retained from NE061 because these criteria are probably adequate. The validation criteria included in that program would in many cases be super- seded by those in the module. It was felt that enhancements to the validation criteria in the module would be more valuable. In addition to the enhancements recommended in Table III-l, the following observations were made about proposed validation checks for individual point source data fields: III-2 ------- TABLE TII-1 NEDS POINT SOURCE INVENTORY DATA QUALITY VALIDATION CHECKS FIELD NAME EPA VALIDATION CHECK FOR POINT RECORDS ES RECOMMENDATIONS 5 6 13 14 City UTM Zone (Universal Transverse Mercator) SIC IPP Process 15 & 16 UTM Coordinates Must be a valid entry in the AEROS City County File For each state a valid begin- ning zone and a valid ending zone. Example: State Oil 15 through 16 are valid. See Table 1. Must he a valid entry in the SIC Names file. A table will be used to match SIC and ll'P codes with SCC code. One entry in table for each SCC. Presently about 1,000 SCC codes. Table 2 tives general pattern tor table of SCC's vs SIC-1PP codes. If found invalid the error could be In the SCC code, For each state: Horizontal: max & min values Vertical: max fc. min values The SCC/SIC-IPP table should also be used to identify missing key SCC codes for facilities in the inventory. ------- TABLE III-l (CONT'D.) NEDS POINT SOURCE INVENTORY DATA QUALITY VALIDATION CHECKS FIELD NAME EPA VALIDATION CHECK FOR POINT RECORDS ES RECOMMENDATIONS 17 Stack Height M 18 19 20 21 Stack Diameter Stack Temp Flow Rate Plume Height 22 & 23 Points with Common Stack Must be < 500 ft. Must be < .2 of stack height 77°F to 2,000°F Must be within range of formulas listed in Table 3 based on SCC Must be < 200 ft. The number in 58-59 (23) must be > the number in 59-60 (22) unless both the fields are 00 or blank. If one field is 00 or blank then the other field must be 00 or blank. When any transaction is made to a record which has number non-zero num- bers in these 2 fields the follow- ing message must be printed: "CHECK POINT ID TO for cor- rect points with COMMON STACK" All stack parameters should be audited based on typical discri- minators for major SCC groups. The table which relates stack gas flow rates to SCC categories should be expanded to include height, diameter, and temperature. Must be 10 £ P _< 200 ft., where P = plume height. Validation discriminator for ex- haust flow rate should be overriden and the audit based on the result- ing velocity or flow rate for all points with common stack vs. a specified range or exit velocities or flow rates. (1) The term 'discriminator1 refers to specific validation criteria (usually a numerical range) for individual data elements. If the data element falls outside the range of the discriminator, it must be checked. ------- •TABLE TII-1 (CONT'D.) NEDS POINT SOURCE INVENTORY DATA QUALITY VALIDATION CHECKS FIELD NAME EPA VALIDATION CHECK FOR POINT RECORDS ES RECOMMENDATIONS 25 26-35 Boiler Design Capacity Control Equipment Code M 01 36-40 CoiiLrol Efficiencies The maximum design rate x heat content must not be > the boiler design capacity + 20%. Must be valid code from Section II of AEROS Vol. V (42 codes at present). Also must be valid for the specific pollutant. Table 4 contains this information. Table 4 will need to be updated per Lodi cal l.y. Must be in the range of values for each device-pollutant combination in Table 4. In cases where both primary and secondary control de- vices are coded, this check should apply only to the code for the se- condary device. If there is no secondary device (secondary code= 000) the check applies to the pri- mary device. If a number is coded for either primary or secondary device, both fields must have de- vice codes, L.e., primary & se- condary device fields must both have codes or both be blank. If the control device code fields are biank, the control efficiency field must also be blank. If the control device code-000, then efficiency ------- TABLE III 1 (CONT'D.) NEDS POINT SOURCE INVENTORY DATA QUALITY VALIDATION CHECKS FIELD NAME EPA VALIDATION CHECK FOR POINT RECORDS ES RECOMMENDATIONS H 36-40 Control Efficiencies (Cont'd.) 42-45 % Thruput 46 Hours/Day 47 Days/Week 48 Weeks/Year 49-53 Emission Estimates must be zero or blank. NA indicates control equipment code is not applicable for that pollutant, control de- vice combination. All 4 seasons must sum to 100 unless there is only one nonblank season with an entry of 99. Must be _< 24 if not print message and make it blank. Must be j< 7 if not print message and make it blank. Must be <_ 52 if nor print message and make it blank. Must be £ 25,000 for each pollutant. Check a value for each pollutant because the 25,000 might be changed to a different number for each pollutant. The discriminator proposed is too broad and will not identify the majority of errors found in this field. The following dis- criminator is proposed: for pollutants with emissions > 100 tons/yr. for which the method of estimation ^ 3 and ^ 1, emissions should be within + 20% of those calculated using the emission factor table. (1) The term 'discrimination1 refers to specific validation criteria (usually a numerical range) for individual data elements. If the data element falls outside the range of the discriminator, it must be checked. ------- TABLE III-l (CONT'D.) NEDS POINT SOURCE INVENTORY DATA QUALITY VALIDATION CHECKS FIELD NAME EPA VALIDATION CHECK FOR POINT RECORDS ES RECOMMENDATIONS 49-53 Emission Estimates (Cont'd.) M t-t I 59 % Space Heat 61-65 Allowable Emissions Must: be numeric (can have lead- ing blanks, not all blanks) con- tains an SCC which begins with a 1 or 2 for all other SCC's no check is necessary. Must be all 9's or not > than 25,000 for each pollutant. Check a value for each pollu- tant as for Emission Estimates. The following check can be also made for each Category II SCC series; specific pollutants can- not be blank nor zero. For example, emissions of particulate and SO from boilers (1-01-XXX-XX) and in-process fuel (3-90-XXX-XX) must not be coded or left blank or = 0. Also, once a method = 1 is identi- fied, an emission factor should be computed from the data reported (process & emission) and saved on a separate file so that new/re- vised emission factors can be com- puted and reissued through AP-42. For each of the .criteria pollutants a discriminator should be estab- lished which best represents cur- rent regulation trends. For example, a value of 0.03 grains/scf for part- iculates, which corresponds to a clean plume, could be adopted. (1) The term "discriminator1 refers to specific validation criteria (usually a numerical range) for individual data elements. If the data element falls outside the range of the discriminator, it must be checked. ------- TABLE III-l (CONT'D.) NEDS POINT SOURCE INVENTORY DATA QUALITY VALIDATION CHECKS FIELD oo NAME EPA VALIDATION CHECK FOR POINT RECORDS 66 Compliance Status 67-68 Compliance Year & Month 69-71 Date of Update 72 Emergency Control 78-79 Operating Rate vs. Design Rate Must be = 1,2,3,4. Cannot be blank. Must be <_ today _ 5 years. Must be _<_ today. Must be 0,1,2, blank. Operating rate must be <_ 110% design rate. These fields have different units: SCC/YR for operating rate, SCC/HR for de- sign rate, convert design rate to SCC/HR by multiplying it by // ES RECOMMENDATIONS SCC processes codes with a se- condary code for in-process fuel should be flagged and the exist- ence of the fuel code verified. For example, an asphaltic con- crete rotary drier (3-05-002-01) should also have an in-process fuel code, i.e., 2-98-004-01 (re- sidual oil), 3-90-005-01 (distil- late oil) or 3-90-006-01 (natural gas). After the semi-annual updates to the file, fuel summaries should be made available to the state & re- gional offices for manual veri- fication against published data in the Mineral Industry Survey (MIS). ------- .TABLE III-l (CONT'D.) NEDS POINT SOURCE INVENTORY DATA QUALITY VALIDATION CHECKS FIELD NAME EPA VALIDATION CHECK FOR POINT RECORDS ES RECOMMENDATIONS Operating Rate vs. Design Rate (Cont'd.) Total fuel reported by a facility should be verified against a typical usage range per type of fuel. Ten major types of fuel have been identified in the NEDS file. i vo 80,81,83 84 Ash, Sulfur, Heat Content Source Code SCC 1- 2- 3- Consistent with ranges in Table 5. For each SCC the following source codes are valid. Source Code B C P (except 390 ----- ) 390 ---- 4 ------- 6 ------- C P s No code necessary If any of the above fields are blank, then those fields are valid, unless it specifically states that the field cannot be blan,. The processing of records with blank fields should be avoided. Records coded with blank fields should be returned to their originator for completion. ------- 0 SIC (Field #13). If the review of the Standard Industrial Classifi- cation (SIC) field were linked to the review of the Source Classifi- cation Code (SCC) and the Implementation Planning Program (IPP) process code, missing key SCCs might be identified. Also, the com- pleteness of the inventory could be judged more appropriately. o Stack Parameters (Fields #17 through 21). The proposed validation checks are much too limited. An order of magnitude error in coding stack parameters such as a stack temperature of 770 F rather than 77 F for emissions from a rock crusher might be undetected if these criteria are used. Yet, such an error, if used in air quality dispersio; modeling, could cause significant errors in predicted pollutant concen- trations. The validation checks for these parameters must be process specific. o Allowable Emissions (Fields #61 through 65). The proposed validation criteria are too broad and should be particularized for individual processes. o Operating Rate vs. Design Rate (Fields #78 and 79). The recommended enhancements should prove valuable to anyone using the inventory in air quality maintenance analysis. Enhancements were not recommended for all of the validation criteria but only for those which were considered to be most important and which promised to improve significantly the quality of NEDS inventory data. Validation Criteria Tests To determine the feasibility of the proposed validation criteria and the recommended enhancements, the NEDS data files for North and South Carolina were tested against selected validation criteria. There are three methods that can be used to audit data: (1) manual, (2) a semi-automated approach, and (3) an automated computer system. The cost and time required to audit data by a completely manual method or to develop software for an automated approach precluded the adoption of either of these methods for this study. Thus, a semi-automated approach was selected in which the EPA's Emission Inventory System/Permits and Registration (EIS/P&R) was used to retrieve specific data sets from the data file which were then audited 111-10 ------- manually. Because of the tediousness of auditing the files manually, the number of SCCs and validation criteria selected were limited. Because of these limitations, the files from two states were audited rather than from one so that anomalous results that might be due to characteristics of a single data file would be reduced. The files for North and South Carolina were selected because there was ready access to them and a familiarity with them. The classes of SCCs tested included: o Emission sources which were fairly common in the two study files. o Those sources which were most likely to be major emitters. ° Sources for which the data in the file were fairly complete. Using these general criteria, the files were visually inspected, and the following codes were selected for auditing: o 1-01-002-01 and 1-02-004-01. These two combustion source categories were selected inasmuch as the emissions from large pulverized coal burn- ing utility boilers (1-01-002-01) and from large residual oil burning industrial boilers (1-02-004-01) are quite significant. The two source categories were likely to have markedly differing source characteristics such as operating efficiencies, schedules, and stack parameters, however. Also, a large amount of data that could be used to establish SCC-specific validation criteria were likely to be available. o 3-05-020-01 through 3-05-020-06. The first five codes in this series were grouped because each refers to a crushing operation in a stone quarry. It was felt that most crushing operations should have similar characteristics. The Category IV code 06 (screening/conveying/handling) was grouped with the codes for crushing operations because the source characteristics would be similar. o 3-07-001-04 through 3-07-001-06. These codes cover sources in the sulfate pulping industry: recovery boiler/direct contact evaporator, smelt dissolving tank, and lime kiln. The validation criteria for these sources are common to all, and, thus, they were grouped for testing. III-ll ------- o 3-05-007-01 through 3-05-007-05. Kilns and dryers in the Portland cement manufacturing industry are covered by these codes. They were grouped for auditing because the source characteristics which were validated are similar. Although the test of the validation criteria was limited to these SCCs, the results should be applicable to most sources in a point source inventory. For each source selected using the procedures discussed above, the following audit checks were performed: 1. Missing Processes/Sources Within a Plant (missing SCCs). There are two methods that can be used to determine if SCCs might be missing from the data for a particular facility. For each SIC, a specific group of processes or unit operations should be present. If a cross-reference between SICs and SCCs can be established, missing or incorrectly coded SCCs could be determined by retrieving data for an SIC. If the IPP codes are linked to the SIC, a further sophistication would be added to this method. In the second method, a retrieval is made of all SCCs in a given faci- lity. For each "key" SCC a particular group of "sister" SCCs should be present. For example, in a stone quarry, a combination of crushing, materials handling, and storage operations would be ex- pected. If for a particular quarry an SCC for primary crushing is found without the corresponding code for storage, it could be sus- pected that the storage operation had been inadvertently overlooked. The second method for finding SCCs was tested because of a high probability that the SIC might be missing or incorrectly coded. 2. Validation of Stack Parameters. Table III-2 lists the validation criteria used to check the stack parameters for possible error. Most of the validation criteria included in Table III-2 were culled from Exhaust Gases from Combustion and Industrial Processes (EPA Publication No. APTD-0805) which contains ranges of typical values of stack parameters for selected industrial processes. These cri- teria were modified, to reflect current operating practice. The audit check for flow rate/exit velocity is a particularly important check among stack parameter audits. Although an audit of exit 111-12 ------- TABLE III-2 sec 1-01-002-01 1-02-004-01 3-07-001-06 3-05-020-01 through 3-05-020-06 3-05-007-01 through 3-05-007-05 VALIDATION CRITERIA FOR STACK TEMPERATURE DIAMETER (FT) (°F) 15-30 5-30 1-15 1-10 5-20 250-370 250-700 150-350 60- 80 250-750 STACK PARAMETERS STACK HEIGHT (FT) 200-800 100-500 30-250 20- 50 100-300 EXIT VELOCITY (FEET /SECOND) 30-60 30-60 20-40 5-30 20-60 PLUMED HEUUIT (FT) — — — 10-200 (1) The plume rise must be given If no stack parameters are coded. ------- velocity is recommended and these criteria were tested accordingly. there is certainly considerable merit in the validation criteria f c r flow rate proposed for the validation module. The proposed flow rate validation is particularly appropriate for those SCCs for which little stack characterization data are available. The recommended approach, however, is probably superior for such major sources as combustion. EPA might consider combining the two approaches. 3. Universal Transverse Mercator (UTM) Validation. The method used to audit UTMs was similar to that proposed in the module but was applied to determine if the source was correctly located in a specific county rather than just the state in general. A state was divided into a number of boxes -which contained one or more counties. The coordinates coded in the file for each source were compared with the coordinates of the corners of the box which contained the county in which the source was located. 4. Emissions Audit. Two separate steps were used to audit emissions: (1) the record was checked to determine if the entry for particulate emissions for those sources with a high emission potential based on a review of AP-42 was blank or zero, and (2) if the entry was not blank or zero, a ratio, R, was calculated using the formula, where, E- = Reported emissions E_ = Calculated emissions using annual throughput and the emission factors associated with the appropriate SCC. R was then checked to see if it fell within a range from 1.4 to 0.6. Although the recommendation has been made that only sources with emissions >_ 100 tons/year be audited, all sources selected for auditing in this test were checked. 5. Validation of Annual Operating Rate vs. Design Rate. The criteria proposed for the validation module were tested. A ratio, R, was calculated using the formula, 111-14 ------- where, EL = Theoretical maximum operating rate (maximum design rate X operating schedule) EL = Annual operating rate reported Results or the Validation Criteria Tests Table III-3 presents the results of the test of the validation criteria, i.e., operating and design rates, emissions, plume height, stack height, stack diameter, temperature, and exit velocity in terms of the percentage of records reviewed which failed an audit. As can be seen from this table, the over- whelming majority of the records reviewed failed at least one criteria test. According to these tests results, most of the anomalies, if the large number of blank data entries is disregarded, were detected by tests of emissions, stack gas velocity, and operating and design rates. Of a total of 136 plants tested, 42 were missing UTM coordinates and the coordinates of another 22 were apparently anomalous. Of all the facilities tested, none were found to have all the SCCs which were expected. There are two readily apparent explanations for the large number of points which failed to pass these audits: 1. There are numerous, severe problems with the data files audited. This conclusion must be conceded because of the numerous missing items in the data. Both files were rather old but were used pri- marily because of their ready availability. Both files have been substantially updated recently. 2. The auditing criteria used in the test may have been too sensitive, i.e., the range of discriminators used as audit criteria may be too narrow and, thus, resulted in the rejection of too many "good" re- cords. Although the best information available was used, it is probable that many of the records rejected were not in error. The next step in an auditing procedure would be to request that the originator of any apparently anomalous data verify the correctness of that data. 111-15 ------- TABLE III-3 PERCENT OF RECORDS INDIVIDUAL VALIDATION CRITERIA Number of Re- cords Tested Operating and Design Rate M l-i M 1 o> Emissions plume(2) Height Stack Hoi al-it- Stack Diameter REASON FOR FAILURE Blank Incorrect Blank Incorrect Blank Incorrect Blank Incorrect Blank Incorrect 1-01-002-01 NC 4 0 25 0 0 — — 0 0 0 75 SC 16 0 19 0 19 — — 0 19 0 38 WHICH FAILED VALIDATION CRITERIA 1-02-004-01 NC 49 12 18 18 14 — — 2 45 22 29 SC 38 0 32 16 18 — — 0 29 0 5 3-05-020-01/06 NC 162 10 7 8 27 38 2 2 0 2 0 SC 71 80 0 4 52 6 0 1 0 1 0 3-07-001-04/06 3-05-007-01/02 NC 27 0 7 4 44 — — 0 0 0 0 SC NC(1' SC 26 0 7 0 — 100 4—0 o—o 88 — 57 — — 0 — 86 0 — 0 0—0 0 — 29 OVERALL FAILURE RATE 22 10 8 34 16 1 3 9 4 7 Temperature Blank 0 13 0 0 Incorrect 25 44 16 0 19 14 ------- TABLE III-3 (CONT'D.) PERCENT OF RECORDS WHICH FAILED INDIVIDUAL VALIDATION CRITERIA 1-01-002-01 1-02-004-01 3-05-020-01/06 VALIDATION REASON FOR CRITERIA FAILURE NC SC NC SC NC SC Exit blank 0 0 10 16 01 Velocity Incorrect 50 62 69 18 01 Total % Failure by SCC of at Least One Criteria 100 81 96 92 60 86 3-07-001-04/06 3-05-007-01/02 ovt;RALL m FAILURE NC SC NCU; SC RATE 0 0 — 14 3 33 50 — 29 20 78 92 — 100 There were no sources with this SCC in the Nortli Carolina file. (2) ------- It can be further concluded that several iterations of auditing and verifyii g data may be necessary before the auditing criteria can be refined. It is recommended that any computerized validation program be tested on real data before it is finally adopted by EPA. The data from a minimum of two states should be tested in this recommended effort. The anomalies identi- fied must be verified. Also, randomly selected data from records which passed the audit should be independently verified. Not only can auditing routines be too sensitive, but also too insensitive. Before these tests are run, however, a major effort should be made to update the data files so that they are as complete as possible. A computerized auditing program which has been subjected to such tests can be quite useful in improving the quality of NEDS data. SAROAD AUDITING PROCEDURES After reviewing possible enhancements of auditing systems for SAROAD, it was determined, in concurrence with EPA, that the most valuable enhance- ment would be a list of validation criteria for individual pollutants and sampling methods delineating maximum and minimum values of data. Because of limited time and fiscal resources, this development of maximum/minimum discriminators was limited to those pollutants and sampling methods for which data were readily available. Table III-4 lists selected minimum value and maximum value discrimina- tors for pollutants for which there are EPA designated reference and equiva- lent methods. These discriminators are based on the required performance specifications for the methods in accordance with 40 CFR 53 and the lower detectable limit of sensitivities as determined under the performance tests. In compiling the table, a complete summary of actual values for the lower detectable limits as determined by the performance tests was unavailable. However, EPA specifications require the limit to be at least 0.01 ppm for ozone, sulfur dioxide and nitrogen dioxide. Selection of discriminators for methods other than EPA-designated reference and equivalent methods requires prior knowledge of the measurement range used, and the lower detectable limit of sensitivity of the method. 111-18 ------- TABLE IH-4 M I-H I SELECTED Parameter so2 so i. so2 so2 so2 so2 so2 so2 °3 °3 °3 °3 °0 3 °3 o 3 °3 °0 3 CO CO CO NO., 2 NO, MINIMUM & MAXIMUM VALUE DISCRIMINATORS EPA-Designated Method Maximum EQS-0775-001 EQS-0775-002 EQSA-1 27 5-005 EQSA-127 5-006 EQSA-0276-009 EQSA-0676-010 EQSA-0876-011 EQSA-0876-013 RFOA-1075-003 RFOA-107 5-004 RFOA-0176-007 RFOA-107 6-01 4 RFOA-107 6-015 RFOA-1076-016 RFOA-] 17 6-017 EQOA-0577-019 RFOA-057 7-020 RFCA-027 6-008 RFCA-0876-OJ2 RFCA-0177-018 RI-NA-0677-021 RFNA-0777-022 FOR EPA Value 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 50 50 50 0.5 0.5 DESIGNATED METHODS (ppm) Minimum \ * ft ft 0.004 0.003 * * ft * 0.002 0.001 ft ft * * ft ft 0.500 0.500 0.500 * * *Performance Specifications require a lower detectable limit of at. least 0.01 ppm. ------- Because the lower detectable limit may be affected by such factors as sam- pling rate and instrument averaging time, these variables must be also taken into account when determining the lower detectable limit of sensitivity. A feasibility analysis was performed to develop screening criteria or discriminators for use in identifying raw SAROAD data which fall outside the range and/or sensitivity of measurement methods. The following conclusions were drawn. 1. It is feasible to develop a set of minimum and maximum value discriminators for those pollutants for which there are EPA-designated reference and equivalent methods. Such designated methods require use of one specific measurement range, and conformity with specific performance specifications including the lower detectable limit of sensitivity. 2. Development of minimum/maximum discriminators for pollutants measured by methods other than designated reference or equivalent methods is not feasible, because of the greater diversity of procedures and instrumentation being used which are based on the same principles of measurement and are assigned the same method code. Such procedures, manual or instrumental, may or may not have the same sensitivity and may be used on one of several different measurement ranges. 3. The establishment of a maximum value discriminator based on a method's measurement range as opposed to the current system of using a single maximum value for each parameter code will provide more realistic auditing. However, the establishment of such a system would require the inclusion of a measurement range code in the SAROAD Parameter Method File. 4. The establishment of a minimum value discriminator based on a method's lower detectable limit of sensitivity can be readily accomplished by using the minimum detectable values which are maintained in the Para- meter Method File. An audit using the minimum value discriminator will have little consequence, however, because it is not unusual for many pollutants to occur at ambient concentrations which are less than the lower detectable limit of sensitivity of a method. For some 111-20 ------- parameters, such as methane and suspended particulate, ambient con- centrations remain well above the minimum detectable values due to high natural background levels. In such cases, the lower detectable limit of sensitivity is a poor choice for a discriminator. GENERAL CONCLUSIONS AND RECOMMENDATIONS NADB certainly needs computerized auditing systems for NEDS and SAROAD data because of the importance of preserving the integrity and quality of these data coupled with the enormity of the task of auditing all the data in NEDS and SAROAD. The proposed validation module is a significant step beyond existing programs such as NE061. Its development should go forward. Yet, the validation module under development is not perfect. Some major improve- ments to the module are recommended and, if accepted, these enhancements should significantly improve the auditing criteria included in the module. It must be emphasized, however, that any system should be thoroughly tested before being adopted for use. As anomalous data are identified by an audi- ting system and verified by the originators, the auditing system could be subjected to continuous testing to determine its precision and accuracy. 111-21 ------- CHAPTER IV FEASIBILITY OF A QUALITATIVE INDEX FOR NEDS Whenever a vast quantity of data is handled by a computerized system such as the National Emissions Data System (NEDS), inevitably there are questions about the "quality" of the data in the system. Quality refers not only to the correctness of the data in a file but also to the complete- ness of the file and its age. One must know if the data to be used for such activities as air quality maintenance planning are correct, complete, and current. In an effort to address this issue related to the quality of NEDS data, the National Air Data Branch (NADB) requested that a proposed Emission Inventory Quality Index be reviewed to determine its feasibility, recommended improvements be made to this proposed index, or a new index be developed. REVIEW OF PROPOSED EMISSION INVENTORY QUALITY INDEX The Emission Inventory Quality Index (EIQI) which has been proposed in- cludes seven key 'elements which could be used to judge the quality of a NEDS data file: 1. Base Year. If the data in a file are more than two years old, major updates and revisions, which would be necessary to reflect what may be substantial changes in the emission inventory, may not have been made. Thus, the age of the data file is of considerable importance in judging its quality. 2. Semiannual Report Currency. Each state is required by Environmental Protection Agency (EPA) regulations to report semiannually emissions and other related data for all new sources, sources that cease oper- ation, and sources which achieve compliance during the reporting period (40 CFR 51.7). If the NEDS file has not been updated with these semiannual reports, it will not be current and may not be complete. The semiannual reporting requirement is not sufficient, however, to ensure that the file will be completely updated. Semi- annual reports should be used to supplement periodic inventory updates. IV-1 ------- 3. Verification File. EPA is attempting to create a "verification file" of sources not presently in NEDS by using information avail- able from Dunn and Bradstreet, state industrial directories, and other similar references. The Regional offices, in liaison with the states, have been requested to verify the existence of point sources in the verification file and to determine if those that exist should be incorporated into NEDS. The size of the verification file for a particular state when compared with the size of the state's NEDS file is an indication of the completeness of the NEDS file. 4. NEDS/CDS Mismatches. Sources which appear in Compliance Data System (CDS) should be present in NEDS. Efforts are underway to eliminate these mismatches. 5. SIEFA. The Source, Inventory, and Emission Factor Analysis (SIEFA) computer program is supposed to provide an indication of the preci- sion and accuracy of a state's emission inventory. 6. Data Anomalies. As described in Chapter III, NADB is developing computerized data auditing systems to identify apparent data anomalies. NEDS users often identify data anomalies, as well. The number of anomalies identified by either method is an indica- tion of the correctness of NEDS data. 7. Missing Items. NADB has an automated system for identifying items missing from a NEDS file. Only key items which are not included in edit checks, i.e., those items which will cause the entire data set to be rejected, should be considered. Years of record, city, Stand- ard Industrial Classification (SIC) , and estimation method cannot be considered, because if they are missing the data set will be rejected. On the other hand, contact personnel and all Card 5 data should be excluded because they are not key data. A single EIQI can be calculated using a multiple linear equation to combine these seven quality factors. Of necessity, this formula causes some factors to be given more importance than others. Neither the EIQI or any other proposed indices should be adopted at this time. An index should be simple and readily understood and all of the proposed indices are much too complex. Although the factors identified are important, IV-2 ------- there is considerable disagreement concerning their relative importance. Many of the inputs to an index are still in the development stage. An im- proved automated data auditing system would be particularly useful for input to an index. For all of these reasons, an EIQI is not feasible at present. CONCLUSIONS AND RECOMMENDATIONS There is, however, much that could be done during the next few years to hasten the implementation of a NEDS data quality index, although such index is not currently feasible. NADU should supply a statistical quality report on each state's data files to NEDS users. These reports could be output by an automated auditing system. Few software modifications would be necessary. In general, the reports would identify the percentage of records in a file which fail to pass individual validation criteria. (A format similar to Table III-3 could be used.) Other quality measures such as completeness and age could be incorporated as well. These reports could be used to identify problems with the data files, as well as provide a method for comparing the quality of a state's file with that of another state. IV-3 ------- APPENDIX A CODES PROPOSED BY TACB ------- ADDITIONS TO':;EDS SOURCE CLASSIFICATION CODES INDUSTRIAL PROCESS - CHEMICAL MANUFACTURING Plastics 3-01-018-06 High Density Polyethylene -07 Low Density Polyethylene -08 Polybutadiene -09 Polypropylene -10 Polystyrene Units Tons Product Phthalic Anhydride 3-01-019-01 via Naphthalene -02 via 0-Xylene Amines/Amides 3-01-03U-02 Diethylamine -03 tertButylanine -Oh Ethanolajnine -05 Ethyler.eamine -06 Hexame'chylenedianyLne -07 nPropylarr.ine ' -08 Urea Acetaldehyde 3-01-131-01 General -02 via Ethylene -03 via Ethanol ice-tic Acid 3-01-132-01 General -02 via Methanol -03 via Butane -Ok via Acetaldehyde Acetic Anhydride 3-01-133-01 General -02 via Acetic Acid -03 via Ethylene Oxidation Acetone Cyanohydrin 3-01-13^-01 General ------- INDUSTRIAL PROCESS - CHEMICAL MANUFACTURING continued Acetonitrile 3-01-135-01 General Units Tons Product Acetylene 3-01-136-01 General Acrylates 3-01-137-01 Butyl Acrylate -02 Ethyl Acrylate -03 Methyl Acrylate -Ok Butyl Methacrylate -05 isoButyl Methacrylate -06 Ethyl Methacrylate -07 Methyl Methacrylate -99 Other/Not Classified Acrylic Acid 3-01-138-01 General Acrylonitrile 3-01-139-01 General Adiponitrile 3-01-lUO-Ol General -02 via Adipic Acid -03 via Butadiene Allyl Alcohol 3-01-lUl-Ol General Allyl Chloride 3-01-1U2-01 General it it ii it Aniline 3-01-1U3-01 General ------- INDUSTRIAL PROCESS - c?".:::.:;.L MANUFACTURING continued Bisphenol A 3-01-lUU-Ol General nButyl Alcohol 3-01-11*5-01 General secButyl Alcohol 3-01-IU6-01 isoButyl Alcohol 3-01-1U7-01 Gerersl tertButyl Alcohol 3-01-lUS-Cl General nButyl Chlorice 3_0l-ll| 9-011 General 1,3-Butylene Glycol 3-01-150-01 General Butyraldehyde 3-01-151-01 Genc-ril Carbon Dis\ilfide 3-01-152-01 General Carbon Tetrachloride 3-01-153-01 Ger.-:.-al f Cellosolves* 3-01-15^-01 General Units Tons Product ------- j (JSTRIAL PROCESS - CHEMICAL M/-.:?UFACTURIiTG cor.tir. Chlorohydrins 3-01-155-01 General Chloroform 3-01-156-01 General Chloroprene 3-01-157-01 General Cyclohexanol 3-01-158-01 General Cyclohexanone 3-01-159-01 General Dichlorobutene 3-01-160-01 General Dichloroethane 3-01-161-01 General -02 1,1-DichloroGthane -03 1,2-Dichloroethane Diethyl Ether 3-01-162-01 General Diisopropyl Ether 3-01-163-01 General . Dimethyl Terephthalate (+TPA) 3-01-16U-01 General Units Tons Producl ------- INDUSTRIAL PROCESS - CHEMICAL MANUFACTURING continued l,U-Dioxane 3-01-165-01 General Dipropyl Ether 3-01-166-01 General Ethyl Acetate 3-01-167-01 General Ethyl Alcohol 3-01-168-01 General Ethyl Benzene 3-01-169-01 General Ethyl Chloride 3-01-170-01 General Ethylene 3-01-171-01 General 1,2-Ethylene Dichloride 3-01-172-01 General Ethylene Glycol 3-01-173-01 General Ethylene Oxide 3-01-17^-01 General Freons 3-01-175-01 General Units Tons Product ------- INDUSTRIAL PROCESS - CHEMICAL MAI7JFACTUPINC- continued Glycerin 3-OI-1T6-01 General -02 via Epichlorchydrin -03 via Allyl Chloride -OU via-Acrolein-Hycirogen Peroxide -05 via Propylenr— Chlorine 1,6-Hexanediol 3-01-177-01 General HydanR 3-01-178-01 General Units . Tons Product n 11 n Hydrogen Cyanide 3-01-179-01 General -02 Direct Process HypalonR 3-01-180-01 General 3-01-15.1-01 General Isoprene 3-01-162-01 General Lactic Acid 3-01-153-01 General Methyl Acetate 3-01-18^-01 General Methyl Alcohol 3-01--185-01 General ------- INDUSTRIAL PROCESS - CHEMICAL MANUFACTURING continued Methyl Chloride 3-01-186-01 General Methyl Chloroform 3-01-187-01 General Methyl isoButyl K^tone 3-01-188-01 General . Methacrylonitrile 3-01-189-01 General Methylcyclohexane 3-01-190-01 General Methylcyclopentane 3-01-191-01 General Methyl Ethyl Ket'one 3-01-192-01 General Methyl Propyl Ether 3-01-193-01 General Methylene Chloride 3-01-19U-01 General Nitromethane 3-01-195-01 General NordelR 3-01-196-01 General Units Tons Product ------- TTCC r'lj-^^Tp * r >*•• *-»rr? A fmrr^T1**.'; I.^Ji^ •• ^*.—.- : JuwrlJ-i .'-r-i* L; /."*»«-• j. v i • • . - ^/ Olefins 3-01-197-01 Ethylene -02 Fropylene -03 Butylene -99 Other/Not Classified Oxo Process 3-01-198-01 General Paraformaldehyde 3-01-199-01 General Perchloroethylene 3-01-200-01 General Pentaerythritol 3-01-201-01 General Phenol 3-01-202-01 General isoPropyl Alcohol 3-01-203-01 General Propylene Glycol 3-01-20U-01 General Propylene Oxide 3-01-205-01 General Styrene 3-01-206-01 General Units Tons Product it M II ------- INDUSTRIAL PROCESS - CHEMICAL .".^"UrACTi:? .IITG cor.tir.UGC Tetraethyl Lead 3-01-207-01 General Tetrahydrofuran 3-01-208-01 General Trichloroethylene 3-01-209-01 General Trinethylolpropane \ 3-01-210-01 General Units Tons Product Triton R 3-01-211-01 General Vinyl Acetate 3-01-212-01 General -02 via Acetylene -03 via Ethylene Vinyl Chloride 3-01-213-01 General Vinylidene Chloride 3-01-21U-01 General VoranolR 3-01-215-01 General ------- INDUSTRIAL PROCESS - PRIMARY METALS Units Aluminum Ore - Bauxite 3-03-000-02 Alumina Xfg. Tons Product Aluminum Ore - Electroljrtic Reduction 3-03-001-06 Ingot Casting Tons Metal -07 Aluminum Fluoride Mfg. Tons Produced -08 Cryolite Mfg. " Iron Production 3-03-008-09 Ingot Casting Tons Metal -10 Ore Calcining Tons Produced Magnesium - Electrolytic 3-03-035-01 Magnesium Oxide Kiln Tons Produced -02 Magnesium Chloride Neutralizer " -03 Magnesium Chloride Dryer " -OU Magnesium Chloride Cells Tons Metal -05 Magnesium Casting/Alloying " -99 Other/Not Classified " ------- HDUSTRIAL PROCESS - PETRCLEUV INDUSTRY Crude Distillation 3-06-OlU-Ol General Gas Recovery/Liquifaction 3-06-015-01 General Gas Sveetening 3-06-016-01 General Hydrogen Treating 3-06-01T-01 General Aromatic Recovery 3-06-018-01 General Solvent Extraction 3-06-019-01 General Acid Treating 3-06-020-01 General Polymerization 3-06-021-01 General Isomerization 3-06-022-01 General Alky1ation 3-06-023-01 General Dehydrogenation 3-06-02U-01 General Units 1000 Barrels Processed Million Cubic Feet Processed 1000 Barrels Charged 1000 Barrels Processed ------- NDUSTRIAL Pr~CES3 - PETPHLEUV '"DUSTPY continued Lube Oil 3-06-025-01 General Delayed Coking 3-06-026-01 General Calcining 3-06-027-01 General Waste Water Treatment 3-06-028-01 General Units 1000 Barrels Processed 1000 Barrels Charged Tons Processed 1000 Barrels Waste Wate: ------- INDUSTRIAL PROCESS - riATU::;.! GAS INDUSTRY Compression 3-10-001-01 Elcvdowri -02 Futi'civ-c Units Million Cubic Feet Processed it Dehydration 3-10-002-01 tri Ethylerx- Glycol -99 Other/Not Classified ii it Gas Sweetening 3-10-003-01 M2A Process w/Flare -02 MEA Process v/Incinerator • -99 Other/ICot Classified it it it Natural Gas Liquids 3-10-OOU-01 Refrigeration -02 Absorption -03 Fracticnation -OU Adsorption -99 Other/Hot Classified 1000 Gallons Product tt tt tt it Flares 3-10-005-01 Waste Gas Million Cubic Feet ------- '.'NDUSTRIAL PROCESS - PLASTIC FASEICATI-: Melamine 3-11-001-01 General -99 Solvent -Specify Tons Product Tons Solvent Phenolic 3-11-002-01 General -99 Solvent-Specify Tons Product Tons Solvent Polyester 3-11-003-01 General -02 Fiberglass -99 Solvent-Specify Tons Product it Tons Solvent Polystyrene 3-11-OOU-Ol General -02 Styrofoam -99 Solvent-Specify Tons Product it Tons Solvent Polyurethane 3-11-005-01 General -99 Solvent-Specify Tons Product Tons Solvent Polyvinyl Chloride 3-11-006-01 General -99 Solvent-Specify Tons Product Tons Solvent Other/Not Classified 3-11-999-99 Specify in Remark Tons Product ------- 3IET SOURCE EVAPORATION - CJ-ZAI-::"G SOLVES? Units Surface Wiping U-01-003-01 Acetone Tons Solvent -02 Butyl Acetate " -03 Butyl Alcohol " -OU Carbitol " -05 Cellosolve " -06 Cellosolve Acetate " -07 Diaethylfornanide " -08 Ethyl Acetate " -09 Ethyl Alcohol " -10 Gasoline -11 Isopropyl Alcohol -12 Isopropyl Acetate -13 Kerosene -lU Lactol Spirits " ' -15 Methyl Acetate " -16 Methyl Alcohol " -17 MEK " -18 MIBK " -19 Mineral Spirits " -20 Naphtha " __ _ , it -21 Toluene -22 Varsol " -23 Xylene " -99 Other-Specify ------- POINT SOURCE EVAPORATION - SURFACE COATING Units Sealing Compounds ^-02-010-01 General Tons Coating -99 Solvent-Specify Tons Solvent ------- POINT SOURCE EVAPORATION - PSTP.CLEUM PRODUCTION STORAGE Units Fixed Roof U-03-001-17 Breath - Naphtha 1000 Gal Stge Capacity -18 Breath - Reformate " It it it it -19 Breath - Alkylate -20 Breath - Gas Oil " -21 Breath - Residual Oil " -22 Breath - LPG " -62 Working - Naphtha 1000 Gal Throughput -63 Working - Reformate " -6k Working - Alkylate -65 Working 7 Gas Oil -66 Working - Residual Oil -67 Working - LPG Floating Roof U-03-002-17 Stand Stge - Naphtha 1000 Gal Stge Capacity -18 Stand Stge - Reformate -19 Stand Stge - Alkyiate -20 Stand Stge - Gas Oil -21 Stand Stge - Residual Oil ti ------- POINT SOURCE EVAPORATION - PETROCHEMICAL STORAGE Units Fixed Roof - Breathing 14-oU-OOl-Ol Acetaldehyde 1000 Gal Stge Capacity -02 Acetic Acid " -03 Acetic Anhydride " -OU Acetone " -05 Acetonitrile " -06 Acrylonitrile " -07 Allyl Alcohol " -08 Allyl Chloride " -09 Butadiene " -10 secButyl Alcohol " -11 isoButyl Alcohol " -12 tertButyl Alcohol " -13 nButyl Chloride " -lU Carbon Tetrachloride " -15 Chloroform " -16 Chloroprene " -17 Cumene " -18 Cyclohexanone " -19 Dichloroethane " -20 Dichloropropylene (PDC) " -21 Diethyl Ether " -22 Diethylamine " -23 Diisopropyl Ether " -2k l,U-Dioxane " -25 Dipropyl Ether " -26 Ethyl Acetate " -27 Ethyl Acrylate " -28 Ethyl Alcohol " -29 Ethyl Benzene " -30 Ethylene " -31 1,2-Ethylene Dichloride " -32 Ethylene Oxide " -33 Freon 11 -3^ Isoprene " -35 Isocyanates " -36 Methacrylonrcrile " -37 Methyl Acetate " -38 Methyl Acrylate " -39 Methyl Alcohol " -Uo Methylcyclohexane " -1»1 Methylcyclopentane " -U2 Methylene Chloride " -1*3' Methyl Ethyl Ketone " -kh Methyl Kethacrylate (i-IMA) " -U5 Methyl Propyl Ether " -1*6 Nitromethane " -1*7 Phenol " -148 Propane Dichloride " -1*9 Propionaldehyde " ------- POINT SOURCE EVAPORATION - PETROCHEMICAL STORAGE continued Units Fixed Roof - Breathing (continued) U-OU-001-50 isoPropyl Alcohol 1000 Gal Stge Capacity -51 nPropylamine " -52 Propylene Oxide " -53 Styrene " -5U Tetrahydrofuran " -55 1,1,1-TrichIoroethane " -56 Trichloroethylene " -57 Trichloropropylene " -58 Vinyl Acetate " -59 Vinyl Chloride " -60 Vinylidene Chloride " -6l Xylene " -99 Other/Not Classified " Fixed Roof - Working U-OU-005-01 Acetaldehyde 1000 Gal Throughput -02 Acetic Acid " -03 Acetic Anhydride " -Ok Acetone " -05 Acetonitrile " -06 Acrylonitrile " -07 Allyl Alcohol " -08 Allyl Chloride " -09 Butadiene " -10 secButyl Alcohol -11 isoButyl Alcohol " -12 tertButyl Alcohol " -13 nButyl Chloride " -Ik Carbon Tetrachloride " -15 Chloroform " -16 Chloroprene " -17 Cumene -18 Cyclohexanone " -19 Dichloroethar.e " -20 Dichlorcpropylene (PDC) " -21 Diethyl Ether " -22 Diethylamine -23 Diisopropyl Ether " -2k l,U-Dioxane " -25 Dipropyl Ether -26 Ethyl"Acetate " -27 Ethyl Acrylate " -28 Ethyl Alcohol " -29 Ethyl Benzene -30 Ethylene -31 1,2-Ethyleae Dichloride " -32 Ethylene Oxide " ------- POINT SOURCE EVAPORATION - PETROCHEMICAL STORAGE continued Units Fixed Roof - Working (continued) l*-Ol*-005-33 Freon 11 1000 Gal Throughput -3l* Isoprene -35 Isocyanates -36 Methacrylonitrile -37 Methyl Acetate " -38 Methyl /-.crylate " -39 Methyl Alcohol -1*0 Methylcyclohexane -1*1 Methylcyclopentane -1*2 Methylene Chloride -1*3 Methyl Ethyl Ketone " -1*1* Methyl Methacrylate (MMA) " -1*5 Methyl Propyl Ether " -1*6 Nitroraethane -1*7 Phenol " -1*8 Propane Bichloride " -1*9 Propionaldehyde " -50 isoPropyl Alcohol " -51 nPropylamine -52 Propylene Oxide " -53 Styrene -5l* Tetrahydrofuran " -55 1,1,1-Trichloroethane " -56 Trichloroethylene " -57 Trichloropropylene " -58 Vinyl Acetate " -59 Vinyl Chloride " -60 Vinylidene Chloride " -6l Xylene " -99 Other/Not Classified " Floating Roof - Standing U-OU-010-01 Acetaldehyde 1000 Gal Stge Capacity -02 Acetic Acid n -03 Acetic Anhydride " -Ol* Acetone " -05 Acetonitrile " -06 Acrylcnitrile " -07 Allyl Alcohol " -08 Allyl Chloride " -09 Butadien-e " -10 secButyl Alcohol " -11 isoButyl Alcohol " -12 tertButyl Alcohol " -13 nButyl Chloride " -ll* Carbon Tetrachloride " -15 Chloroform " ------- POINT SOURCE EVAPORATION - PETROCHEMICAL STORAGE continued Units Floating Roof - Standing (continued) lt-OU-010-l6 Chloroprene 1000 Gal Stge Capacity -IT Cumene " -18 Cyclohexanone " -19 Dichloroethane " -20 Dichloropropylene (PDC) " -21 Diethyl Zther " -22 Diethylamine " -23 Diisopropyl Ether " -2U l,U-Dioxane " -25 Dipropyl Sther " -26 Ethyl Acetate " -27 Ethyl Acrylate " -28 Ethyl Alcohol " -29 Ethyl Benzene " -30 Ethylene " -31 1,2-Ethylene Bichloride " -32 Ethylene Oxide " -33 Freon 11 " -3^ Isoprene " -35 Isocyanates " -36 Methaerylonitrile " -37 Methyl Acetate " -38 Methyl Acrylate " -39 Methyl Alechoi " -ko Methylcyclohexane " -Ul Methylcyclcpentane " -1*2 Methylene Chloride " -h3 Methyl Ethyl Ketone " -kk Methyl Methacrylate (I-S4A) " -U5 Methyl Propyl Ether -U6 Nitromethane " -1*7 Phenol " -it8 Propane Dichloride " -i;9 Propionaldehyde " -50 isoPropyl Alcohol " -51 nPropylardne " -52 Propylene Oxide " -53 Styrene " -5^ Tetrahydrofuran " -55 1,1,1-Trichloroethane " -56 Trichloroethylene " -57 Trichlorcpropylene " -58 Vinyl Acetate " -59 Vinyl Chloride " -60 Vinylldene Chloride " -6l Xylene " -99 Other/Not Classified " Other/Not Classified U-0^-999-99 Specify in Remark 10°° Gal Stored ------- " POINT SOURCE EVAPORATION - PETROCEEMICAL MARKETING & TRAiATSPORTATIOM Units Tank Cars/Trucks - Splash Load 4-10-001-01 Acetaldehyde 1000 Gal Transferred -02 Acetone, " -03 Acetonitrile " -OU Acrylonitrile -05 Allyl Alcohol " -06 Allyl Chloride " -07 isoButyl Alcohol -08 tertButyl Alcohol " -09 nButyl Chloride " -10 Carton Tetrachloride " -11 Chloroform " -12 Chloroprene " -13 Cumene " -14 Cyclohexanone " -15 Cyclopentane " -16 Dichloroethane -17 1,2-Dichloroethylene " -18 Diethyl Ether " -19 Diethylamine " -20 Diisopropyl Ether " -21 l,U-Dioxane -22 Dipropyl Ether " -23 Ethyl Acetate " -2U Ethyl Alcohol " -25 Ethylbenzene " -26 Freon 11 " -27 Heptane " -28 Hexane " -29 Isoprene " -30 Methacrylonitrile " -31 Methyl Acetate " -32 Methyl Alcohol " -33 Methylcyclohexane " -3^ Methylcyclopentane " -35 Methylene Chloride " -36 Methyl Ethyl Ketone " -37 Methyl Propyl Ether " -38 Nitromethane " -39. isoOctane " -40 Pentane " -41 isoPentane " -42 nPropylanine " -*43 isoPropyl Alcohol " -44 Styrene -45 Toluene " -46 1,1,1-Trichloroethane " -47 Trichloroethylene " -48 Vinyl Acetate " -49 Vinyl Chloride " -50 Vinylidene Chloride " -51 Xylene " -99 Other/Not Classified " " ------- POINT SOURCE EVAPORATION - PETROCHEMICAL MARKETING & TRANSPORTATION ccntir.ued Tank Cars/Trucks U-10-005-01 -02 -03 -OU -05 -06 -07 -08 -09 -10 -11 -12 -13 -1U -15 -16 -17 -18 -19 -20 -21 -22 -23 -2k -25 -26 -27 -28 -29 -30 -31 -32 -33 -3k -35 -36 -37 -38 -39 -UO -Ul -1+2 -U3 -kk -U5 -U6 -1*7 -1*8 -1*9 -50 -51 -99 - Submerged Load Acetaldehyde Acetone Acetonitrile Acrylonitrile Allyl Alcohol Allyl Chloride isoButyl Alcohol tertButyl Alcohol nButyl Chloride Carbon Tetrachloride Chloroform Chloroprehe Cumene Cyclohexanone Cyclopentane Dichloroethane 1,2-Dichloroethylene Diethyl Ether Diethylamine Diisopropyl Ether l,U-Bioxane Dipropyl Ether Ethyl Acetate Ethyl Alcohol Ethylbenzene Freon 11 Heptane Hexane Isoprene Methacrylonitrile Methyl Acetate Methyl Alcohol Methylcyclohexane Methylcyclopentane Methyl en e Chloride Methyl Ethyl Ketone Methyl Propyl Ether Nitromethane isoOctane Pentane isoPentane nPropylamine isoPropyl Alcohol Styrene Toluene 1 ,1 ,1-Trichloroethane Trichloroethylene Vinyl Acetate Vinyl Chloride Vinylidene Chloride Xylene Other /Hot Classified Units 1000 Gal Transferred 11 n n it tt n tt tt 11 n ti ii " it it it it it n it n it it n n n it it it " it it n it ii ti it ti it 11 n it it tt " n tt " " tt it ------- POINT SOURCE EVAPORATION - PETROCHEMICAL STORAGE continued Units Fixed Roof - Working (continued) U-OU-005-33 -3U -35 -36 -37 -38 -39 -Uo -Ul -U2 -U3 -UU -U5 -U6 -U7 -US -1*9 -50 -51 -52 -53 -5U -55 -56 -57 -58 -59 -60 -61 -99 Floating Roof - U-OU-010-01 -02 -03 -OU -05 -06 -07 -08 -09 -10 -11 -12 -13 -lU -15 Freon 11 Isoprene Isocyo. nates Methacrylonitrile Methyl Acetate Methyl Acrylate Methyl Alcohol Met hylcyc lohexane Methylcyclopentar.e Methylene Chloride Methyl Ethyl Ketone Methyl Methacrylate (MMA) Methyl Propyl Ether Nitroraethar.e Phenol Propane Bichloride Propionaldehyde isoPropyl Alcohol nPropylamine Propylene Oxide Styrene Tetrahydrofuran 1,1,1-Trichloroethane Trichloroethylene Trichloropropylene Vinyl Acetate Vinyl Chloride Vinylidene Chloride Xylene Other/Kot Classified Standing Ac et aldehyde Acetic Acid Acetic Anhydride Acetone Acetonit.rile Acrylcnitrile Allyl Alcohol Allyl Chloride Butadiene sec Butyl Alcohol isoButyl Alcchol tertButyl Alcohol nButyl Chloride Carbon Tetrachloride Chloroform. 1000 Gal Throughput 11 it ii it n ii it n n n it it 11 it ii tt it n it it it it n n ii n ii tt M 1000 Gal Stge Capac: ii it it n n n n n it ti ii n ii it ------- POINT SOURCE EVAPORATION - PETROCHEMICAL MARKETING & TRANSPORTATION continued Marine Vessels U-lO-015-01 -02 -03 -OU -05 -06 -07 -08 -09 -10 -11 -12 -13 -Ii* -15 -16 -17 -18 -19 -20 -21 -22 -23 -2l* -25 -26 -27 -28 -29 -30 -31 -32 -33 -3U -35 -36 -37 -38 -39 -1*0 -1*1 -1*2 -1*3 -1*1* —1*5 -1*6 -1*7 -1*8 -1*9 -50 -51 -99 - Load Ac tt aldehyde Acetone Acstonitrile Acrylonitrile Allyi Alcohol Allyl Chloride isoButyl Alcohol tertButyl Alcohol nButyl Chloride Carbon Tetrachloride Chloroform Chloroprene Curtene Cyclohexancne Cyclopentane Bichloroethane 1 , 2-Dichloroethylene Di ethyl Ether Diethylamine Diisopropyl Ether l,l*-Dioxane Dipropyl Ether Ethyl Acetate Ethyl Alcohol Ethylbenzene Freon 11 Heptane Hoxane Isoprene Methacrylonitrile Methyl Acetate Methyl Alcohol M&thylcyclohexane Met hyl cycle-pent ane Methylene Chloride Methyl Ethyl Ketone Methyl Propyl Ether Nlti'omethane .isoOctane Pent ane isoPentane nPropylamine isoPropyl Alcohol Styrene Toluene 1 ,1 ,1-Trichloroethane Trichloroethylene Vinyl Acetate Vinyl Chloride Vinylidene Chloride Xylene Other/Not Classified Units 1000 Gal Transferred n it n it it tt it n n n n n n n n n n n n n n n n n ii n n n ii n n n n n n n it n n n n it •fi it ii it it n ti it ------- POINT SOURCE EVAPORATION - PETRQCK&MICAL MARKETING & TRANSPORTATION continued Units Marine Vessels - Load U-10-015-01 Acetaldehyde 1000 Gal Transferred -02 Acetone -03 Acstonitrile -OU Acrylonitrile -05 Allyl Alcohol " -06 Allyl Chloride " -07 isoButyl AlcohSl " -08 tertButyl Alcohol JJ -09 nLutyl Chloride -10 Carbon Tetrachloride -11 Chloroform -12 Chloroprene -13 Cuirene -lU Cyclohexancne -15 Cyclopentane -l6 Dichloroethane -17 1,2-Dichloroethylene -18 Diethyl Ether " -19 Diethylamine " -20 Biisopropyl Ether -21 l,U-Didxane -22 Dipropyl Ether " -23 Ethyl Acetate " -2U Ethyl Alcohol " -25 Ethylbenzene -26 Freon 11 " -27 Heptane " -28 Ilexane -29 Isoprene " -30 Methacrylonitrile " -31 Methyl Acetate " -32 Methyl Alcohol " -33 Kfcthylcyclohexane " -3^ Methylcyclopentane -35 Methylene Chloride " -36 Methyl Ethyl Ketone " -37 Methyl Propyl Ether " -33 Hitromethane " -39 ' isoOctane " -UO Pentane " -Ul isoPentane " -k2 nPropylamine " -i*3 isoPropyl Alcohol " -kk Styrene " -^5 Toluene " -b6 1,1,1-Trichloroethane " -U7 Trichloroethylene " -U8 Vinyl Acetate " -1*9 Vinyl Chloride " -50 Vinylidene Chloride " -51 Xylcne -99 -Other/Not Classified " ------- !?OINT SOURCE EVAPORATION - PETROCHEMICAL MARKETING & TRANSPORTATION continued Tank Cars /Trucks 4-10-010-01 -02 -03 -04 -05 -06 -07 -08 -09 -10 -11 -12 -13 -14 -15 -16 -17 -18 -19 -20 -21 -22 -23 -24 -25 -26 -27 -28 -29 -30 -31 -32 -33 -34 -35 -36 -37 -38 -39 -ho -4i -42 -43 -44 -45 -46 -47 -48 -49 -50 -51 -99 - Unload Ac et aldehyde Acetone Acetonitrile Acrylonitrile Allyl Alcohol Allyl Chloride isoButyl Alcohol tertButyl Alcohol nButyl Chloride Carton Tetrachloride Chloroform • Chloroprene Cumene Cyclohexanone Cyclopentane Dichloroethane 1 ,2-Dichloroethylene Diethyl Ether Diethylamine Diisopropyl Ether 1 , 4-Dioxane Dipropyl Ether Ethyl Acetate Ethyl Alcohol Ethylbenzene Preon 11 Heptane Hexane Isoprene Methacrylonitrile Methyl Acetate Methyl Alcohol Methylcy c lohexane Methylcyclopentane Methylene Chloride Methyl Ethyl Ketone Methyl Propyl Ether Nitronethane isoOctane Pentane isoPentane nPropylamine isoPropyl Alcohol Styrene Toluene 1,1,1-Trichloroethane Trichloroethylene Vinyl Acetate Vinyl Chloride Vinylidene Chloride Xylene Other/Not Classified Units 1000 Gal Transferred it ii it it ii it it it ii n tt n M II II II It II II II II II II II If II II It It II II It It IT II It tt II tt II It •II II It II It It II It II II ------- POINT SOURCE EVAPORATION - PETROCHEMICAL MARKETING & TRANSPORTATION continued Units Marine Vessels - Unload H-10-020-01 Acetaldehyde 1000 Gal Transferred -02 Acetone " -03 Acetonitrile " -Ok Acrylonitrile " -05 Allyl Alcohol " -06 Allyl Chloride " -07 isoButyl Alcohol " -08 tertButyl Alcohol . " -09 nButyl Chloride " -10 Carbon Tetrachloride " -11 Chloroform " -12 Chloroprene " -13 Cuiaene " -lU Cyclohexanone " -15 Cyclopentane " -16 Dichloroethane " -17 1,2-Dichloroethylene " -18 Diethyl Ether " -19 Diethylamine " -20 Diisopropyl Ether " -21 l,U-Dioxane " -22 Dipropyl Ether " -23 Ethyl Acetate -2k Ethyl Alcohol " -25 Ethylbenzene " -26 Freon 11 " -27 Heptane " -23 Hexane " -29 Isoprene " -30 Methacrylonitrile " -31 Methyl Acetate " -32 Methyl Alcohol " -33 Methylcyclohexane " -3k Methylcyclopentane " -35 Methylene Chloride " -36 Methyl Ethyl Ketone " -37 Methyl Propyl Ether " -38 Nitromethane " -39 isoOctane " -kO Pentane " -Ul isoPentane " -k2 nPropylamine " -k3 isoPropyl Alcohol " -kk Styrene " -U5 Toluene " -1+6 1,1,1-Trichloroethane " -1+7 Trichlorcethylene " -U8 Vinyl Acetate " -1+9 Vinyl Chloride " -50 Vinylidene Chloride " -51 Xylene " -99 Other/Not Classified " ------- APPENDIX B CODES PROPOSED BY RADIAN ------- Symbols in Che far right hand column of the Source Classi- fication Code tables indicate the action taken to revise each code These symbols represent the following actions: Symbol Action * No changes were made to the existing EPA SCC. 4- No changes were made to the newly added TACB (Texas'Air Control Board) SCC. 1 Both the source title and emission factor were changed for an existing EPA SCC. 2 Both the source title and emission factor were changed for a newly added TACB SCC. 3 A new SCC was added. 4 Only the emission factor was changed for an existing EPA SCC. 5 Only the emission factor was changed for a newly added TACB SCC. ------- KKVISED SCC LISTINGS Fixed Roof 4-03-001-01 4-03-001-02 4-03-001-03 4-03-001-04 4-03-001-05 4-03-001-06 4-03-001-07 4-03-001-08 4-03-001 -09 4-03-001-10 4-03-001-11 4-03-001-12 4-0 3-001-1'i 4-03-001-14 4-03-001-15 4-03-001-16 4-03-001-17 4-03-001-18 4-03-001-19 4-03-001-20 4-03-001-21 4-03-001-22 4-03-001-23 4-02-001-24 4-02-001-21) Source Breath-Gasoline < 100,000 hbl Breath-Crude < 100,000 bbl Workijig-fiasollne Working-Crude Breath-JP-4 < 100,000 bbl Breath-.Iet Kero < 100,000 bbl Breath-Dist No. 2 < 100,000 bbl Breath-Benzene Breath-Cyclohexane Breath-Cyclopentane Breath-Heptane Breath-llexane Breath-Isooctane Breath- Isopentane Breath-Pentane Breath-Toluene Breath-Naphtha Ureath-Ketormate Dreaih-Alkylate Breath-Cas Oil Hreath-Keaid No. <100,000 bbl Breath-l.l'G Breath-Gasoline > 100,000 bbJ Breath-Crude > 100,000 bbl Brealh-.JP-4 - 100,000 bbl Part 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 S0x 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 NO 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 IIC 84. 20. a. 2. 31. 1. 1. 28. 31. 58. 11. 32. 13. 142- 94. 12. 0 8 2 5 4 6 4 8 0 4 3 1 9 0 9 8 0.06 62.1 15.0 22.6 CO 0 0 0 0 0 0 • 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1000 1000 1000 1000 1000 II II II II II II II II II II II II II II II II II II II II gal. gal. gal . gal. gal. n ii M . M n M n n n 11 n n n n 11 n n n ii n Units Action storage capacity 1 storage capacity 1 throughput 4 throughput 4 storage capacity 1 n n i 1 n n ^ 4 n n * II II £ II II * II II ^ II II i II II A ^ + M II . f + 2 4- M n •> n n •> ii n > ------- RKVISl'l) SCC LISTINGS Fixed Roof (cont. ) Source 4-03-001-26 A-03-001-27 4-03-001-2H 4-03-001-50 4-03-00L-51 4-03-001-52 4-03-001-53 4-03-001-54 4-03-001-55 4-03-001-56 4-03-001-57 4-03-001-58 4-03-001-59 4-03-001-60 4-03-001-61 4-03-001-62 4-03-001-63 4-03-001-64 4-03-001-65 4-03-001-66 4-03-001-67 4-03-001-«J8 4-03-001-99 Breath-Jet Kero > 100,000 bbl Ureath-Dist No. 2 > 100.000 bbl Breath-Resid No. 6 > 100,000 bbl Working-JP-4 Working-Jet Kero Working-lust No-. 2 Working-Benzene Working-Cycloliex Working-Cyclopent Working-Heptane Worklng-llexane Working-lsooctane Work!ng-Isopent WorkIng-Tentane WorkIng-Toluene Working-Naphtha WorkIng-Keformate Work Ing-Alkylate Working-Gas Oil Work ing-lies lil No. 6 Uorking-U'G breath Specify Working Specify Part 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 (, so X 0 0 0 0 0 0 0 0 0 0 0 0 • 0 0 0 0 0 0 0 0 0 ~N--x 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 lie l.l 0.10 0.005 2.5 0.027 0.023 2.2 2.4 6.40 1.20 3.60 1.50 15.7 10.6 0.66 0.0002 CO 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1000 gal. ii n n n 1000 gal. n n ii n n n n n n n n ii ii n ii n n ii n M n n n ii n n n ii n n n n n ii Units Action stotage capacity 3 n n 3 n n 2 throughput 1 11 1 4 4 4 «• * ii * ii A Ii A ii * n A 4 + n _i_ + 11 4 5 II _L. 1000 gal. storage capacity 1000 gal. throughput ------- REVISED SCC LISTINGS Floating Roof 4-03-002-01 4-03-002-02 4-03-002-03 4-03-002-04 4-03-002-05 4-03-002-06 4-03-002-07 4-03-002-08 4-03-002-09 4-03-002-10 4-03-002-11 4-03-002-12 4-03-002-13 4-03-002-14 4-03-002-15 4-03-002-16 4-03-002-17 4-03-002-18 4-03-002-19 4-0 J-002-20 Source Standing STG-Gasoline <100,000 bbl Working-Gasoline <100,000 bbl Standing STG-Crude <100,000 bbl Working-Crude Standing STG-JP-4 <100,000 bbi Standing STG- Jet Kero <100,000 bbl Standing STG-DistNo. 2 <100,000 bbl Standing STG- Benzene Standing STG-Cyclohex Standing STG -Cycl open Standing STG-lleptane Standing STG-llexane Standing STG-Iuooctane Standing STG-lsopentane Standing STG-Pentane Standing STG- Toluene Standing STG-Naphtha Standing STG-Re formate Standing STG-Alkylate Standing STG-Gas Oil Part 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 S0x 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 NO 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 IK: 12.0 0.023 3.65 4.38 0.197 0.179 4.02 4.38 8.76 1.64 4.75 2.01 20.8 13.9 1.75 CO 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Units Act 1000 gal storage capacity 1 1000 gal throughput 1 1000 gal storage capacity 1 1000 gal throughput A 1000 gal storage capacity 1 n M ii n -I ii n n n i n n n n ^ II II M II 1 II II II II A II II II »l £ II II II II £ II II II II £ II II II II £ II II II II £ II II II II / II II II II , 1 II II II II 1 II II II II , ------- sec LISTINGS Floating Roof Cont. Source 4-03-002-21 4-03-002-22 4-03-002-23 4-03-002-24 4-03-002-25 4-03-002-26 4-03-002-27 4-03-002-28 Standing STG-Resld No. 6 <100,000 bbl Standing STG-Gasoline >100,000 bbl o o Working-Gasoline >100,000 bbl 0 Standing STC-Crude >100,000 bbl 0 Standing STG-JP-4 >100.000 bbl 0 Standing STG-Jec Kero >100,000 bbl 0 0 Standing STG-Dlst. No. 2 >100,000 bbl Standing STC-Resld No. 6 >100,000 bbl 0 — X 0 0 0 0 0 0 0 NO - — -x 0 0 0 0 0 0 0 uc 0.007 6.94 0.013 2.08 2.48 0.113 0.102 CO 0 0 0 0 0 0 0 0 0 0.004 Units 1000 gal throughput 1000 gal storage capacity Action 2 3 3 3 3 3 4-03-002-99 Standing STG-Capacity 0 0 0 0 ------- REVISED SCC LISTINGS Continued Variable Vapor Space 4-03-003-02 4-03-003-03 4-03-003-04 4-03-003-05 4-03-003-06 4-03-003-07 4-03-003-08 4-03-003-09 4-03-003-10 4-03-003-11 4-03-003-12 4-03-003-13 4-03-003-1.4 4-03-003-15 Source Working-Gasoline Working-JP-4 Working-Jet Kero Working-Dlst. No. 2 Working-Benzene Worklng-Cyclohex Worklng-Cyclopent Working-Heptane Worklng-Ilexane Working-Isooctane Working-Isopentane Working-Pentune Working-Toluene Working-Res id No. 6 Pare. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 SO X 0 0 0 0 0 0 0 0 0 0 0 0 0 0 N0y 0 0 0 0 0 0 0 0 0 0 0 0 0 0 nc 7.7 2.3 0.025 0.022 2.1 2.3 7.2 1.4 4.0 1.7 17.8 12.0 0.62 0.0002 CO 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Unlit. 1000 gal throughput it it 4 1 1 4 4 4 * * 4 3 4-03-003-99 Working-Specify 0 0 0 0 ------- REVISED SCC LISTINGS Continued Fixed Uool Breathing (Petrochemical ) 4-04-001-04 4-04-001-06 4-04-001-14 4-04-001-15 4-04-001-19 4-04-001-26 4-04-001-28 4-04-001-39 4-04-001-42 Source Breath- Ace tone Breath-Aery lonit rile Breath-Carbon Tetra- chlorlde Breath-Chloroform B reath- 1.2-1) Ichloro- ethane Breath-Ethyl acetate Breuth-Ethylalcohol Breath-Menthyl Alcohol Breath-Methylene Part. 0 0 0 0 0 0 0 0 0 SO X 0 0 0 0 0 0 0 0 0 N0x 0 0 0 0 0 0 0 0 0 uc 43.8 21.9 62.1 76.7 31.8 30.3 10.2 13.1 113 CO 0 0 0 0 0 0 0 0 0 Units Activity 1000 gal storage capacity 5 II II II II C II M II II lj ii ii ii H 5 II M II II 5 II M II M Ij II II II II Ij II II II II C II II II II C 4-04-001-43 4-04-001-44 4-04-001-50 4-04-001-55 4-04-001-56 4-04-001-58 Chloride ilreath-Kethyl lithyl 000 26.6 0 Ketone 3reath-Methyl- 000 13.9 0 methacrylate Breath-Isopropyl- 0 0 0 11.3 0 alcohol Breath-1,1, 1 Trichloro- 0 0 0 62.1 0 ethane Breath-Trichloroethylene 0 0 0 40.2 0 Breath-Vinyl Acetate 000 33.6 0 II II II II II II II II II II II II II 5 5 ------- REVISED SCC LISTINGS Continued Fixed Roof Working (Petrochemical) 4-04-005-04 4-04-005-06 4-04-005-14 4-04-005-15 4-04-005-19 4-04-005-26 4-04-005-28 4-04-005-39 4-04-005-42 4-04-005-43 4-04-005-44 4-04-005-50 4-04-005-55 4-04-005-56 4-04-005-58 Sources Part. Working- Acetone Working- Aery Ion It rile Working-Carbon tetra- chloride Working-Chloroform Working- 1,2-Dichloro- ethane Worklng-Ethlaceiate Uorklng-Ethylalcohol Working- Methylalcohol Working-Methylene Chloride Working-Methyl Ethyl Kutoae Wo r king-Met hylnie Lh- acrylate Worklng-lsopropyl Alcohol Worklng-1, 1 , 1-Tr Ichioro- ethane Workiug-Trlchloroelhy leiu; Working-Vinyl At:etat«i 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 sox 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 NO 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 lie 4.0 1.8 5.2 7.1 2.4 2.3 0.66 1.1 11.0 2.1 0.72 0.72 5.1 2.H 2.7 CO Units 0 1000 gal throughput Q M II II Q II II II Q II II II Q II II ' II Q II II II Q II II II Q II II II Q II II II Q II II II Q II II II Q II II II Q II II II Q II II II Q II II II Activity 5 5 5 5 5 5 5 5 * 5 5 5 5 5 5 5 ------- REVISED SCC LISTINGS Floating Roof (Pet rochemi r.a 4-04-010-04 4-04-010-06 4-04-010-14 4-04-010-15 4-04-010-19 4-04-010-26 4-04-010-28 4-04-010-39 4-04-010-42 4-04-010-43 4-04-010-44 4-04-010-50 4-04-010-55 4-04-010-56 4-04-010-58 Standing 1) Source Stand 1 ng-Acetone Stand ing-Aery lonit rile Standing-Carbon Tetrachloride Stand ing-Chloroform Standlng-1. 2-Uichloroethane Stand ing- Ethy lace t ate Standing-Ethyl Alcohol Standing-Methyl Alcohol Stand Ing-Methylene Chloride Standing-Methyl Ethyl Ketone St and ing-Me thy Imethacry late Standing- Isopropyl Alcohol Stand lng-1 , 1, 1-Trlchloroethane Standlng-Trlchloroethylene Standing-Vinyl Acetate Part 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 S()x 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 NO* 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 lie 6.2 3.1 8.8 11.0 4.4 4.4 1.4 1.9 16.1 3.7 1.9 1.6 8.4 5.5 4.7 CO 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 .Units Action 1000 gal. storage capacity 5 II II II I C II II II II «j II II II II Ij II II II II K II II II II C 5 II II II 1 C II II II II C " ' 5 II II II II C II II II II I. II II II II C II II II II fj II II II II Ij Variable Vapor Space (Petrochemical) 4-04-011-01 Working-Acetone 4-04-011-02 Worklng-Acrylonltrlle 4-04-011-03 Working-Carbon Tetrachloride 4-04-011-04 Working-Chloroform 4-04-011-05 Working-],2-Dtchloroelhane 4-04-011-06 Working-Kthylacetate 4-04-011-07 Working-Ethyl Alcohol 4-04-011-08 Working-Melhyl Alcohol 4-04-011-09 Working-Metl-.vlene Chloride 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 o 0 0 0 0 0 0 0 0 0 3.8 1.7 4.8 6.7 2.2 2.2 0.62 1.0 10.0 0 0 0 0 0 0 0 0 o 1000 gal. n n • n n n n n ,. n n n i n n throughput •i Ml II II II II II II 3 3 3 3 3 3 3 3 'J ------- REVISED SCC LISTINGS FlcaLing Roof Standing Petrochemical (cont.) Source 4-04-011-10 4-04-011-11 4-04-011-12 4-04-011-13 4-04-011-14 4-04-011-15 Working-Methyl Ethyl Ketone Worklng-Methylmethacrylate Working-Isopropyl Alcohol Work ing-1,1,l-Trichlornethane Worklng-Trlchloroethane Working-Vinyl Acetate Part 0 0 0 0 0 0 SO 0 0 0 0 0 0 NO 0 0 0 0 0 0 nc 1.9 0.68 0.68 4.8 2.6 2.5 CO 0 0 0 0 0 0 Units 1000 gal. throughput it n it ii Action 3 3 3 3 3 3 ------- REVISED SCC LISTINGS Tank Cars/Trucks - Load ing Source 4-06-001-01 4-06-001-02 4-06-001-03 4-06-001-04 4-06-001-05 4-06-001-06 4-06-001-25 4-06-001-26 4-06-001-27 4-06-001-28 4-06-001-29 4-06-001-30 4-06-001-50 4-06-001-51 4-06-001-52 4-06-001-53 4-06-001-54 4-06-001-55 4-06-001-75 4-06-001-76 4-06-001-77 Submerged-Normal Gasoline Submerged-Normal Crude Submerged-Normal JP-4 Submerged-Normal Jet Kero Submerged-Normal IHst No. 2 Submerged-Normal Res Id No. 6 Splash-Normal Gasoline Splash-Normal Crude Splash-Normal JP-4 Splash-Normal Jet Kero Splash-Normal 1)1 st No. 2 Splash-Normal Resld No. 6 Submerged-Balance CasolIne Submerged-Da lance Crude Suhmerged-Balance JP-4 Submerged-Balance Jet Kero Submerged Balance Dlst No. 2 Suhmerged-Balance Resld No. 6 Splash-balance Gasoline Splash-Balance Crude Splash-Balance Jl'-4 Part 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 so X 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 NO X 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 HC 5 3 1.5 0.02 0.01 0.0001 12 7 4 0.04 0.03 0.0003 8 5 2.5 0.03 0.02 0.0002 8 5 2.5 CO 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Units Action 1000 gal. transferred 3 II II II '1 II II II 1 II II II "\ II II Ql '1 II II II •! II II II -J II II II •! II II II •> II II II 'J II II II -j II II II •> II II II •> II II II •> II II II -J II II II -J II II II O II II II "J II II II "J II II II 1 II II II . •> ------- UJiVISliO SCC Tank Cars/Trucks - Loading (cont.) Source 4-06-0001-78 4-06-001-79 4-06-00L-BO Splash-Balance Jet Keru Splash-Ualance Dist No. 2 Splash-Balance Uesld No. 6 i'art 0 0 0 sox 0 0 0 NO X 0 0 0 0 0 0 MIL .01 .02 .0002 0 0 0 CO Units Action 0 0 0 1000 gal. n n n n L ransf erred n n j 3 3 4-06-01)1-99 Other-Specify Delete all other 4-06-001 Classifications ------- KEV1SKI) SCC LISTINGS Con tinned Marine Vessels 4-06-002-01 4-06-002-02 4-06-002-03 4-06-002-04 4-06-002-05 4-06-002-06 4-06-002-07 4-06-002-08 4-06-002-09 4-06-002-25 4-06-002-26 4-06-002-27 4-06-002-28 4-06-002-29 4-06-002- 30 Sources Loading Clean Ships-Gasoline Loading Dirty Ships-Gasoline Loading Clean Bargea- Gusol Ine Loading Dirty Hargea- Gaaoline Loading General-Crude Loading General-JP-4 Loading General-Jet Kero Loading General-Dial. No. 2 Loading General-Resld No. 6 Tranalt Gasoline Transit Crude Transit- JP-4 Transit-Jet Kero Transit-Diet. No. 2 Trans It-Reaid No. 6 Part. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 so - x 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 NO 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 (1C 1.3 2.5 1.2 •J.8 1.0 0.5 0.02 0.005 0.00004 3 1 0.7 0.02 0.005 0.00003 CO Units 0 1000 gal tranaferred 0 " " " /> it it ii /» II II II Q II M II ,< II II II n II II II Q II II II 0 " " Q II II II r\ II II II Q II II II 0 " " " l\ II II II /\ II II II Act 1 vi ty 3 3 3 3 3 3 3 3 3 3 3 3 J 3 3 4-06-002-99 Other Spucity 0 0 0 1000 gal transferred Delete all other 4-06-002 ------- RliVlSEI) SCC LISTINGS Continued Underground Gasoline Storage /I-06-003-01 4-06-005-02 4-06-003-03 4-06-003-04 4-06-003-05 4-06-003-99 Fill Velilcle Gas Tank 4-06-004-01 4-06-004-02 4-06-004-99 Source Splash Loading Sub Load-Uncont. Sub Load-Opn Sys. Sub Load-Cls Sys. Unloading Specify Vapor Dlsp. Loss Lie]. Spill Loss Other Speclty Part. S0v N0v 11C " " "" ~ J\ ^^ *\ No Change 0 0 0 0 0 0 0 0 0 9.0 0.7 CO 0 0 0 Units 1000 gallons pumped Activity ------- |