DRAFT
GUIDANCE ON THE
•
IMPLEMENTATION
OF AN
EMISSION STATEMENT PROGRAM
-------
DRAFT
GUIDANCE ON THE
IMPLEMENTATION
OF AN
EMISSION STATEMENT PROGRAM
Office Of Air Quality Planning And Standards
Office Of Air And Radiation
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
July 1992
-------
DRAFT
GUIDANCE ON THE
IMPLEMENTATION
OF AN
EMISSION STATEMENT PROGRAM
Office Of Air Quality Planning And Standards
Office Of Air And Radiation
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
July 1992
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CONTENTS
Page
ACKNOWLEDGEMENTS vii
ABBREVIATIONS xi
DEFINITIONS xiii
EXECUTIVE SUMMARY 1
1 .0 INTRODUCTION 5
1 .1 Purpose 5
1.2 Background 5
1 .3 Structure 9
2.0 GENERAL PROVISIONS 11
2.1 Waiver of Requirements 11
2.2 Optional Emission Statement Submittals ....... 12
2.2.1 State Implementation Plan Revision 12
2.2.2 Data and Status Report Submittal Dates .... 13
2.2.3 Optional Data Elements 14
2.2.4 Data Elements Overview 14
2.2.5 Outline of Recommended Source
and State Submittals 16
2.2.6 Source Supplied Data 17
2.2.7 State Supplied Data 19
2.2.8 Source and State Supplied Data
Elements by Plant, Point and Segment Level . 20
2.2.9 Suggested Optional Data 21
2.3 State Submittals to EPA 23
2.3.1 AIRS Data Submittal 23
2.3.2 Emission Statement Status Report . 23
2.4 Additional State Data Responsibilities 25
2.4.1 Data Consistency 26
2.4.2 Data Confidentiality 27
2.4.3 Data Flow . 29
3.0 EMISSION STATEMENT REPORTING ' . 31
3.1 Development of Reporting Format 32
3.2 Traditional Sources . 32
3.2.1 AFP644 Report . . • 34
3.3 Nontraditional Sources 35
3.3.1 Emission Statement Initial Reporting Form . . 37
4.0 DRAFT STATE REGULATION 39
§XX.010 Applicability '. . 39
§XX.020 Preamble 40
§XX.030 Definitions . 40
§XX.040 Compliance Schedule 43
§XX.050 Requirements 43
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CONTENTS (CONTINUED)
Page
5.0 POSSIBLE ACTIONS FOR NONCOMPLIANCE ..... 47
6.0 PROPOSED USES FOR EMISSION STATEMENT DATA 49
6.1 Base Year SIP Emission Inventory 49
6.2 RFP Tracking 49
6.3 Periodic SIP Inventories 50
6.4 AIRS Facility Subsystem (AFS) and Annual Point
Source Reporting 51
6.5 Permit Program 52
6.6 National Emission Trends 52
6.7 Compliance Certifications 53
6.8 Progress Toward Attainment ... 55
6.9 Rule Effectiveness 55
7.0 FUTURE OF EMISSION STATEMENT REPORTING 57
8.0 REFERENCES 59
APPENDIX A:
Locating Sources A-1
APPENDIX B:
Example Certification of Data Accuracy B-1
APPENDIX C: . ..
RE Percent Method Codes C-1
APPENDIX D:
Estimating Emissions . D-1
APPENDIX E:
Excerpt from the AIRS SCC and Emission Factor Listing .... E-1
APPENDIX F:
Example Emission Statement Status Report . . F-1
APPENDIX G:
Emission Statement Reporting Package for Traditional-Sources G-1
Part 1: Example Letter to Traditional Sources G-2
Part 2: Example AFP644 Report G-5
Part 3: Example Instructions G-14
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CONTENTS (CONTINUED)
APPENDIX H:
Emission Statement Reporting Package for Nontraditional Sources H-1
Part 1: Example Letter to Nontraditional Sources .... H-2
Part 3: Example Initial Reporting Form H-5
Part 2: Example Instructions H-10
APPENDIX I:
EPA Facility ID Code 1-1
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ACKNOWLEDGEMENTS
This report was prepared by Stephanie M. Stich, Kirstin Brust,
and Rebecca Battye of E.H. Pechan and Associates, Inc. of Durham,
North Carolina. The work was conducted under EPA Contract No.
68-D9-0168 for EPA Project Officer Mary Ann Warner-Selph at
(919) 541-1192.
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viii
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ABBREVIATIONS
AFP644 Report
AFS
AIRS
CAA
CAAA
CFR
CHIEF
D&B
EM/CC
EPA
FACTS
FINDS
FIPS
GPS
I/M
NAAQS
AIRS AFS Plant Emissions Inventory Report
AIRS Facility Subsystem
Aerometric Information Retrieval System
Clean Air Act
1990 Clean Air Act Amendments
Code of Federal Regulations
Clearinghouse for Inventories and Emission
Factors
Dun and Bradstreet
Enhanced Monitoring/Compliance Certification
U.S. Environmental Protection Agency
Facility and Company Tracking System
Facility Index System
Federal Information Processing Standards
Global Positioning System
Inspection and Maintenance
National Ambient Air Quality Standards
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NAPAP National Acid Precipitation Assessment
Program
NO Nitric oxide
NOX Nitrogen oxides
NO2 Nitrogen dioxide
NSPS New Source Performance Standard
NSR New Source Review
OAQPS Office of Air Quality Planning and Standards
OIRM Office of Information Resources Management
OMB Office of Management, and Budget
ppm Parts per million
psi(a) Pounds per square inch (actual)
QA Quality Assurance
RACT Reasonably Available Control Technology
•
RE Rule Effectiveness
RFP Reasonable Further Progress
SAMS SIP Air Pollutant Inventory Management
Subsystem
SCC Source Classification Code
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SIC Standard Industrial Classification
SIP State Implementation Plan
tpy Tons per year
VOC Volatile Organic Compounds
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DEFINITIONS
Actual emissions: The actual rate of emissions of a pollutant
from an emissions unit for the calendar year or seasonal period.
Actual emission estimates must include upsets, downtime and
fugitive emissions, and must follow an "emission estimation
method."
AIRS code: The 9 digit source identification code used by the
Aerometric Information Retrieval System (AIRS). The code is
determined as follows: the first two digits are the State
Federal Information Processing Standards (FTPS) code, the next
three are the FIPS county code, and the last 4 digits are a
unique identifier for the emissions .facilities in AIRS/AFS.
Annual process rate: The actual or estimated annual fuel,
process, or solid waste operating rate. The AIRS facility
subsystem source classification code table prescribes the units
to be used with each source classification code.
Certifying individual: The individual responsible for the
completion and certification of the emission statement (i.e.,
officer of the company) and who will take legal responsibility
for the emission statement's accuracy.
Control efficiency: The actual total control efficiency achieved
by the control device(s). The actual efficiency should reflect
control equipment downtime and maintenance degradation. If the
actual control efficiency is unavailable, the design efficiency
or the control efficiency limit imposed by a permit should be
used.
Control equipment identification code: The AIRS/AFS code which
defines the equipment (such as an incinerator or carbon adsorber)
used to reduce, by destruction or removal, the amount of air
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pollutant(s) in an air stream prior to discharge to the ambient
air.
Emission factor: An estimate of the rate at which a pollutant is
released to the atmosphere as the result of some activity,
divided by the rate of that activity (e.g. production rate or
throughput).
Estimated emissions method code: A one-position AIRS/AFS code
which identifies the estimation technique used 'in the calculation
of estimated emissions.
EPA Facility ID code: The Facility Index System (FINDS) facility
identification code, also known as the EPA facility
identification number. A number assigned by EPA to link source
information between EPA databases.
Fugitive emission: Releases to the air that are not emitted
through stacks, vents, ducts, pipes, or any other confined air
stream, including fugitive equipment leaks, evaporative losses
from surface impoundments, and releases from building ventilation
systems.
Material balance: Technique used to estimate emissions from a
source by accounting for the weights of one or more substances in
all incoming and outgoing process streams.
Nontraditional sources: Those sources that have not previously
reported emissions (e.g., sources emitting 25 to 100 tpy of NOX
and new VOC or NOX sources) .
Oxides of nitrogen: (or NOX) In air pollution usage, this
comprises nitric oxide (NO) and nitrogen dioxide (NO2) , expressed
as molecular weight of N02.
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Peak ozone season: That contiguous 3 month period of the year
during which the highest ozone exceedance days have occured over
a period covering the last 3 to 4 years. Most ozone
nonattainment areas have a peak ozone season lasting from June
through August. The period used for the 1990 base year ozone SIP
inventory should be used for subsequent emission statements.
Percentage annual throughput: The weighted percent of yearly
activity for the following periods:
1) December-February
2) March-May
3 3 June-Augus t
4) September-November
The first season (December-February) will encompass 2 ..calendar
years (e.g., Dec '92 - Feb '93).
Plant: The total facilities available for production or service.
Plant level information (e.g., address, latitude/longitude, SIC
code) is a required component of emission statement reporting.
Point: A physical emission point or process within a plant that
results in pollutant emissions. A unique identifier (point
identification number) exists for each point within each facility
in the AIRS database.
Potential to emit: The capability of a source to emit a
pollutant at maximum design capacity, except as constrained by
federally-enforceable permit conditions which include the effect
of installed air pollution control equipment, restrictions on the
hours of operation, and the type or amount of material combusted,
stored, or processed.
Process rate (identified as fuel process rate on the AIRS AFP644
report): Quantity per unit time of any raw material or process
intermediate consumed, or product generated through the use of
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any equipment, source operation, or process. For a stationary
internal combustion unit or any other fuel burning equipment,
this term means the quantity of fuel burned per unit time.
Rule effectiveness: A measure of the ability of the regulatory
program, to achieve all the emissions reductions that could be
achieved by full compliance with the applicable regulations at
all sources at all times. It reflects the assumption that
regulations typically are not 100 percent effective due to
limitations of control techniques or shortcomings in the
enforcement process. EPA allows the use of an 80 percent default
value, but gives States the option to derive local, category-
specific RE factors.
SCC: Source Classification Code. An eight-position code which
provides a detailed analysis of a process creating emissions at a
point. A listing of SCCs can be found in the EPA document AIRS
Facility Subsystem Source Classification Codes and Emission
Factor Listing for Criteria Air Pollutants.
Segment: Components of an emissions point or process, at the
level that emissions are calculated. One example of a segment is
a boiler burning #2 oil. A unique identifier (segment
identification number) exists for each segment within each point
and plant in the AIRS database. Each segment is also identified
by a SCC.
SIC code: Standard Industrial Classification code. A series of
codes devised by the Office of Management and Budget
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Stack: A (smoke) stack or vent within a plant where emissions
are introduced into the atmosphere. A unique identifier exists
for each stack, within each facility in the AIRS database.
Stationary Source: Any building, structure, facility, or
installation which emits, or may emit, any air pollutant subject
to regulation under the Act.
Traditional sources: Those sources that have traditionally
reported their emissions. Generally, larger sources that have
previously been required to submit emission information.
Transport region: A region covering multiple States which may be
established by the Administrator whenever interstate transport of
pollutants contributes significantly to the violation of NAAQS.
Typical ozone season day: A day typical of that period of the
year during the peak ozone season.
Volatile organic compounds (VOC): Any compound of carbon,
excluding carbon monoxide, carbon dioxide, carbonic acid,
metallic carbides or carbonates, and ammonium carbonate, which
participates in atmospheric photochemical reactions. This
includes any such organic compound other than the following,
which have been determined to have negligible photochemical
reactivity: methane; ethane; methylene chloride
(dichloromethane); 1,1,1-trichloroethane (methyl chloroform);
1,1,1-trichloro-2,2,2-trifluoroethane (CFC-113);
trichlorofluoromethane (CFC-11); dichlorodifluoromethane (CFC-
12); chlorodifluoromethane (CFC-22); trifluoromethane (FC-23);
1,2-dichloro 1,1,2,2-tetrafluoroethane (CFC 114);
chloropentafluoroethane (CFC-115); 1,1,1-trifluoro 2,2-
dichloroethane (HCFC-123); 1,1,1,2-tetrafluoroethane (HFC-134a);
1,1-dichloro 1-fluoroethane (HCFC-141b); 1-chloro 1,1-
difluoroethane (HCFC-142b); 2-chloro-1,1,1,2-tetrafluoroethane
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(HCFC-124); pentafluoroethane (HFC-125); 1,1,2,2,-
tetrafluoroethane (HFC-134); 1,1,1-trifluoroethane (HFC-143a);
1,1-difluoroethane (HFC-152a); and perfluorocarbon compounds
which fall into these classes - (1) cyclic, branched, or linear,
completely fluorinated alJcanes, (2) cyclic, branched, or linear,
completely fluorinated ethers with no unsaturations, (3) cyclic,
branched, or linear, completely fluorinated tertiary amines with
no unsaturations, and (4) sulfur containing perfluorocarbons with
no unsaturations and with sulfur bonds only to carbon and
fluorine.
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EXECUTIVE SUMMARY
The 1990 Clean Air Act Amendments (CAAA) require increased
reporting and tracking of emissions. The emission statement
requirements have been developed to be consistent with several
other reporting requirements. Thus, emission statement data will
provide information useful for the development, quality
assurance, and completeness of several emission reporting
requirements, including: tracking of reasonable further progress
(RFP), periodic State Implementation Plan (SIP) inventories,
annual Aerometric Information Retrieval System (AIRS) Facility
Subsystem (AFS) submittals, the operating permit program (Title
V), emission trends, and compliance certifications. The future
of emission statement reporting includes the ultimate goal of
consolidating these reporting requirements into one annual
effort.
This document contains technical guidance for the
development and implementation of an emission statement program.
It is not meant to be interpreted as requiring or mandating any
of the provisions discussed. Its purpose is to provide an
interpretation of the 1990 Clean Air Act Amendment requirement
for emission statements by addressing which sources are subject
to emission statements, what constitutes an emission statement,
what should be submitted, and suggested dates for these
submittals. EPA plans to revise the Code of Federal Regulations
to incorporate emission statements. The process will include an
opportunity for full public notice and comment on the provisions.
Such a revision will allow EPA to require the submittal of
appropriate emission statement data and status reports.
The basic requirements of the CAAA, Section 182(a)(3)(B) are
reviewed in this document. Section 182(a){3}(B) requires that:
States with areas designated as nonattainment for ozone require
emission statement data from sources of volatile organic
1
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This ^«qu
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.
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Based upon sections 184(b)(2) and 182(f) of the CAAA, the
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st^temeitt requirement: -also Ap^li'6^ -to st-atrionaccy ,sOttrces
/ J\ *. ff , vj, j f f-f'S J fff ••' ^* ff •. v fff ff J s.:^ ~* f ff.f-.fA^jff /> •. ^v fff ••-"* /
hiclt' ^mi^r 'ca&rhave '•Eh&'pbteatia!/' 'tdlei'Ifcr""SO"'"'t'Ei'y ' or more of VQC,
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transport -i^gipng^ f- A' revision, ot- ?'the/iSEtat«>5: 0$3^ r!equiring
v, •• 7 IF ^ f ffrfrr ffftt IT fffr v vE. J % ffffds -A. •,vs\ : ffffr Jff : f* Jffff r f ff. £•. fff v vt.tfi ^^^ ^ ^^ ^.*T *ff T
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entis:sionL statement s^snouXa. faer,subnKLt,tea'>wathins;2 x^ars, of ,the
f f •, ff f. ff : f f f f : ^** f ' f f
&fceiit- of s'
••••
IfeeTStates may waived witji "SPA - approval,! "the- requirement for
f •. '"•s i- •. •. ^ •ff'\ \ f f' : v TAVv^ ^^^. \-. ^W ./ * ^^r ss. s ^ -"P /
fsS'ioil^ statements "' for ^classes or-- <^tegori'esv&f ; ^ sources '- with
- fchaua^S' toas^per "year "'of- actual jglaiifc-wijcJfe- JSfO* or\VOC
^^ /•. v f •. v ^fc' r * v s ^ i. A- •. **• A j- % -k-u s -u ^^ •••• •**• f
ryn5m|^ if the class or category is
included in the base year and periodic inventories and emissions
are calculated using emission factors established by EPA (such as
those found in EPA publication AP-421) or other methods
acceptable to EPA.
The CSAA^ require-'facilities, to subinit the'first emission
< f —' fff V. •. "" f V. f f f -, •. f
statement to the State5 within, three years;,«%er the ^date o£ the
enactment" p£^the' C&AAr and aimiialix;''thereafter". "EP&^is'strongly
recommending" that. States- require, a "sttbraittal date jod: April 15 to
allow use of the emission statement data in the preparation of
the annual point source data submittal to EPA under 40 CFR
51 .323. - Tfee 'first emission statement, which is,,dug||ii|?f^§pps
beA'basedi? bWfemissions in 1992.
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:
t^bn^of data /accuracy/"" sou^ee-'Tdeixifif i&atibn-
WV ^ ' * " f J
1iiqn;;7raild;"proC^^ The individual data
elements are described in detail in sections 2.2.6 and 2.2.7 of
this document. The emission statement data elements were
developed to be consistent with other source and State reporting
requirements. This consistency is essential to assist States
with quality assurance for emission estimates and to facilitate
consolidation of all EPA reporting requirements.
In. Jidcpt tiort to^the ^eraissipn'^statemsrft. siibmxttal^ States
|rwtde"^o^P^ the" degree, of
compliance with/ the 'emission,' statement ^ograi&V^ Beginning 'July
1>'l993r States - snouid/reporV quarterly to EPA5 t3ie total., number
'• ' *• ffff : : s •. *» ^ •• ffff --F* JJ f f ff f w ^^ ^ ^ ^ fjf f jf ff : t f
of- sources affected by, tile emission statem'erit?prbvisibns/,v"the
.• S. ^Jl ^ ff J i-,41- ^W ^ f f ff •. W. •* f ff /•!• •.-. '- ffff JJV.V..', f fff f V AW^C V ffff f •. V,*. * f ff"~ •.
niintb'er ffiat "Have^coriSlied^ith'^t-he 'ei&'is'sibiu statement provisions
^ ^ ^ f : : ::: ff frr :ft , *> f r f f -S.:-. , ff :f.: , ff ff fj-j <-<, f rrrr : \f f f *• ff"r v
an£rtfte"{iyambe.r " tlaat %ave; iibjf/ \ '^hisrstaC^frepbr t^shb)d'Xd>also
include the- total annual; and topical, ozone, \seasoit' day 'emissions
j f -V.S v vf : : jfJtfff. : -. fff. •-: : f f ff! fff fff fj^1 f+J. f JJjjf Vf^ffff w f f +.fjf/f,s fffff^-. f,ff* •. •. ^'.sffffff •. f
from.' al^vreportin^: sb^'cesT/y'both.'Jcorrected jjn& ribn-cbfrUcted for
ruie^-effebtlveness' (RB}/» States,, should include ia; tKeir-'status
report a 'list:of sources- that" are^eliiiguent "ih 'submitting their
emission statements and that emit:/ 500 Jtpy or more o£ VOC or 2500
tpy~ or raore of NOX. This report should' be a' quarterly submit tal
taitil'/all the ' regulated" sources .have complied "for the reporting
year- Suggested submittal^dates- for -the quarterly sjtatus reports
are Jul'y.f, October Jr January 1 ,, and.t April ;1'r
States should maintain adequate records of emission
statement data and source certifications of emissions submitted
to them by sources for a period of at least three years to allow
for review or verification of the information as needed.
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States are responsible for reviewing the consistency of the
emission statement data with other available data sources and for
resolving any inconsistencies with the facility. Once ah
efdssiqn. estimate is agreed upon, 'the *$!&££} should eater the
emission statement data into ATS by July 1 of/ each year,
begijOJiing ih. 1993* States should coordinate this activity with
other reporting requirements to avoid deleting valuable ' data in
the AIRS database.
eC eMWioti statement" iireportirig'foEmat^d^scra.bed in this
'w j-t r v. f •.£•. •. f ^ j f. •. w -. f ** : :: ** rr r r. ft.-.-. i. A-.SV f -. :* s Jfr -.^ f'f .,
provides ;fpr\twcs' data "collectibH mechanisms-- States
should send traditional sources, that is, those with emission
data already in the AIRS database, the source's AIRS AFP644
report for review and/or correction. Nontraditional sources,
those who do not have emission data on file with the EPA, should
be sent an Emission Statement Initial Reporting Form. In both
cases, the reporting form or report should be accompanied by an
explanatory letter and detailed instructions. States have the
optloi3clofr<3e.vel6pirfgrthelr own emission ~sfeatemerit reporting
forntat. „ if States^ develop art alternativeTrel^rtfng mechanism,,
care should be" taken, to ensure" €hat thVmlttiiium;eiK£ssiori
•*• "• Vf ff. •. ff : v v
statement data elements are requested Cartel "that t£e^ emission
statement data are provided Co the &PS via the A$RS ' system-
The "provisions ^outlineci in -thiV>eport are jaot; mandated at
time. ' A revision^ of , the CFRr\addres$ihg' B'oth; data and
status "report1 subntittais^ is anticipated' to 'occur /la order to
reflect ;the/:rec;Uir;eraents ^of;'fhe ^emission, ^stateineat progranti EPA
is anticipating pursuing the ruleraaking process to require
submit tal of the emission statement data. This process will
occur after an opportunity for full public notice and comment is
provided.
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1.0 INTRODUCTION
1.1 Purpose
The purpose of this document is to provide guidance to State
agencies for the development of their emission statement
programs. In addition, this guidance meets the requirements of
section 182(a)(3)(B) of the CAAA by prescribing a form for the
submission of annual emission statements.
The EPA is working to coordinate the emissions reported for
several programs. Part of this effort involves maintaining
consistency in the emission data reported for emission
statements, the annual point source submittal, and the SIP ozone
emission inventory. To achieve this goal, the VOC and NOX
emissions values obtained under the emission statement program
should be used in the annual point source submittal and in the
SIP ozone emission inventory.
1.2 Background
On November 15, 1990, amendments to the Clean Air Act (CAA),
were enacted. Title I of the CAAA requires, among other things,
that States with areas designated nonattainment of the ozone
National Ambient Air Quality Standards (NAAQS) establish
regulations for annual reporting of actual emissions by sources
that emit VOC or NOK in the nonattainment areas. Based upon
sections 184(b)(2) and 182(f) of the CAAA, emission statements
are also required from sources in attainment areas within ozone
transport regions which emit, or have the potential to emit, 50
tpy or more of VOC, or 100 tpy or more of NOX.
Emission statements are intended to assist the State
agencies in their reporting and analysis of emission estimates.
The emission estimates reported on emission statements will be
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useful in the annual tracking of emission reductions. This
tracking will help to monitor the progress that areas make
towards attainment of the ozone NAAQS.
Section 182(a)(3)(B) of the CAAA, which contains the
requirements for emission statements, reads as follows:
Emission statements. - "(i) Within 2 years after the
date of the enactment of the Clean Air Act Amendments
of 1990, the State shall submit a revision to the State
implementation plan to require that the owner or
operator of each stationary source of oxides of
nitrogen or volatile organic compounds provide the
State with a statement, in such form as the
Administrator may prescribe (or accept an equivalent
alternative developed by the State}/ for classes or
categories of sources, showing the actual emissions of
oxides of nitrogen and volatile organic compounds from
that source* The first such statement shall be
submitted within 3 years after the date of the
enactment of the Clean Air Act Amendments of 1990.
Subsequent statements shall be submitted at least every
year thereafter. The statement shall contain a
certification that the information contained in the
statement is accurate to the best knowledge of the
individual certifying the statement.
(ii) The State may waive the application of clause
to any class or category of stationary sources which emit
less than 25 tons per year of volatile organic compounds or
oxides of nitrogen if the State, in its submissions' under
subparagraphs (1) or (3) (A), provides an inventory of
emissions from such class or category of sources, based on
the use of the emission factors established by the
Administrator or other methods acceptable to the
Administrator.tl2
Section 184(b)(2) of the CAAA states that stationary sources
which emit, or have "the potential to emit, 50 tpy or more of VOC
in ozone transport regions are considered major sources. These
sources are subject to all regulations which apply to major
stationary sources within moderate nonattairmen't areas. The
emission statement requirement applies to sources in marginal and
above ozone nonattainment areas and therefore also applies to
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these sources of VOC in ozone transport regions. Section
184(b)(2) of the CAAA reads as follows:
"...For the purposes of [control of interstate ozone
air pollutionj any stationary source that emits or has
the potential to emit at 1 east 50 tons per year of
volatile organic compounds shall be considered a major
stationary source and subject to the requirements which
would be applicable to major stationary sources if the
area were classified as a Moderate nonattainment
area.'*
Section 182(f) extends the requirements for major sources of
VOC in ozone transport regions to major sources of NOX. Section
182(f) reads as follows:
"The plan provisions reguired under [subpart 2] for major
stationary sources of volatile organic compounds shall also
apply to major stationary sources fas defined in section
302—) of oxides of nitrogen'1*
Section 302(j) defines a major stationary source of oxides
of nitrogen as:
"any stationary facility or source of air pollutants which
directly emits, or has the potential to emit one hundred
tons per year or more of any air pollutant"5
Therefore, the emission statement requirement is extended to
include sources in attainment areas within ozone transport
regions which emit, or have the potential to emit 100 tpy or more
of NOX or 50 tpy or more of VOC.
Additionally, if a source emits at least the minimum
established reporting Level of VOC or NO,, {for example, 25 tpy or
more in an ozone nonattainment area), and the other pollutant is
emitted at less than 25 tpy, then the other pollutant should also
be included in the emission statement. Likewise, for sources in
attainment areas of ozone transport regions, if a source emits at
least the minimum established reporting level of VOC or NOX (for
example, 50 tpy of VOC or 100 tpy of NOX) , then the other
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pollutant should be included even if it is emitted at levels
below the specified cutoffs. This provision is consistent with
that for SIP emission inventories.
The emission statement provisions 6&3JL. for emission,
estimates frost sotree- sourcesv tH&t are v.v.y^.v-::-.--.-":.:.'v..'..v.-.',;.v.-.-.-.-.-1:.-.;'x-<••••-•.-.-.•. .•.v-i---i;---•.
^|^|»:fiiti^lllKli^
^^§^|y;;;^e^-;;|^c|§^^ifflS|^
•:•:»•:.::—-:•:•••:•:-•»---» •:•:•:•:;::
Jftlv c - -'": trtyn:"?: 'f* ft
^^^^Bir^^^i1!^^!^^
:,...:;-fff- ••-.::•:<'.-. ....:•» •:•••: K«C, .. K-»^-" •-•.•.•.•:•:•:: ...••.-.-> V- ••.•.-.•;•.:: ...•.••.--.. .v,-.->^—• fcl-.-.v.v7.'K.^. .-.•.•.-.-.-fr .•.•.:::v. —-.*,.. ttfttfr*/' ;:• ••]•&?&.„
:^^^^
tpy voc.)
A revision of- the CFlC: addressiiicf 'bbfch^data-. and status
report; siibmittals-v is anticipated. to • occur in. order to reflect
the requirements of-'the emission/statement program,. EPA is
anticipating pursuing the ruleiuaking process to require submittal
of the emission statement data. States should therefore consider
-------
setting up their emission statement programs to require that this
information be submitted.
1.3 Structure
This guidance document is structured as follows. The
general provisions are presented in the next section. Emission
statement reporting is discussed in section 3.0, and includes a
suggested reporting format. A draft State regulation is
presented in section 4.0. Possible actions for noncompliance
with the emission statement provisions are discussed in section
5.0. A discussion of the possible uses for emission statement
data is provided in section 6.0, and the future of emission
statement reporting is examined in section 7.0.
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10
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2.0
GENERAL PROVISIONS
This section discusses the conditions under which the
emission statement requirements may be waived, details the
recommended emission statement data, describes requested State
submittals, and reviews other State data responsibilities.
2.1 Waiver of Requirements
.:K-K-K:MK-; ' "-:••••:•::::::.••:••::::•—:•::::S-K; ••«::-:•: ••:«K:::::•• ii;:::>>:-• «:•:•:•':::-:::•::•:"HK•::*• K-K-»S'- :::>"-->>w-:::::'-::''-'-:-:->>*-J'-'-••••:••
3ii^£3£$o&£^£n$^^
v:-:v:->KvMctM^::^:X'K".-Xvrt-rr-..v.v.-:«K«:.:.:x-.:v.->.-rt-••/•:•• ^.•x-iKi-.jj.-XvXvX-fj—w..-.-.-.-:c.X'«v:c<.;:..x-:rf.-»^r- ••:-.•:•:•:•:•»:«:•:•:•;-:•:•
States
should get clearance from the appropriate EPA Regional Office to
waive the emission statement requirement for these smaller
sources.
* though sources;"emi€£irig^}beI6w' 25 '-Spy plant-wide of VOC
-;Npx can be exempted front "eialssipn statemeTit',req^tiremeiit.s^ it
may- not be advantageous for-States; to do- so. These smaller
sources can produce a significant amount of emissions,
particularly in urban areas. In addition, larger sources have
already been controlled to a great extent and the next logical
sources to regulate and/or monitor are these smaller sources.
Also, for the base year and other required inventories, VOC point
sources emitting 10 tpy or greater emissions in nonattainment
areas must be inventoried. States may want to set the emission
statement threshold at least this low to allow use of emission
statement data in preparing emission inventories.
For assistance in locating sources who have not previously
submitted emissions data to AIRS, see Appendix A.
11
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2.2 Optional Emission Statement Submittalg
The following section describes the source and State
supplied information that EPA is requesting to be submitted as
part of the emission statement program, and details the proposed
data elements. Submittal due dates are presented, and a list of
suggested optional data elements is provided.
2.2.1 State Implementation Plan Revision
&&<
lHIrP*!^^
tsfel^SEK^^isssSr &]&!8f-vir$zP-3??:: 5KPJ^S*sST?*^^"R$n?: -£ "?r
l|iiPl^^fiKpf||^lS;l^ The revised SIP should require the
submission of annual emission statements from owners or operators
of these applicable stationary sources of NOX or VOC.
Emission statement SIP revisions will be subject to a "Table
2 " level of review in which EPA headquarters (OAQPS) will be
allowed a 30 day period in which to review the SIP revision and
provide comments. Final approval authority, however, will reside
with the Regional Administrator. A notice in the 54 FR 2214-2225
January 19, 1989 Federal Register initially defined a system for
SIP decision authority by establishing three categories of SIP
revisions (Tables 1, 2 and 3). Under the Table 2 level of review
for SIP actions is listed, "Any other action not listed
elsewhere." The emission statement SIP revision would fall in
this category because it does not appear in Table 1 or Table 3.
12
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2.2.2 Data and Status Report Submittal Dates
The annual emission statements should include the estimated
actual annual and typical ozone season day emissions of NOX
and/or VOC, by segment within the facility. The CAAA specify
that the first statements are due from the facility to the State
(or appropriate local agency) no later than three years after
enactment of the CAAA, and must represent emissions during
calendar year 1992. lE order to provide time, for, the States to
incorporate ttielr emission 'statement',, data into t&e "annual' ppint
source ,sttbmittal,, (whlcX is &?& each.,year f on eruly\1), 'it is
recommended' that' the , due * date /for" this, first emission statements
be',,April'', 1;5/v',19$3,: The emission statement data can be used by
the States to prepare the required annual point source submittal.
The emission statement program establishes a data collection
procedure and provides segment level emission data to assist in
the development of estimations. In order to facilitate the
ultimate goal of synchronizing all industry reporting
requirements, coordination between emission statement and other
reporting requirements, such as the annual statewide point source
submittal, and the periodic nonattainment inventory submittal, is
strongly recommended.
In addition to the submittal of emission, statements and
emission, statement data, EPA, is ^requesting that States provide an
Emission Statement Status Report (see section2,3',,2Kand 'provide
emission,,statement-,data to, the EPA.,,by July XT/J993 for*the first
emission statement'(to coordinate with the'annual point source
subiaifctal) ." Thereafter, emission, statement's-should be submitted
annually, but the status- report should be submitted to EPA'' on a
quarterly basis until all applicable sources have reported* It
would therefore benefit the States to request an April 15-
submittal of data from the sources, to be .able to meet, the •July. 1.
datevi """""
13
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2.2.3 Optional Data Elements
Furthermore, States may want to request sources with
emissions of SO2 over 100 tpy, CO over 1000 tpy, or lead over 5
tpy to also report under the emission statement provisions. This
emissions data could then be used by States to prepare their
annual AFS submittal to EPA. By gathering these data under the
emission statement program, States would eliminate the use of two
different reporting mechanisms for their annual AFS submittal.
2.2.4 Data Elements Overview
Sources are requested to submit specific data elements to
the State (or appropriate local agency) in order to comply with
emission statement reporting. The data elements are, to the best
extent possible, consistent with other EPA reporting requirements
and with EPA data systems.
Under the State-wide point source reporting requirements
program and currently as part of the SIP emission inventory
requirements, data elements that describe source identification,
operating schedule, emissions information, control equipment, and
process data are required to be submitted to EPA and are included
in the AIRS database.
•••.v... .-i-.;.;.;; • j •••:•••'•" "•'•':•:•:•:•*-• -•••••.•.•..••••••:•'•'•:•::"• • •• .•-•..,•..,-.• •••.- •—•:••••--•—•-'.•...-
^s3^^^aec^iK^y^.t^e3^sy^
;iHIs|§^||^^
..............
" almaally ' , .
By compiling the emission statement data, facilities and
States should be better prepared to meet subsequent reporting
14
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requirements and to provide better quality assurance of emission
estimates. In addition, the EPA will be better suited to work
towards the ultimate goal of compiling all emission reporting
requirements into a single annual effort.
Bach efe!ssloiTs-€a€emer?t shotild con-tain\, afc aTmiiiimuifc, the
> v. v. -\ C > .•. Crf-, f.v : f, f.
£pXlo**in£r informatibn; ^ certification, "of data a&curacsy, source
identification information, operating- 'schedule, process data,
control equxpment t aaicii' emissions informations " The purpose of
requesting- the-emission"statement data is for verification of the
j, •* •» f 1 'f •••:•'.
fission estimates by the _$tate or Regional Office," ^ sitnple
e^i;iiaa.te o£ eiaissiotis provided fay the source without
documeafcation would preclude verification "of the estimate if it
is-ijx cojoflict- with the State's or EP^'a emission estimate*" For
complete emission statement reporting, data is requested from
both sources and States. These suggested data elements are
discussed in detail in sections 2.2.6 and 2.2.7.
The AIRS system"has been modified to compute rule
effectiveness adjusted emissions at the SCC pollutant (segment)
level. Therefore, States may use this feature to calculate RE
emissions. However, States should ensure that adequate RE
information is provided to AIRS so that an accurate adjustment
can be made. The necessary data elements to compute RE adjusted
emissions are listed as requested emission statement data.
At present, EPA is making changes in the application of RE
and in the input of RE data into AIRS that could affect emission
statement reporting. Any changes in RE that apply to emission
statements will be addressed in a later guidance.
15
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2.2.5 Outline of Recommended Source and State Submittals
& summary of recommended submittalsT b# Isoorxje^ and States-
i«ar' the emission statement program is prov£de^ 'below, " The
pdl-vidual ' items on the lists" are ^described ia detail ila this
Shatter ,^
EPA requests Sources to provide the following:
• Identification of plant
• Operating information
• Process rate data
• Control equipment information
• Emissions estimates
• Certification of data accuracy
EPA requests States to provide the following:
• SIP revision by November 15, 1992
* Identification codes (AIRS, point, segment)
• Value for rule effectiveness
• Source emissions data entered annually into AIRS
• Quarterly emission statement status report
• Specification of peak ozone season to source
16
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2.2.6 Source Supplied Data
T&e minlmtan source ^ideritlHcation^lnformatlon.- T?rovided bv
(1) Full name, physical location, and mailing address
of the facility, (2) Latitude and longitude and (3) 4 digit SIC
code(s) .
Sources should supply their latitude and longitude
consistent with EPA's Locational Data Policy Implementation
Guidance.6 The guidance, which contains detailed procedures and
guidelines for implementing locational policy, recommends the use
of a global positioning system (GPS) to most accurately determine
latitude and longitude. While sources have the main
responsibility for determining their latitude and longitude, for
improved accuracy of these locational coordinates, States should
assist sources as needed.
An alternative method for locating a source's latitude and
longitude is for States to provide a Geological Survey
topographical county or regional map with locational coordinates
to each source. The source can determine latitude and longitude
by locating the facility on the map.
SIC codes and their descriptions can be found in the
Standard Industrial Classification Manual, published by the
Office of Management and Budget.
m^
source:-:
(1) Percentage annual throughput (percentage of annual activity
by season) , (2) Days per week on the normal operating schedule,
(3) Hours per day during the normal operating schedule, and (4)
Hours per year on the normal operating schedule.
17
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The minimum process rate data provided Ibv the' s
St.at-e ..for alrarobrlatV local'" agency^' should ^include: ( 1 ) Annual
process rate (annual throughput 3 a , and (2) Peak ozone season
daily process rate.
"lav 'tile
. • -w. •. •. f ^ . VL - wv -Jr. .» fffff, ; Jfff. f . f >W«rf •• -.Vf-v Vff _.-. f V s, i- *,-._ f ftfj
fco the- -State (or --appropriate, local 'aoenevV should' include:
(1) Current primary and secondary control equipment
identification codes, and (2) Current combined (if primary and
secondary control equipment is used) control equipment efficiency
(%) . Valid control equipment identification codes are presented
in Appendices G and H. States may need to assist the source in
determining the type of control equipment that the source is
using.
*Phe minimum emissions information provided by the- sdu-rc&i&i
tile State (or apx>gqpriatelocaX agency^ sTtlQuid'/x^clud^: (1 )
Estimated actual VOC and/or NO* emissions at the segment level,
in tons per year for an annual emission rate and pounds per day
for a typical ozone season day19, (2) Estimated emissions method
code, (3) Calendar year for tha emissions, and (4) Emission
factor (if emissions were calculated using an emission factor) .
Valid estimated emissions method codes are presented in
Appendices G and H.
In the event that emission factors are utilized in the
calculation of emissions, a source should use emission factors
that are approved by EPA or the State. Otherwise, the source
should petition the State for approval of their emission factors.
alf annual process rate is given for a fuel process, the
data must represent the amount of fuel burned, if the annual
throughput is given, then the throughput must correspond to a
specific SCC.
^Pounds per day information is included because most SIPs
and SIP rules are predicated on pounds per day.
18
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Each emission, statement should' atl'so include a certification.
, accuracy, <;>€o
statement, The individual certifying the
statement should be an official of the company who will take
legal responsibility for the emission statement's accuracy. A
sample certification of data accuracy form is provided in
Appendix B.
2.2.7 State Supplied Data
In additian/J£o/the emission statement i'^ata requested ,from
the sources, it' is^recpmme^
" data elements ^i^h"ar^vtteces^ry~;ifc^\iine">anrittal' 'Sfile
' >. s t sf •. ff sfff %-.-.-. ^ A f ff ffff V *rjfff ff f ., f ff ff .. f ,;.;.;:..;.;;.;«:.....:
of e^ssion /statement *-i^ Bie AEftS
database.''^ 'T&ese data, include sdurce;;identi£icatiortr;;'infprmati§l
and emission inf ormtin .
the ^gtate-^-shou^d "include: (1) AIRS code, (2) AFS point number
(ID) , and (3) AFS segment number (ID) .
The AIRS code may be assigned prior to sending the Emission
Statement Initial Reporting Form to the facility.
Tne minimum source emission information^ provided' bv: the
'~ "" " ••^••••'•i in •^^a^^i .M»I NT" ^ m^^Jt^^, , i ....i
State- should include: (1) SCC(s) and descriptions for each
segment, (2) Current RE factors at the SCC pollutant level, if
applicable, and (3) RE method code(s). Valid RE method codes are
provided in Appendix C.
States should be aware of the control efficiency applied by
a source so that the appropriate emissions values are reported.
The emission estimates should be neither over or under corrected
as a result of rule effectiveness.
19
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In addition, States should inform sources as to when the
peak ozone season occurs, to ensure an accurate estimate of their
typical ozone season daily emissions. Information on determining
the peak ozone season is provided in Appendix D,
SCC information is provided in the document, AIRS Facility
Subsystem, Source Classification Codes and Emission Factor
Listing for Criteria Air Pollutants. An excerpt from this
document is provided in Appendix E.
2.2.8 Source and State Supplied Data Elements
by Plant, Point and Segment Level
a$^1;;;^rtS^^s^!;;^fe;:?r^>^H:*^i*^¥;
CM^JjJK:..: J^iftlxJttfeS-&£it2t.J.." ttE::::&Q&G-IILiiC:::";±J
SSiVS*^ ^X^zttL
giant level' emission statement data: (1) Full name, physical
location, and mailing address of the facility, (2) Source 9 digit
AIRS code (supplied by the State), (3) Source latitude and
longitude, (4) 4 digit SIC code, and (5) Calendar year for the
emissions.
PHlftl-pgvejlf:^ (1) Percentage annual
throughput (percentage of annual activity by season), (2) Days
per week on the normal operating schedule, (3) Hours per day
during the normal operating schedule, (4) Hours per year during
the normal operating schedule, and (5) AFS point number (supplied
by the State),
Segment -
^ : (1) Estimated actual VOC
and/or NOX emissions at the segment level, in tons per year for
an annual emission rate and pounds per day for a typical ozone
season day, (2) Emissions method code, (3) SCC for each of the
20
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emission estimates (supplied by the State unless the source has
this information) , (4) Current primary and secondary control
equipment identification codes, (5) Current control equipment
efficiency (%) , (6) Annual process rate (annual throughput), (7)
Peak ozone season daily process rate, (8) Rule effectiveness
factor at the SCC pollutant level (supplied by the State), (9)
Rule effectiveness method code (supplied by the State), (10) AFS
segment number (supplied by the State), and (11) Emission factor
(if emissions were calculated using an emission factor) .
2.2.9 Suggested Optional Data
States may augment the recommended emission statement data
to better quantify local issues and/or concerns. States'" pay add
wKafcevjer/data"''elementS';;;b^st^se^e 'their --needs > 'however, "the
following data elements are "suggested as' useful additions to the
e'mfis'iori statement ' dat a - outlined "above .,
Latitude and longitude method code, (2) Latitude and longitude
textual description, (3) Latitude and longitude estimation of
accuracy, (4) Stack identification, (5) Number of employees, (6)
Plant contact, and (7) Plant phone number.
(1) Days per week
of operation during the peak ozone season, (2) Weeks of operation
during the peak ozone season, (3) Start time on both the normal
operating schedule and on a typical ozone season day, and (2) End
data elements are included in the Office of
Administration and Resources Management's Locational Data Policy
Implementation Guidance, February 1992, (Publication number 220-
B-92-008) as necessary locational data that will have to be
collected in the future in addition to latitude and longitude.
AFS will be modified by early fiscal year 1993 to support these
additional data elements.
21
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time on both the normal operating schedule and on a typical ozone
season day.
: o> Speciated VOC
emissions, and (2) other criteria pollutants including sulfur
oxides (SOJ , particulate matter (PM10) , lead and carbon monoxide.
•&-tt>.-->-'v:**f----.v-v*£r-'-m'm^ -_
Suiggeafee&#op^^^ Capture
efficiency (%) . This is a measure of the volume of pollutant
captured or recovered relative to the volume of pollutant
generated.
1 } Design
capacity, (2J Fuel use data (i.e. f h.eat coatent) , (3) Tank data
(i.e., vapor pressure, vapor mole weight, diameter, height, age,
loading type, color, fixed roof tank information/ and floating
roof tank information), and (4) Solvent usage data (i.e., solvent
purchased, and solvent reprocessed) .
Suggested op-t lonal" 'stack inf ormat IOR : Stack parameter
information (i.e., height and diameter).
22
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2.3 State Submittals to EPA
ates'^are request e&!'VaVsubk£t several,/ iteits: under the
jj^fff, fff f.vJ.fj Sf. v. ^f.ffffffff^- ft -.f -. f ffffff fvjvfjffff •-. f ffjfffff ffff f: jv.f f\j f ffsJr ^ s fffffj ~V if v^v j~ ^^ ffff ~ ^^
em£ ssias: discussect -earli'er^ '£ii^t:hi's/dcx;xxmeat:;
/ 'states; are request e<%7 to stOMkL^^bofch^sdwce; supplied
plie<3 f&afca^tp" the ,^&Tvia' tSd^AZR^^taipase'l I
r'econuRencled-thalr States "'also- prepare v'aiiuiiiEfiittal5 are aet'ailequarterly basis
to EPA by no later than July 1 , beginning in 1993, This report
will be a quarterly submittal until all the regulated sources
have complied^for'the reporting year. The reporting, cycle begins
23
-------
agaiaTwith. l&e^nexi: year's emission "statement "su&mi£tal.
suggested suBmittar dates" for the J.M V f. K ^, Cv ff ff, J. •*•> ?
corrected data can"t>e obtained ftoitfA&S "Ci^AXRS is used to
calculate SB-corrected emissions) after the ^missions information
has been subnaitted to AIRS. '' Tn. addition! "'soairces that are
-f A J- ff jt% JV^ JVS * V V
delinquent in "sufcanilbtijag tiiexr "emissioix, statements should be
individually' listed l£ they emit 500 tpy OJT more o£ VOC or 2501(3
tp# or more of KCX* A detailed listing of the minimum data
recommended for the Emission Statement Status Report submittal to
EPA is contained in the following text. An example format for
the Emission Statement Status Report is provided in Appendix F.
i1 for the'% Ein^ssion Statement ^Status
Report submittalf to- BPA-" include source idejxt'i-fication'1 information
and. emissions1 " <
Slfriielt^ for all
and emit'. SOO tbv
l)^ 'should 'Include :
(1) Full name of the facility, (2) County code in which the
facility is located, (3) AIRS facility ID code, and (4) EPA ID
code (FINDS code) for the facility (if already assigned by EPA) .
o&^a^^
Inf orliiiloG : Actual VOC and/or NOX emissions totaled for all
sources which submitted emission statements, in tons per year for
an annual emission rate and pounds per day for a typical ozone
season day, both RE-corrected and non RE-corrected.
24
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2.4 Additional State Data Responsibilities
siKL'e'vf or "resolving^ eMssion. 'estimate
inconsistencies witft'the -sources 'prior' td subradLt'tal aH'the
emi'Ssiqri' stateroeott" dafca- tOfJS&&Z- To avoid data inconsistencies,
States need to be available to assist sources, particularly
nontraditional sources, with the preparation of the emission
x-v&w*v-'-m*y-w.-"f*m^
:STn:aty-i'"V>-&Ci*'T: "V'^>;':^&'QQ-1--'C^:'i*"*T^^^'QG:^-Q^i.iT*/TOC"'v:1::TI:
::::lilaY:-:: JLrocU.^UU ::;>•:..%>•.•...•. ^.-.:; •:.:.:«•"••:•••'.,>...•:>.•:> ..... vi:. . ••:•-.;.-.-/...••.. •.•,...,.-.,>•.,..:.-.-.-.'.:«.••>•>•-•=•:"••••••-'* .-... :.- ••••••-..-:•."»•... ^ ...... .-.-^ •••:••:• • ^.-..-. ..... •- ..-.••
States shoulcJ a^gwent,1' thef requested; emission statement
inforntatipa with important data that sources, particttlarly
with no preyiOiuS emission reporting experience," may not "have.
Th'ese"dataJinclude the source*'s scclancfcAlRS code, AFSf point aad
< v. v •: AV •.t.tf-w >^vtj^' X.<«v^. iv^- » •*•
segment identi£ication hmrtbersx and current "BE factors at the^SCC
pollutant level,"" These $ata .elements are,"not ^recfuired^ for the
scsurceT Submittal to the" State, but* axe recornmendecl "for the State
> V fj-jf f. JV f. ' f. fS. V -.-.-.
submlfctal to 4the 'AZRS1 database,. The State could prefall the
above information prior to forwarding the emission statement form
to the source. The State should prefill the SCC number and
description prior to forwarding the form to the source if the
source does not have this information so that the source can
accurately compute its emissions and process rate data. States
could obtain SCC information by sending out a survey to sources
requesting descriptions of the processes that a facility carries
out. Prior knowledge of these processes would enable the State
to fill in the appropriate SCC before sending out the emission
statement form. It is recommended that States submit all data,
whether provided by the source or the State, into the AIRS
database.
25
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States should Isoaontain ''adequate records' o£ emission
•. SS -f ' f J •. f
';'data and,- source c&tt±££G&£o&£'of"^Z
.- .- •• -. V^ ",• -. •. > ff ff s v /.-.••. ^ .- -. -. •• v -. .- ' fff f fff ; * j-f *•. f
f -V. '-.J^ff -f ff /-. >v f, fff* -.-• f ff f ••'.-'M- *-ff ffjf f -ff •*• A*. •"• -^J f fjk.fv''' vw VJV+tf ffQfrrf ••?• £••*•-•• J>.» V.-.I". -V-*-Jv ff f "•' •W-r vf . f f f
KS Jj&em 6gf sources/ £cr; a -period-, or -at 'least three jears to
r ' verification , o£ - ^he information, 'as
In order to ensure proper data flow into the AIRS database,
States need to be cognizant of the timing of different emission
reporting requirements.
2.4.1 Data Consistency
jiffi&Zx^^igZ^fi&i^
b>^lCl V-'^^'.CO^ : ^tSO-^JUHlfCl^CSij-:-- • tfaiti-ty-:: : £ .fe£ O ja.-W JE tO W X-Cgx^Ct JiV*: :::..W» kJJGU5> &.5fc fctJi I>TM:- >::-Wi*U .JHAJ. : :-:;O ln-Ctt CJ
:v:"i:v>x-Xv:rvr.%v:«vK:\::>>x%:-x%vK-N:.:'»::-:v:^->vX-:^^^^ ..... ..........
using an emission factor approach, the State should compare the
emission factor, the activity data, and the control efficiency
assumptions. If source testing was used to determine the
facility estimate, the State may compare the estimate with an
emission factor estimate for relative magnitude or
reasonableness. Finally, if the estimate represents an
engineering judgement or a material balance, the State may wish
to provide additional guidance to the facility on how they would
like the estimate to be made.
Using either EPA or State-supplied emission factors, the
AIRS database can be used to calculate emission estimates. If
sources use emission factors to calculate their emissions, States
should input the emission factors used by the sources or
reconcile the sources' emission estimates with the EPA or other
State emission factor. Alternatively, sources could submit their
input data to the State without actually calculating their
emissions. Emission estimates could then be generated by AIRS
using EPA's or the State's emission factors and sent back to the
source for verification and certification. States can use any
26
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method to verify consistency in emission values they choose.
However, States should make sure that the source-certified
emission values are identical to the non RE-corrected emissions
in the AIRS database.
2.4.2 Data Confidentiality
The EPA has provisions for maintaining the confidentiality
of a limited number of process rate data elements in the AIRS
database. Process rate information may be considered
confidential by EPA if it is confidential business information
and constitutes a trade secret. T&e data, ^elements- requested '•for
eiftis'si.on statements that jss&y be considered "eo,nf identiaJL inclade
annual process- ^rate^ ah<3 pea& baoiie season. 'daily^pr-ocess^ rate,
EPA published a policy statement in the February 21, 1991
Federal Register (Vol. 56, No. 35) regarding EPA's views on the
confidentiality of certain emission data. The statement,
entitled "Disclosure of Emission Data Claimed as Confidential
Under sections 110 and 114(c) for the Clean Air Actr"d
specifically excludes emission data from the general definition
of trade secret information for certain classes of information
submitted to EPA under sections 110 and 114 of the CAAA.
Emission statements are submitted under section 110 of the CAAAr
and thus, 'certain data -elements that axe suggested^ emissions "data
for eflaLssion statements, are not considered to" fee confidential.
These data elements are: full name, physical "location,, and
mailing address of the. facility;1, latitudes and. longitude; SIC
code; "VQC and KTO* ^emission's (tpy^and "Ibs/day}^? "estiioatedl
emissions method? calendar year for the emissions; and: the SCXp
If States have questions on specific data confidentiality issues,
they should contact their EPA Regional Office on an individual
basis.
dSection 1905 of Title 18 of the United States Code.
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2.4.3 Data Flow
The CAAA require that a SIP revision, which includes a
provision for an emission statement program, be submitted by
November 15, 1992. In addition, the CAAA require that the first
set of emission statements, representing 1992 emissions, be
submitted to the State agency no later than November 15, 1993.
Again, EPA strongly recommends that the State agencies schedule
the first emission statement data submission for April 15, 1993
and annually on April 15 thereafter. This schedule will allow
time for verification of the data prior to the July 1 AIRS/AFS
data submittal, which coincides with the due date of the annual
point source submittal. Emission statements request the same
information as that reported for the point source submittal, with
the addition of peak ozone season daily process rate for
determining typical ozone season day emissions.
Many types of data are housed in the national AIRS/AFS
database. It is important for State agency personnel reporting
emission statement data to understand and coordinate with other
agency reporting activities to AFS. A potential to override data
exists when different agencies (e.g., local and State) or
different personnel within an agency update the AIRS database.
State agencies should develop and implement procedures to ensure
that one set of submittals do not override other submittals
accidentally. For example, when submitting permit, emission
statement, periodic SIP or other data in AFS batch format, it is
important to run the AFS "trial dummy update" to fully understand
how the data in the system will change following the update.
When uploading data from the SIP Air Pollutant Inventory
Management System (SAMS), the AFS compare preprocessor compares
the newly submitted data with the existing data in the AIRS
database. The results from the preprocessor tell the user
whether the new information is a "change", meaning the new data
is different from that currently on the database, or if it is an
28
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"add", meaning the data does not exist on the AFS database
currently. States should refer to AFS guidance for more detailed
information, on the data submittal process.
«
reJB^ns^felld^y"^c^ [the;"S|^tte, agenc.^;^t^:'jjoor
activities' wafchiJTT AIRS'.
29
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30
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3.0 EMISSION STATEMENT REPORTING
developed ^ a proposed ^
reporting' pro.cess',T' However, 'fcHe CAAA' ^ailow- JStates to
their [own /orraat" f or^ei^ssiqn 'Stat6^nt.' 'reporting*.
Emissions data is requested both from facilities that have not
previously been asked to submit emission information and from
facilities familiar with emissions reporting. Therefore, the
emission statement reporting format needs to accommodate
different levels of emission estimation experience. To^ac&ieve
tHe ''greatest accuracy possible-, while "n-ot^ placing' art undtte 'burden
ant smaller s:'spurqes- ,' ^States- eoulct 'adopt a jfciual^ era£ss±dn /statement
reporting 'forittat.'S Usiitg this "'apprpach'7, "traditional sc-urces/
sC wh«Sse emi'ssiotts .are iti fcHe ; AIR'S, database-,' ^pjjicL^s^PP^Y
ti'oti'^tq;' tlxe; jState^Cor ^'appropriate ,iocal "agency )
^revising\the±r AF]?^44^report . ]^ai67APP^44' report is an 'output
report [of. aJ'spurce-^s?';e%Lss-i.paSv>dat^ %siorec3£Twi£l4^a^ the/AERS
database-, 'Nbritradafcloaal' "sources ;?' HSose,' wifcn?""Eb;;v previous
^•^ '<. -• ^/// •- ^/v -. s\v.-f -.v j-v s^ -•.-j'^, / vr^ ^ j-^ .•-..'W.-/ fjjfffr vj. f f *> ^^ •'*•*• ^ >.vv
einissiohs data^qo, £il"e [witit 'th'e^PAi' wouX'cL'be^seo^^aa- Emission
Statei^nt,,Initial^Reportihg -Form^ After the State has entered
the nontraditional source's first year's data into AIRS,
subsequent emission statement reporting provisions could be met
by supplying the source with their AFP644 report for revision.
Regardless of what' reporting format"; is/used by -sources to
submi!t their emission statement inf ormatioja, both traditional and
aofttra-ditional sources s&cvldvcertiix the "accura'ey of their
emission statements. No eiaissioa,, statement is considered
cc^lete;'%«athput "the certifying ''f^^^^j^K^^'^L'^^^j^"^"'^^e^
to data accuracy^ The certifying individual should be an officer
of the company who will take legal responsibility for the
emission statement's accuracy. An example emission statement
certification of data accuracy is given in Appendix C.
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3.1 Development of Reporting Format
The following format for emission statement reporting is
presented as an option for States to consider. It is not
necessary for States to collect the emission statement data in
the format proposed in this document. States are requested,
however, to submit the emission statement data to the EPA by
updating the AIRS database. The emission statement data
collected by the State should be sufficient to meet the EPA
provisions outlined in section 2.2 of this document.
3.2 Traditional Sources
States should send traditional sources copies of their AFS
data as presented in the AFP644 report accompanied by
instructions and an explanatory letter stating that the data
elements be updated and certified for accuracy. The requested
data elements for emission statement reporting should be
highlighted so that the source can easily identify the data that
need to be reviewed.
Appendix G, Part 1 contains an example explanatory letter to
be used as an example of appropriate correspondence from the
State to traditional sources. The letter contains background
information on the emission statement provisions and details the
facility's obligations. Appendix G, Part 3 contains instructions
to assist sources with the update of their emissions data using
the AFP644 report. The letter and instructions are intended as
examples of appropriate State guidance to sources. This or
similar information should be forwarded to sources along with
their AFP644 report. An overview of methods for estimating VOC
and NOX emissions is given in Appendix D.
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It is important when States submit emission statement data
to the AIRS database that a source be entered into AIRS only once
and that the AIRS code and all locational data for the source be
accurate and complete. This procedure allows EPA to correctly
assign an EPA facility ID code. States should be aware of
whether a source already exists in the AIRS database, or is an
addition to the database before entering its emission statement
data. In addition., States should verify that an EPA facility ID
code has been assigned to each new facility whose emission data
have been submitted to AIRS. EPA is replacing all references to
NEDS/CDS IDS with the EPA facility ID code. EPA updates and
assigns these codes on a regular basis. Therefore, States should
be able to review sources' AFP644 reports during the year
following the sources' initial data submittal to AIRS to
determine the EPA facility ID code. A more detailed discussion
of the EPA facility ID code is found in Appendix I.
The source should mark directly on the AFP644 report to
indicate any changes or corrections. The report should then be
forwarded to the State (or appropriate local agency) for State
agency personnel to review the new information for consistency.
Any inconsistencies should be reconciled between the State and
the facility. The State should then enter the emission statement
data into AIRS. Data formats and field lengths of emission
statement data elements are specified in the AIRS User's Guide
Volume IX: AFS Data Dictionary.'1
Alternatively, the State may request that sources submit the
emission statement information in a machine readable format, or
in some other format developed by the State, to ease the AFS
update process. Regardless of the reporting mechanism used, it
remains the State's responsibility to detect and resolve
inconsistencies in facilities' emission statement data prior to
entering the data into the AIRS database.
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3.2.1 AFP644 Report
The proposed emission statement reporting format for sources
with emissions data in AIRS (i.e., traditional sources) is the
AFS AFP644 report. See Appendix G, Part 2 for a sample AFP644
report. The AFP644 report can be accessed via the AFS default
report menu or via the ad hoc batch (Quick Look) report screens
by designating a report type of "TE" for specifying plants above
a "Threshold Emissions" level. The actual menu selection is
called "default". The AFP644 output format is predefined, but it
can be customized to print various levels of data (plant, stack,
point, segment, or any combination). When using the quick look
"TE" option to create the AFP644 report, if no threshold emission
level is set, the user should request that the system only report
emission values greater than zero. This request may
significantly reduce the length of the report. The quick look
"TE" option also allows the user to select several facilities for
which the system should generate AFP644 reports. Using this
option, numerous sources' reports can be generated and printed in
one job.
Although the AFP644 report can be accessed by running the
quick look report type "TE", some States may prefer to run AFP644
as a fixed format report. Screens within the fixed format allow
the user choices, such as selecting the level of emissions, which
States may find useful.
The AFP644 report was specifically created to serve as a
turnaround document for State and/or local agencies to send to
facilities. However, States may wish to alter the report prior
to sending it to the source to highlight requested data fields
and/or adjust the formatting. The report may be altered by
sending it to a file rather than a printer. A report saved to a
file will be in DOS text format and may be altered by using any
34
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of the numerous available text editors or word processing
packages. States may also use AFS to generate mailing labels.
MIT ,
tkH'ement rep^ftingroir¥'Hfg'hIigh€ecL oa 'Tfchjs "example.
&FP644 'repbrt '^iri"Append£s<:'^Z% Ad&i;t£oT^>,&fe"e'Hm:%^^
the "Afp;^ reportr "ftowever/ only '^e\higha£g&tea;;dafc<* "e
'requested to- "He veriffed or supplied by tEe source-
The sample facility (plant) represented in the example
report is composed of 2 stacks, 3 points, and 5 segments. On the
AFP644 report, specific emission statement information is
requested under different levels (i.e., plant, point, and
segment) of operation. Plant information is primarily
identifying information. Point data are collected for individual
stacks or storage tanks and segment level information is
collected below the point level. For example, if a boiler
operates on either oil or natural gas, as in the example AFP644
report, emissions would be reported for segment 1 for the burning
of oil and for segment 2 for the combustion of natural gas. Each
segment represents a separate process.
States may use an equivalent alternative to the AFP644
report and instructions, however, the minimum emission statement
data elements, as outlined in section 2.2 of this document,
should be included. It should be kept in mind that States are
requested to enter the emission statement data into the AIRS
database regardless of the emission statement reporting
mechanism.
3.3 Nontraditional Sources
Nontraditional sources, those with no previous emissions
data on file with the EPA or State, should be sent an Emission
Statement Initial Reporting Form to report their first year's
35
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emission statement data. The form should be accompanied by an
explanatory letter and detailed instructions to assist the
sources with accurately completing the requested information.
Appendix H, Part 1 contains an example explanatory letter to
be used as an example of appropriate State correspondence to
nontraditional sources. The letter provides background
information on the emission statement provisions, introduces the
initial reporting form, and discusses the facility's obligations.
Appendix H, Part 3 contains example instructions to sources for
completion of the Emission Statement Initial Reporting Form.
These instructions are intended to assist States in developing
adequate guidance to ensure consistent emission statement data
reporting by sources. Both the letter and instructions are
provided as examples. However, States should send this, or
similar information, to the source along with the initial
reporting form. As mentioned previously, an overview of methods
for estimating VOC and NOX emissions is given in Appendix D.
e^^j^jfj^^^W^^^^^^: :•:•.•.<«•:..x-.-:-:-:-x-,-•.•:•;•:-.:•:.v;-:::-.-::-:• • v— • • ••'••
saiiidli- segmertfiad^esttiMiicalt:iic^^-llumbiierfsl^':?•••:?;:ISt'ifees- are
-.• .v.^. ••. •..•.-.•....•.v.-tT ..•.•.-..••...••.•.•..,•..•.•...•. — •.• .•.-.•:.•.-.--•• ...•.•..-:.•-•:•....-..'..•.••..•.•..•. •..••:•:••.--•.•...•.• :.-.-• •:•....•:•::•:•..::•:•:•.•...-.-.—.••.... ..7^ •
^:TOlpai^^^:Si^^f^i^^c^i^tti^in|l
|Kii|s;;^||^^ni^^c^| States should prefill the
Emission Statement Initial Reporting Form with the above
information, where practical. The States should supply the SCC
and its description on the Emission Statement Initial Reporting
Form (if the source does not have this information) in order for
sources to accurately identify their emissions. The SCC
description will let the source know what the SCC refers to. It
is not necessary to enter this description into AIRS because AIRS
automatically provides a description of the SCC upon entry of the
SCC into AIRS. As stated earlier, knowledge of a source's
36
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processes could be obtained from a survey sent out to applicable
facilities, and this information, would enable the State to fill
in the appropriate SCC before sending out the emission statement
form. The remaining State supplied information may be filled in
by States after sources complete the forms. States should also
be available to assist sources in determining the correct
information for other data elements.
The State should submit all emission statement data, whether
provided by the State or the source, to the AIRS database. Once
the source has completed the form and the data are entered into
the AIRS database, subsequent emission statement provisions may
be met by sending the source their AIRS AFP6.44 report for review
and/or correction. Data formats and field lengths of emission
statement data elements are specified in the AIRS User's Guide
Volume IX: AFS Data Dictionary.
3.3.1 Emission Statement Initial Reporting Form
Appendix H, Part 2 contains an example Emission Statement
Initial Reporting Form that can be used by States to forward to
nontraditional sources for emission statement reporting. The
form .consists of four pages, one page each for plant and point
data and two pages for segment level emission statement data. A
second page for the segment level data was developed to
accommodate States who wish to collect additional pollutant data
through the emission statement process. The additional segment
page is not necessary for emission statement reporting; VOC and
NO, data are sufficient.
A shaded "For State Use Only" section is provided for
requested State supplied data. As previously stated, States
should prefill as much of this information as possible prior to
sending the form to the source. Specifically, sources need to
know the SCC and its description in order to correctly compute
37
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their emissions and determine the appropriate units for reporting
process data. The State should supply this information to
sources that do not have access to it. As previously stated, the
SCC description does not need to be reported to the AIRS database
because the system will provide the appropriate description once
the SCC has been entered. The purpose of the description is to
aid both source and State personnel working with the forms to
understand the type of process for which information is being
requested.
The initial reporting form also contains AIRS update screen
numbers. These screen numbers will be helpful for States that
plan to update the AIRS database in an interactive mode. States
using the AIRS batch transmittal may disregard the update screen
information. The correct format for AFS batch transmittal can be
obtained from the State or Regional AIRS contact or by contacting
the National Air Data Branch of the EPA.
When submitting data to AFS using either on-line update
screens or batch transmittal, NOX emissions data (which include
both NO and NO2) should be reported under the data field "NG2",
the appropriate pollutant code. NO* is not a valid pollutant
code for AFS.
States will need to coordinate with the source to ensure
that the initial reporting form is adequate to cover all points
and segments at the plant. The number of pages sent to the
source should reflect the number of points and segments
determined to 'exist at the plant.
The initial reporting form is provided as an option for
States to use. States may use alternative reporting forms as
long as the minimum emission statement data elements are
provided.
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4.0 Draft State Regulation
The following draft model State rule can be utilized in the
development of the State's emission statement program. The model
rule is intended as an example, it does not represent the basis
of the criteria that EPA will use to evaluate and approve the
State SIP. However, by following the information presented in
this guidance document and in the model regulation, States should
be able to develop an acceptable regulation and thereby an
approvable SIP.
A few States have attainment areas in ozone transport
regions. As previously noted, these areas are subject to
emission statement requirements. If States do not have such
regions, section XX.010 of the draft State regulation should be
modified to delete the reference to attainment areas in ozone
transport regions.
§XX.010 Applicability
This regulation applies to all stationary sources with
emissions of oxides of nitrogen (NOX) or volatile organic
compounds (VOC) in nonattainment areas and also sources which
emit, or have the potential to emit, 50 tpy or more of VOC or 100
tpy or more of NOX in attainment areas within ozone transport
regions, with the following exceptions.
Classes or categories of facilities with less than [25 tons,
or appropriate State cutoff] per year of plant-wide actual VOC or
NOX emissions are exempted from this requirement because these
sources are included in the base year and periodic emission
inventories. In [insert State], the following facility classes
or categories are exempted from the emission statement
requirement: (insert list].
Additionally, if either VOC or NOX is emitted at or above
the minimum required reporting level, the other pollutant must be
included even if it is emitted at levels below the specified
cutoffs.
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§XX.020 Preamble
This draft regulation was prepared in response to section
182(a)(3)(B) of the 1990 Clean Air Act Amendments which requires
the preparation and submission of annual emission statements.
Required emission statement data includes plant, point, and
segment information. Facilities are required to provide their
emissions information at the segment (i.e., process) level only.
§XX.030 Definitions
AIRS Facility Subsystem (AFS) codes as discussed in these
definitions may be found in the AFS Data Dictionary. The Data
Dictionary can be accessed online through the Time Sharing Option
(TSO).
As used in this regulation, the following terms are defined
as follows:
(A) "Actual emissions": The actual rate of emissions
of a pollutant from an emissions unit for the
calendar year or seasonal period.
(B) "Annual process rate": The actual or estimated
annual fuel, process or solid waste operating
rate.
(C) "Certifying individual": The individual
responsible for the completion and certification
of the emission statement (i.e., officer of the
company) and who will take legal responsibility
for the emission statement's accuracy.
(D) "Control efficiency": The actual total control
efficiency achieved by the control device(s).
(E) "Control equipment identification code": The
AIRS/AFS code which defines the equipment (such as
an incinerator or carbon adsorber) used to reduce,
by destruction or removal, the amount of air
pollutant(s) in an air stream prior to discharge
to the ambient air.
(F) "Emission factor": An estimate of the rate at
which a pollutant is released to the atmosphere as
the result of some activity, divided by the rate
of that activity (e.g. production rate or
throughput).
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(G) "Estimated emissions method code": A one-position
AIRS/AFS code which identifies the estimation
technique used in the calculation of estimated
emissions.
(H) "Fugitive emission": Releases to the air that are
not emitted through stacks, vents, ducts, pipes,
or any other confined air stream, including
fugitive equipment leaks, evaporative losses from
surface impoundments, and releases from building
ventilation systems.
(I) "Oxides of nitrogen": (or NOX) In air pollution
usage, this comprises nitric oxide (NO) and
nitrogen dioxide (NO2) , expressed as molecular
weight of NO2.
(J) "Peak ozone season": That contiguous 3 month
period of the year during which the highest ozone
exceedances days have occured over a period
covering the last 3 to 4 years. Most ozone
nonattainment areas have a peak ozone season
lasting from June through August. The period
used for the 1990 base year ozone SIP inventory
should be used for subsequent emission statements.
(K) "Percentage annual throughput": The weighted
percent of yearly activity for the following
periods:
1) December-February
2) March-May•
3) June-August
4) September-November
The first season (Dec-Feb) will encompass
2 calendar years (e.g., Dec '92 - Feb '93).
(L) "Plant": The total facilities available for
production or service. Plant level information
(e.g., address, latitude/longitude^ SIC code) is a
required component of emission statement
reporting.
(M) "Point": A physical emission point or process
within a plant that results in pollutant
emissions. A unique identifier (point
identification number) exists for each point
within each facility in the AIRS database.
(N) "Potential to emit": The capability of a source
to emit a pollutant at maximum design capacity,
except as constrained by federally-enforceable
permit conditions which include the effect of
41
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installed air pollution control equipment,
restrictions on the hours of operation, and the
type or amount of material combusted, stored, or
processed.
(O) "Process rate": Quantity per unit time of any raw
material or process intermediate consumed, or
product generated through the use of any
equipment, source operation, or process. For a
stationary internal combustion unit or any other
fuel burning equipment, this term means the
quantity of fuel burned per unit time.
(P) "Segment": Components of an emissions point or
process, at the level that emissions are
calculated. One example of a segment is a boiler
burning #2 oil. A unique identifier (segment
identification number) exists for each segment
within each point and plant in the AIRS database.
Each segment is also identified by a SCC.
(Q) "SIC code": Standard Industrial Classification
code. A series of codes devised by the Office of
Management and Budget (OMB) to classify
establishments according to the type of economic
activity in which they are engaged.
(R) "Stack": A (smoke) stack or vent within a plant
where emissions are introduced into the
atmosphere. A unique identifier exists for each
stack within each facility in the AIRS database.
(S) "Stationary source": Any building, structure, .
facility, or installation which emits, or may
emit, any air pollutant subject to regulation
under the Act.
(T) "Transport region": A region covering multiple
States which may be established by the
Administrator whenever interstate transport of
pollutants contributes significantly to the
violation of National Ambient Air Quality
Standards.
(U) "Typical ozone season day": A day typical of that
period of the year during the peak ozone season.
(V) "Volatile organic compounds (VOC)": Any compound
of carbon, excluding carbon monoxide, carbon
dioxide, carbonic acid, metallic carbides or
carbonates, and ammonium carbonate, which
participates in atmospheric photochemical
42
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reactions. This includes any such organic
compound other than the following which have been
determined to have negligible photochemical
reactivity: methane; ethane; methylene chloride
(dichloromethane); 1,1,1-trichloroethane (methyl
chloroform); 1,1,1-trichloro-2,2,2-trifluoroethane
(CFC-113); trichlorofluoromethane (CFC-11);
dichlorodifluoromethane (CFC-12);
chlorodifluoromethane (CFC-22); trifluoromethane
(FC-23); 1,2-dichloro 1,1,2,2-tetrafluoroethane
{CFC 114); chloropentafluoroethane (CFC-115);
1,1,1-trifluoro 2,2-dichloroethane (HCFC-123) ;
1,1,1,2-tetrafluoroethane (HFC-134a); 1,1-dichloro
1-fluoroethane (HCFC-141b); 1-chloro 1,1-
difluoroethane (HCFC-142b); 2-chloro-1,1,1,2-
tetrafluoroethane (HCFC-124); pentafluoroethane
(HFC-125); 1,1,2,2,-tetrafluoroethane (HFC-134);
1,1,1-trifluoroethane (HFC-143a); 1,1-
difluoroethane (HFC-152a); and perfluorocarbon
compounds which fall into these classes - (1)
cyclic, branched, or linear, completely
fluorinated alkanes, (2) cyclic, branched, or
linear, completely fluorinated ethers with no
unsaturations, (3) cyclic, branched, or linear,
completely fluorinated tertiary amines with no
unsaturations, and (4) sulfur containing
perfluorocarbons with no unsaturations and with
sulfur bonds only to carbon and fluorine.
§XX.040 Compliance Schedule
(A) The owner or operator of any facility meeting the
applicability requirements stated in §XX.010 must
submit an emission statement to the State [or
appropriate local agency] on an annual basis
beginning no later than April 15, 1993 [or
whatever date the State selects], for the previous
calendar year. The emission statement shall
include, at a minimum, the data outlined in
§XX.050(A).
§XX.050 Requirements
(A) The emission statements submitted by the source to
the State [or appropriate local agency] shall
contain (at a minimum) the following information: '
(1) Certification that the information contained
in the statement is accurate to the best
knowledge of the individual certifying the
statement. The certification shall include
the full name, title, signature, date of
43
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signature, and, telephone number of the
certifying individual.
(2) Source identification information:
(a) Full name, physical location/ and
nailing address of the facility
(b) Latitude and longitude
(c) SIC code(s)
(3) Operating information:
(a) Percentage annual throughput by season.
The first season (Dec-Feb) will actually
encompass a two year period. (e.g.
December 1991 through February 1992).
The remaining seasons (Mar-May, Jun-Aug,
Sept-Nov) represent one calendar year
(e.g., 1992).
(b) Days per week on the normal operating
schedule
(c) Hours per day during the normal
operating schedule
(d) Hours per year during the normal
operating schedule
(4) Process rate data:
(a) Annual process rate (annual throughput).
The AIRS facility subsystem source
classification code table prescribes the
units to be used with each source
classification code for annual fuel
process reporting.
(b) Peak ozone season daily process rate.
The AIRS facility subsystem source
classification code table prescribes the
units to be used with each source
classification code for peak ozone
season daily process rate reporting.
(5) Control equipment information:
(a) Current primary and secondary AFS
control equipment identification codes
(b) Current control equipment efficiency
(%). The actual efficiency should
reflect the total control efficiency
from all control equipment and include
downtime and maintenance degradation.
If the actual control efficiency is
unavailable, the design efficiency or
the control efficiency limit imposed by
a permit should be used.
44
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(6) Emissions information:
(a) Estimated actual VOC and/or NOX
emissions at the segment level, in tons
per year for an annual emission rate and
pounds per day for a typical ozone
season day. Actual emission estimates
must include upsets, downtime and
fugitive emissions, and must follow an
"emission estimation method".
(b) AFS estimated emissions method code
(c) Calendar year for the emissions
(d) Emission Factor (if emissions were
calculated using an emission factor)
45
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46
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5.0 POSSIBLE ACTIONS FOB NONCOMPLIANCE
Due
of la,'s6ate'X^I2?, l^ncpmp£iance 'withVtfce emission
statement prpvisibds^is/coasidered'to 'Jse^a violation "of ' tlie State
Implementation Plan* Any SIP not containing a provision for
emission statements will be considered deficient.
Section 113(a) (1) of the CAA describes possible penalties
that could be applied to sources if they do not meet the CAAA
requirements for emission statement reporting. States should
refer to the CAA for a description of the sanction options.
47
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48
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6.0 PROPOSED USES FOR EMISSION STATEMENT DATA
The CAAA require increased reporting and tracking of
emissions. The EPA believes that the submission of accurate
emission statement data will be helpful for the development,
quality assurance (QA), and completeness of several emissions
reporting requirements including: tracking of reasonable further
progress (RFP), periodic SIP inventories, annual AFS submittal,
the operating permit program (Title V), emission trends, and
compliance certifications. In addition, the submission of
accurate emission estimates by the facilities, and then by the
State agencies, will facilitate other State and EPA programs that
require emission estimates. These programs include regional
modeling efforts, control strategy development, economic analyses
of control strategies, and special projects such as reports to
Congress.
6.1 Base Year SIP Emission Inventory
Section 182(a}(1) of the CAAA requires all ozone
nonattainment areas to submit a comprehensive, accurate, current
inventory of actual typical ozone season day emissions from all
sources within 2 years of enactment. The first inventory (base
year) is due by November 15, 1992, and covers actual typical
ozone season day emissions in 1990.
6.2 RFP Tracking
A primary purpose for emission statements is to assist EPA
and the States in the determination of RFP in meeting the NAAQS.
Annual emission statements will greatly enhance the State
agency's ability to track RFP emission reductions. Emission
statements will help monitor growth in an area or source
category.
49
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As part of the RFP program, moderate and above ozone
nonattainment areas must reduce their VOC emissions by at least
15% within 6 years after enactment of the CAAA. A 15% reduction
is generally thought to be adequate for moderate areas to attain
the ozone NAAQS within the applicable time frame, although a
modeling analysis is required to determine if additional
reductions are necessary to attain the ozone NAAQS. In addition,
serious and above ozone nonattainment areas must achieve VOC
reductions after the initial six year period equal to an average
of 3% annually until attainment of the standard is achieved.
These emission reductions are referred to as "milestones."
States must adopt specific measures as part of their control
strategy to meet the 15% and 3% per year requirements.
6.3 Periodic SIP Emission Inventories
Section 182(a)(3) requires that ozone nonattainment areas
submit periodic inventories every three years until the area is
redesignated to attainment. The EPA is recommending that States
synchronize their schedules for developing the periodic
inventories so that the second periodic inventory, which is based
on 1996 emissions and is required by the CAAA no later than
November 15, 1998, is actually submitted early in 1997 (by
February 13, 1997). By accelerating preparation and submittal of
the 1996 periodic inventory, the milestone demonstration
(required under section 182 (g)) that is due for serious and
above areas by February 13, 1997 can be based on this periodic
inventory. If similarly accelerated, future periodic inventories
would then also coincide with subsequent milestone
demonstrations.
The information included in annual emission statements will
facilitate the development of such periodic SIP inventories.
Submission of actual annual typical ozone season day emissions
and operating information will provide internal QA checks that
50
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will assist in the development of accurate estimates. It should
be noted, however, that emission statements alone do not
constitute an overall emissions inventory. Emission statements
will not reflect area, mobile, and biogenic sources. These other
types of sources may also contribute significantly to the
composition of accurate emission inventories.
6.4 AIRS Facility Subsystem (APS) and Annual Point Source
Reporting
AIRS is EPA's database for airborne pollution in the United
States. AFS, one of four subsystems within the AIRS database, is
a national software system which contains emission and compliance
information for individual facilities. Data from the emission
statements will be used to update and augment current AFS
information.
The Office of Air Quality Planning and Standards COAQPS),
which maintains the AIRS database, requires State agencies to
submit annual AFS reports for all stationary sources emitting
over 5 tons per year of lead, 1,000 tons per year of carbon
monoxide or over 100 tons/year of any other criteria pollutant.
This requirement, is detailed under Title 40 of the Code of
Federal .Regulations, Part 51, section 51.321 - 51.323.
It is hoped that the emission statement provisions and their
compatibility with SIP reporting requirements will assist the
States in obtaining better data from the facilities and that this
will result in more accurate, frequent, and complete ATS
submittal by the State agencies.
States may use existing State computer systems for gathering
and reviewing emission statement data. However, the data should
ultimately be entered into AIRS/AFS by the State.
51
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6.5 Permit Program
Within 3 years of enactment of the CAAA, States must submit
proposed permit programs to EPA for approval. Sources subject to
the program must submit complete permit applications within 1
year after a State program is approved by EPA or, where the State
program is not approved, within 1 year after a program is
promulgated by EPA. Permits will be for a fixed term, not to
exceed 5 years. Sources should develop a permit application with
data that correspond with their emission statement information.
Permit programs shall be submitted by major sources starting in
November of 1992, and approval by EPA shall take place within one
year of this submittal. Permit applications are due starting in
November of 1994, and a permit shall be issued within 18 months
after the application is received by EPA. The permit regulations
were proposed in the Federal Register, May 10, 1991, Volume 56,
number 91, pages 21712 - 21781. The permit program regulations
will be located in Part 70 and Part 71 of Title 40 of the Code of
Federal Regulations.
Emission statements will assist State agencies in the review
of permit program data by providing a data source for the quality
assurance of permit applications. When emission statement
programs are implemented across all nonattainment areas, the
State agencies will not be limited to emission data from
facilities in their State, but can access relevant data across
the nation. Emission statements will be a requirement contained
within the Title V permit program.
6.6 National Emission Trends
National emission trends are computed annually using the
previous year's economic and production data and standard
emission factors to develop and revise trends in emissions. The
national emission trends estimation methods were developed to
52
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provide a surrogate indicator of the nation's emissions.
Historically, national emission trends have not accounted for
plant by plant variations in emissions.
When new data are introduced or the emission estimation
procedure is revised/ the national emission trends are
recalculated for the previous years, back to the year 1940.
Recalculation ensures that emissions are calculated using a
consistent method thereby illustrating trends in emissions and
not changes in the estimation method. The national emission
trends require annual computation of area and mobile source
emission estimates.
The national emission trends estimation procedures are
undergoing revision so that the national emission trends
estimates correspond more closely with the State totals as
reported through AFS. In addition, there is new focus on
regional trends in emissions. Emission statement data will be
utilized by EPA in the new national emission trends procedures.
6.7 Compliance Certifications
The EPA will publish enhanced monitoring and compliance
certification (EM/CC) rules in accordance with. Title VII of the
1990 Clean Air Act Amendments. The following information is
based upon the Public Information Document dated August 1991 and
may or may not be part of the final regulations.8
Section 702(b) of the CAAA empowers EPA to require certain
stationary sources of air pollution to install and operate
enhanced monitoring equipment and to submit compliance
certifications„
The owner or operator of a major stationary source must
certify compliance with all applicable requirements under the
53
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CAAA to the permitting authority at least annually. If the
source fails to be in compliance, quarterly deviation reports
based on enhanced monitoring must be submitted to the permitting
authority until the source meets the emission limits or standards
applicable to a "major" pollutant. As currently proposed, the
quarterly deviation reports will be required only if actual
deviations based upon enhanced monitoring are noted.
Furthermore, the deviation reports will be similar to excess
emissions reports currently submitted under the New Source
Performance Standards (NSPS) program and will include information
pertaining to both the emissions unit and the monitoring system.
The specific inforination required in the annual compliance
certification will be detailed in the forthcoming EM/CC
regulations. As stated in the August 1991 Public Information
Document, "the monitoring system must provide, where available, a
direct measurement of emissions, or if direct measurement is not
economical or technologically available, then the most reliable
compliance data on the most frequent basis that is
reasonable...". Currently, the quarterly deviation reports are
required to have the following information: (1) the number and
duration of deviations from the standard that are documented by
the enhanced monitoring system, (2) the reason for deviations and
the corrective/preventative action taken in response, (3) the
number and duration of incidents during which the monitoring
system was not operating or was not producing valid data and the
reasons, corrective action and preventative actions taken, (4)
basic source identification, and (5) total operating time of the
emissions unit during the reporting period.
Enhanced monitoring data will play an important role in the
verification of emission statement information. This data will
be available from sources subject to EM/CC rules.
54
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6.8 Progress Toward Attainment
The primary purpose of requiring SIP revisions is to show
compliance with goals towards bringing an area into compliance
with the NAAQS. Emission statements will assist the State and
local agencies in assessing progress along this path. In
particular, emission statements will enable an agency to quantify
actual emissions on an annual basis for comparison with SIP
projections. The ability to annually quantify actual emissions
will provide an early warning to help agencies determine if
corrective actions are required to meet SIP obligations.
6.9 Rule Effectiveness
By reporting actual emissions, the emission statements can
be analyzed against existing rules and permits to gauge where
rule effectiveness studies should be conducted. EPA has issued
separate guidance on rule effectiveness determinations.9'10
The emission statement guidance does not require sources to
submit RE adjusted emissions to the State (or appropriate local
agency) to comply with the emission statement provisions..
However, EPA requests that States submit the appropriate RE
factor at the SCC pollutant level so that the AIRS database can
accurately adjust the sources' emission estimates to reflect RE.
The AIRS database will store both RE-corrected and non RE-
corrected emissions. The AIRS system will be modified to
maintain RE information to develop consistency with SIP emission
inventory submittals in which emissions data are adjusted for
rule effectiveness.
As stated previously, EPA is making changes in the
application of RE and in the input of RE data into AIRS that
could affect emission statement reporting. Any changes in RE
55
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that apply to emission statements will be addressed in a later
guidance.
56
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7.0 FUTURE OF EMISSION STATEMENT REPORTING
The long-term plan for industry reporting requirements is to
merge requirements into a single annual submittal for permits,
compliance, annual AFS data, emission statements, and any other
applicable requirements.
The recommended emission statement data elements are
consistent, where practical, with other reporting requirements.
This consistency will assist both the EPA and the States with
consolidating data reporting and will also assist in quality
assurance and consistency of data.
57
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58
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8.0 REFERENCES
1. U.S. Environmental Protection Agency, 1985. Compilation, of
Air Pollutant Emission Factors, Volume I: Stationary Point
and Area Sources. Supplements A through D. No AP-42/
Research Triangle Park, NC. 888 pp.
2. Clean Air Act Amendments of 1990, Conference Report to
Accompany S. 1630. 101st Congress, Second Session, House of
Representatives Report 101-952. October 26, 1990.
3. Ibid.
4. Ibid.
5. Ibid.
6. U.S. Environmental Protection Agency. 1991. Office of
Administration aad Resources Management. Locational Data
Policy Implementation Guidance. February, 1992.
Publication number 220-B-92-008.
7. U.S. Environmental Protection Agency. National Air Data
Branch. AIRS User's Guide Volume IX: AFS Data Dictionary.
January 1992.
8. U.S. Environmental Protection Agency. 1991. Public
Information Document: Enhanced Monitoring and Compliance
Certification. Air docket number A-91-52. August, 1991.
9. U.S. Environmental Protection Agency, Ozone and Carbon
Monoxide Programs Branch, Office of Air Quality Planning and
Standards. 1989. Procedures for Estimating and Applying
Rule Effectiveness in Post-1987 Base Year Emission
Inventories for Ozone and Carbon Monoxide State
Implementation Plans. June, 1989. (update anticipated in
May of 1992}
10. U.S. Environmental Protection Agency. 1988. Implementation
of Rule Effectiveness Studies. Memorandum from John Seitz,
Director, Stationary Source Compliance Division, Office of
Air Quality Planning and Standards, to Regional Air Division
Directors, Office of Air Quality Planning and Standards.
March 31. 1988.
59
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APPENDIX A
Locating Sources
While locating traditional sources for inclusion in the
emission statement process will not be difficult due to previous
emission information requirements, finding the nontraditional
sources presents more of a challenge.
The firm of Dun and Bradstreet (D&B) maintains a database on
businesses in the United States. The database can be accessed by
modem through the EPA Facility and Company Tracking System
(FACTS) system maintained by OIRM. The D&B data in the FACTS
system is updated annually in June. Customized reports of the
D&B data can be created based upon numerous variables including
business size, SIC code, and location. States interested in
accessing the FACTS database should call the FACTS help line at
(800) 424-9067.
Other sources that may prove valuable for locating sources
include: State permit program and enforcement files, local
yellow pages, and business and trade listings.
A-1
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APPENDIX B
Example Certification of Data Accuracy
B-l
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SAMPLE CERTIFICATION OF DATA ACCURACY
The data presented herein represents the best available information and is true and accurate to the best of my knowledge.
Print Full Name Print Full Title
w
I
KJ
Signature Date of Signature
Telephone Number
-------
APPENDIX C
Rule Effectiveness Method Codes
DATA ELEMENT NAME: RULE EFFECTIVENESS PERCENT METHOD CODE
DESCRIPTION .... : A ONE-CHARACTER CODE USED TO IDENTIFY THE
METHOD USED TO DETERMINE RULE EFFECTIVENESS.
FORMAT : ALPHANUMERIC
LENGTH : 1'. 0
VALID VALUES ... :
C - DIRECT CALCULATION OF EMISSIONS BY SOLVENT USE, ALL
SOLVENT EMITTED IN TIME PERIOD.
D - DEFAULT VALUE (80%)
E - SOURCE IN COMPLIANCE DUE TO IRREVERSIBLE PROCESS THAT
ELIMINATES SOLVENT USE.
L - LOCAL CATEGORY SPECIFIC RULE EFFECTIVENESS FACTOR - NOT
EPA REGULATED.
M - CONTINUOUS EMISSIONS MONITORS
N - SOURCE NOT SUBJECT TO REGULATIONS
C-1
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APPENDIX D
Estimating Emissions
Annual Emissions
The basic methodologies for computing estimated annual
emissions are contained in the EPA document, Procedures for the
Preparation of Emissions Inventories for Carbon Monoxide and
Precursors of Ozone, Volume I: General Guidance for Stationary
Sources (Procedures Document). These methodologies are
discussed in this guidance document; however, this discussion is
not intended to supersede information in the Procedures Document
mentioned above. For a complete description of emission
calculations the reader should refer to the Procedures Document.
For emission statement reporting, all annual emissions should be
reported as a tons per year value. When estimating annual VOC
emissions, methane, ethane, and chloroflourocarbons are to be
excluded from the estimate because these compounds are considered
to be photochemically non-reactive (see the definition of
volatile organic compounds in the Definitions section of this
document).
Point source emission estimates can be calculated through
the use of source test data, material balances, and emission
factors. States must be available to assist sources,
particularly nontraditional sources, with the calculation of
their emission estimates.
The estimation of emissions through source test data
involves the use of test data obtained by the State or local
agency or provided by the source. The use of source test data
reduces the number of assumptions regarding the applicability of
generalized emission factors, control device efficiencies,
D-1
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equipment variations, or fuel characteristics. Most source test
reports summarize emissions for each pollutant by expressing them
in terms of a mass loading rate, an emission factor or a flue gas
concentration. Emissions estimated through source test data
should be adjusted to account for typical operating conditions,
average control equipment downtime, effects of start-up, and
other factors that affect emission rates over the year.
Emission calculations from emission factor or mass loading
rate data are rather straightforward. For example, if the source
test determined that the average VOC emission rate for the
calendar year was 12 Ibs/hour, emissions could be determined in
the following manner (emissions rate X operating data).
12 Ibs/hour X 16 hrs/day = 192 Ibs/day
192 Ibs/day X 350 days/year = 67,200 Ibs/year, or
33.6 tons per year of VOC
The emission estimate should be adjusted to include emissions
produced above the 12 Ibs/hour normal operating rate such as when
the control equipment malfunctions or an upset occurs. The
estimate should also reflect plant downtime and fugitive
emissions.
Emission calculations using test results expressed in terms
of VOC concentrations can be more complex. The Procedures
Document provides a detailed example of such an emission
calculation.
Continuous emission monitoring (CEM) can provide a more
accurate representation of emissions than a single source test
such as was used in the example above. CEM also provides
emission measurement data when control equipment malfunctions or
is not operating. A further move away from using annual stack
tests to the use of continuous monitoring data for compliance
D-2
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purposes was addressed in the CAAA in the requirement for an
Enhanced Monitoring and Compliance Certification rule that
applies to major stationary sources. It is recommended that for
sources for which continuous monitoring data is available, it
should be used to estimate emissions for emission statements
because of improved accuracy in emissions measurements.
Use of a material balance involves the examination of a
process to determine if the emissions can be estimated solely on
knowledge of specific operating parameters and material
compositions. Although the material balance is a valuable tool
in estimating emissions from many sources, its use requires that
a measure of the material being "balanced" be known at each point
throughout the process. If such knowledge is not available, and
is therefore assumed, .serious errors may result. The simplest
material balance method is to assume that all solvent consumed by
a source process will be evaporated during that process. In this
instance, in order to estimate emissions, the only information
necessary is the total amount of solvent utilized during the
appropriate time interval. Not all material balances are so
easily computed. The Procedures Document provides several
additional examples of more complicated material balance
computations. In addition, material balances cannot be applied
in some evaporation processes because the amount of material lost
is too small to be determined accurately by standard measurement
procedures. In these cases, emission factors will have to be
applied.
Emission factors are one of the most useful tools available
for estimating emissions. An emission factor is an estimate of
the quantity of pollutant released to the atmosphere as a result
of some activity. As a rule, the most reliable emission factors
are those based on numerous and representative source tests or on
accurate material balances. In the event that emission factors
are utilized in the calculation of emissions, a source must use
D-3
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emission factors that are approved by EPA or the State.
Otherwise, the source must petition the State for approval of
their emission factors. The publication, Compilation of Air
Pollutant Emission Factors, Volume 7: Stationary Point and Area
Sources, no. AP-422, contains the preferred emission factors to
use in estimating emissions. Another EPA document, AIRS Facility
Subsystem, Source Classification Codes and Emission Factor
Listing- for Criteria Air Pollutants provides emission factors for
all SCCs. Although many of the emission factors contained in
this document are derived directly from AP-42, these factors do
not supersede those listed in AP-42. However, this publication
does contain some supplemental emission .factors that AP-42
doesn't list. If the emission factor accounts for control
efficiency, both a controlled and uncontrolled emission factor
will be listed. Both of these documents can be accessed through
EPA's CHIEF bulletin board. This system serves as a
clearinghouse for the most recent information concerning emission
inventories and emission factors. Public access requires an EPA-
approved registration, a computer, a communications software
package, and a modem. For information on CHIEF, call the CHIEF
INFO information line at (919) 541-5285.
In the simplest of cases, a source's emissions can be
calculated by multiplying the appropriate emission factor by the
activity data (i.e., process rate). However, when empirical
formulas are available, more detailed computations may be needed
to estimate emissions. For example, additional computation is
required when emissions are affected by temperature, (e.g.
organic liquid storage tanks and loading of rail tank cars, tank
trucks, and marine vessels). The Procedures Document provides a
detailed example of emissions calculation for external floating
roof tanks. In addition, the Procedures Document provides an in-
depth discussion of the effect of seasonal temperature changes
upon emissions.
D-4
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All emissions, both from significant and minor processes
within the plant, need to be a part of the emission estimate. In
addition to estimating such emissions from distinct process vents
in a facility, fugitive emissions should also be included in the
estimate. Fugitive emissions are emissions that are released to
the air through a means other than stacks, vents, ducts, pipes,
or any other confined air stream. Examples of fugitive emissions
include uncontained releases from wastewater treatment, tank and
drum cleaning, miscellaneous solvent losses, and leaking valves.
D-5
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Typical Ozone Season Day Emissions
The basic methodologies for computing typical ozone season
day emissions are also contained in the Procedures Document.
Typical ozone season day emissions should be calculated for the 3
month contiguous period identified in the 1990 base year ozone
SIP inventory. For emission statement reporting, all typical
ozone season day emissions should be reported as a pounds per day
value. When VOC emission estimates are determined, methane,
ethane and chloroflourocarbons are not included in the estimate
because these compounds are considered to be photochemically
nonreactive (see the definition of volatile organic compounds in
the Definitions section of this document).
In general, the emission estimation methodologies are
analogous to the procedures for estimating annual emissions. The
major difference relates to the operating and process rate data.
Where the process rate used for calculating estimated annual
emissions is an annual rate, the process rate for typical ozone
season day emissions is a daily rate averaged over the
appropriate peak ozone season.
It is fairly straightforward and accurate for sources to
compute their typical ozone season day emissions based upon their
peak ozone season daily process rate. The peak ozone season
daily process rate is a recommended emission statement data
element.
To calculate the typical ozone season day emissions using
the peak ozone season daily process rate, the process rate is
multiplied by an EPA or State approved emission factor. If, for
example, a dry cleaning facility cleans 115 pounds of clothing
per day during the peak ozone season, the typical ozone season
day emissions are calculated by multiplying the process rate of
D-6
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115 Ibs/day by the correct emission factor. In this example, an
emission factor of 550 Ibs of VOC emissions per ton of clothes
cleaned is used, and a control efficiency of 70% is applied.
This is an uncontrolled emission factor, and the efficiency of
the source's control equipment should be factored in (multiply by
(1-control efficiency). The typical ozone season day emissions
are calculated as follows (emission factor X typical ozone season
daily process rate).
115 Ibs/day of clothes cleaned
115 * 2000 = .0575 tons/day of clothes cleaned
.0575 tons/day X 550 Ibs of VOC/ton of clothes cleaned =
31.625 pounds/day X (1-.70) =9.49 pounds of VOC emissions
during the peak ozone'season.
As with the annual emissions, significant and minor process
and fugitive emissions should be included in the estimate.
Typical ozone season day emissions must represent an average
daily estimate during the peak ozone season. In order for
sources to compute their daily process rate and emissions during
the peak ozone season," States must tell the sources what the peak
ozone season is.
Most ozone nonattainment areas will use the 3 month period
from June through August to calculate peak ozone season daily
activity rates. However, if the peak ozone season is atypical,
the appropriate 3 month period may have been determined. States
should instruct sources to use the same peak ozone season period
in emission statements that was used in the 1990 base year ozone
SIP emission inventories for the associated nonattainment area.
D-7
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1. U.S. Environmental Protection Agency. 1991. Procedures for
the Preparation of Emission Inventories for Carbon Monoxide
and Precursors of Ozone, Volume I: General Guidance for
Stationary Sources. May, 1991. Publication Number EPA-
450/4-91-016.
2. U.S. Environmental Protection Agency. 1985. Compilation of
Air Pollutant Emission Factors, Volume I: Stationary Point
and Area Sources. Supplements A through D. No AP-42,
Research Triangle Park, NC. 888 pp.
D-8
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APPENDIX E
EXCERPT FROM:
AIRS Facility Subsystem Source Classification Codes
and Emission Factor Listing
for Criteria Air Pollutants
A revised AIRS Facility Subsystem Source Classification
Code Document will be published in 1992.
E-1
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AIRS Facility Subsystem
Source Classification Codes
and Emission Factor Listing
for Criteria Air Pollutants
EPA Document Number: EPA 450/4-90-003
Prepared by the
MONITORING & REPORTS BRANCH and the
NATIONAL AIR DATA BRANCH
Technical Support Division
Office of Air Quality Planning & Standards
U.S. ENVIRONMENTAL PROTECTION AGENCY
Research Triangle Park, North Carolina 27711
MARCH 1990
E-2
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How To Use This Document:
I
U)
PART PMW SOx WOx VOC CO LEAD
Lbs/Unlt Lbs/Unlt Lbs/Unlt Lbs/Unll Lbs/Unlt Lbs/Unll Lbs/Unll Units
Process Name
^"1^ T"*-*v. /•— "'"'x
Aluminum Hydroxide Calcining^.3334^
^ * \a**J \ '*~~-~~~~~~^
By-Producl Coke Manufaturing -
Tons Coal Charged
a of CcaJ Charged
LbslUnil LIuAJni
LfcsAiril VbsAJril
bsAJrtl LbsAJnil
LbiAJnA LbsAJnil
LbsAJnil \ LbsAJnil
LbsAJniJ \ Lbs/Unil
LbsAJnil \ LbsAJnit
LbsAJnil \ LbsAJnil
^«*A
—" moEiriB ihftrn !• noornliaton tec lot
for Ihli polJutanl. thin SCO, YET
4-Di6it SIC Code
Unique SCC Number
i
Source Category Process
For Uta In
Later Edllloni
industry/Source Eaiegoi
mo an a Ih a I EPA WILL NOT d»»lop
an
-------
sec
Process PART
Name Lbs/unii
PM10
Lbs/Unll
SOx
Lbs/Unlt
NOx
Lbs/Unll
voc
Lbs/Unll
CO
Lbs/Unit
LEAD
Lbs/Unil
UNITS NOTES
EXTERNAL COMBUSTION BOILERS
EXTERNAL COMBUSTION BOILERS - ELECTRIC GENERATION -
SIC 4911 raj
Anthracite Coal - 491 1
1-01-001-01
1-01-001-02
-. Pulverized Coal
- Traveling Grate
(Overfeed) Stoker
10.0 A
9.1
2.3 A
4.8
39.0 S
39.0 S
18. 0
10.0
0
0
.07
.07
0.6
0.6
0.0133
0.0133
Tons
Tons
Burned
Burned
.Bituminous Coal -4911
1-01-002-01
1-01-002-02
1-01-002-03
1-01-002-04
1-01-002-05
1-01-002-12
1-01-002-17
- Pulverized Coal: Wet
Bottom
- Pulverized Coal: Dry
Bottom
- Cyclone Furnace
- Spreader Stoker
- Traveling Grate
(Overfeed) Stoker
- Pulveriied Coal: Dry
Bottom (Tangential)
- Atmospheric
Fluidized Bed
Combustion
7.0 A ..
10.0 A
2.0 A
60.0
16.0
10.0 A
...
2.6 A
2.3 A
0.26 A
12.0
6.0
2.3 A
...
39.0 S
39.0 S
39.0 S
39.0 S
39.0 S
39.0 S
U.O
34.0
21.0
37.0
U.O
7.5
15.0
13.0
0
0
0
0
0
0
0
.07
.07
.07
.07
.07
.07
.07
0.6
0.6
0.6
5.0
6.0
0.6
—
0.0133
0.0133
0.0133
0.0133
0.0133
—
—
Tons
Tons
Tons
Tons
Tons
Tons
Tons
Burned
Burned
Burned
Burned
Burned
Burned
Burned
Subbituminous Coal -4911
1-01-002-21
1-01-002-22
1-01-002-23
1-01-002-24
1-01-002-25
1-01-002-26
- Pulverized Coal: Uet
Bottom
- Pulverized Coal: Dry
Bottom
- Cyclone Furnace
- Spreader Stoker
- Traveling Grate
(Overfeed) Stoker
- Pulverized Coal: Dry
Bottom (Tangential)
7.0 A
10.0 A
2.0 A
60.0
16.0
10.0 A
2.6 A
2.3 A
0.26 A
12.0
6.0
2.3 A
35.0 S
35.0 S
35.0 S
35.0 S
35.0 S
35.0 S
34.0
21.0
37.0
14.0
7.5
15.0
0
0
0
0
0
0
.07
.07
.07
.07
.07
.07
0.6
0.6
0.6
5.0
6.0
0.6
0.0133
0.0133
0.0133
0.0133
0.0133
—
Tons
Tons
Tons
Tons
Tons
Tons
Burned
Burned
Burned
Burned
Burned
Burned
-------
APPENDIX F
Example Emission Statement Status Report
F-1
-------
SAMPLE FORMAT FOR
EMISSION STATEMENT STATUS REPORT
(Page 1 of 2)
Date: | j State: [
Year of Emissions: |_
Total Number of Sources Required
to Submit Emission Statements:
Total Number of Sources that:
Have submitted Emission Statements
Have not submitted Emission Statements
Total Actual VOC Emissions
(Sum of Emissions from All Sources who Submitted Emission Statements)
Non RE-Corrected. RE-Corrected
Annual Emissions: Annual Emissions:
I I Tons/year I | Tons/year
Typical Ozone Season Day Emissions: Typical Ozone Season Day Emissions:
I I Pounds/day I I Pounds/day
Total Actual NOx Emissions
(Sum of Emissions from All Sources who Submitted Emission Statements)
Nop. RE-Corrected. RE-Corrected
Annual Emissions: Annual Emissions:
I I Tons/year | [ Tons/year
Typical Ozone Season Day Emissions: Typical Ozone Season Day Emissions:
| I Pounds/day I | Pounds/day
F-2
-------
SAMPLE FORMAT FOR
EMISSION STATEMENT STATUS REPORT
(Page 2 of 2)
Sources emitting £ 500 tpy of VOC that have failed
to submit Emission Statements:
Plant Name
County
Code
AIRS ID
EPA ID
Sources emitting a 2500 tpy of NOx that have failed
to submit Emission Statements:
Plant Name
County
Code
AIRS ID
EPA ID
F-3
-------
APPENDIX G
Emission Statement Reporting Package for Traditional Sources
Appendix G is composed of 3 parts: an explanatory letter,
an example AFP644 report, and example instructions to complete
the report. These 3 elements complete the package of information
necessary for States to supply to traditional sources for
emission statement reporting.
G-1
-------
APPENDIX G
Part 1
Example State Letter to Traditional Sources
G-2
-------
Date
Air Emissions Official
Gasoline Distributors, Inc.
101 Refinery Blvd.
City, State 99999
Dear Air Emissions Official:
Under the 1990 Clean Air Act Amendments (CAAA), States are
required to revise their State Implementation Plans to include
the requirement that certain firms submit annual stationary
source emission statements to the State in which they operate.
Emission statements will provide the State with an estimate of a
source's emissions, and are required from all sources in ozone
nonattainment areas emitting [insert State cutoff, if applicable]
nitrogen oxides (NOX) or volatile organic compounds (VOC). This
requirement also applies to sources in attainment areas within
ozone transport regions which emit or have the potential to emit
50 tons per year or more of VOC or 100 tpy or more of NOX.
Based upon [cite State statutes or regulations], your firm
is required to submit an emission statement. The first emission
statement from your firm must be submitted to [insert name of
appropriate State or local agency] by [April 15 or whatever date
is required by the State]. The emission estimates must represent
the actual annual emissions of NOX and VOC for calendar year
1992. The emission estimate must include an estimate of
emissions from normal operations as well as any emissions that
may have resulted from malfunctions.
Emissions data for your firm are already on file with the
EPA. Therefore, an update of your firm's emissions data as
G-3
-------
maintained in the Environmental Protection Agency's Aerometric
Information Retrieval System (AIRS) database is sufficient. The
current AIRS emissions data (AFP644 report) for your firm is
attached for your review. Updates should be noted directly on
the form and the form must then be returned to the [insert name
of appropriate State or local agency]. Detailed instructions
regarding the update of your AFP644 report are also provided.
A certification of data accuracy must be included with your
emissions corrections to successfully comply with the emission
statement requirement. The certification of data accuracy must
state that all information being submitted is complete, true, and
accurate to the best knowledge of the certifying individual. The
certifying individual is defined to be an official of the company
who will take legal responsibility for the emission statement's
accuracy. The certifying individual's signature on the
certification of data accuracy is essential for the completeness
of the emission statement. No emission statement will be
accepted without a signed statement.
Failure to comply with the emission statement requirement
may result in a civil action, a civil penalty, or both. State
sanctions for noncompliance include [insert sanctions].
Questions about the new CAAA emission statement requirement
and emission reporting should be directed to [the appropriate
contact at the State]. This contact can be reached at: [insert
phone number].
Sincerely,
Jane Smith
Director of Air Quality
G-4
-------
APPENDIX G
Part 2
Example AFP644 Report
The example facility (plant) represented in this form is
composed of 2 stacks, 3 points, and 5 segments. Of the three
points, 2 are stacks and 1 is a tank. The first point is a stack
on a boiler that operates on distillate oil (segment 1) and
natural gas (segment 2). The second point has no stack and
includes fixed roof tanks that have breathing loss emissions
(segment 1) and working loss emissions (segment 2). The third
point is the second stack. It emits pollutants from the spray
painting of widgets (segment 1).
G-5
-------
o
I
a\
DATE: 01/29/92 AFS PIA8T EMISSIONS INVENTORY PGM: AFP644
SAMPLE OP AFS APP644 REPORT PAGE: 1
PLANT: 9999 - SAMPLE PLANT *$&•$&Mt$§S9$? : 199°
STATE: NC/37 CITY: 55000 - RALEIGH SIp""lNVENTORif"INDICATOR : 03 - CARBON MONOXIDE AND OZONE SIP INVENT
COUNTY: 183 - HAKE CO MSA: - NUMBER OF STACKS: 2 NUMBER OF POINTS: 3 NUMBER OF SEGMENTS: 5
fJVVI^'KAME: SAMPLE PLANT . LAST PLANT UPDATE : 92/01/27
APPflESfi;""": 101 MAIN STREET REGIONAL PLANNING :
pm,STATE;: RALEIGH,NC 27522 LOCAL CONTROL REGN:
AQCR : 166 INSPECTOR : ERIC JOHNSON
AMBIENT MONITORING: N SOURCE MONITORING: Y
STAtTOARO pCt)STRm:CLABSiFIC^T10N£i: ^fflajIfi^Pl^:
3714 - HOTOR VEHICLE PARTS 4 ACCESSORIES fl$p : SAMPLE PLANT
ACDiRESS : 101 HAIH STREET
SlCTVSTMCiJ: RALEIGH. HC 21622
NEDS : 9999 *
EPA ID NUMBER : NCD000555888 DUNN t BRADSTREET : DBXX81589 CDS : 99999
EMISSIONS CONTACT : JOHN SMITH, (919)541-5582
LA-TiTUPE : 36:14:12 UTM ZONE : 17 EMERGENCY CONTROL PLAN : 2 - ECAP SUBMITED
LPNGITUDE : 080:59:20 HORIZONTAL : 501.0 KM STATE DATA ELEMENT 1 :
VERTICAL : 4010.0 KM STATE DATA ELEMENT 9
USER PLANT ID : NUMBER OP EMPLOYEES : 125 PROPERTY AREA (ACRES) : 10.0
PRINCIPAL PRODUCT : AUTO PARTS
PLANT POLLUTANT:
POLLUTANT ESTIMATED UNITS ALLOWABLE UNITS POT. UNCTHL UNITS POT. CNTRL UNITS ACTUAL UCNTRL UNITS
N02 28.14000 TY 40.00000 TY 350.00000 TY 48.00000 TY
VOC 205.5638 TY 225.0000 TY 2010.0000 TY 280.0000 TY
POLLUTANT CO DAILY UNITS OZONE DAILY UNITS ADJUSTED UNITS
NO2 220.0000 PD 260.0000 PD
VOC 1650.0000 PD 1725.000 PD
PLANT COMMENT:
COMMENT COMMENT
NO.
001 E THIS IS A TEST COMMENT.
PLANT LEVEL COMMENTS ARE FOR THE PLANT AS A WHOLE.
-------
DATE: 01/29/92
AFS PLANT EMISSIONS INVENTORY
SAMPLE OF AFS AFP644 REPORT
PGM: AFP644
PAGE: 2
PLANT: 9999 - SAMPLE PLANT
STATE: NC/37 CITY: 55000 - RALEIGH
COUNTY: 183 - HAKE CO MSA: -
YEAR OF EMISSIONS : 1990
SIP INVENTORY INDICATOR : 03 - CARBON MONOXIDE AND OZONE SIP INVENT
NUMBER OP STACKS: 2 NUMBER OF POINTS: 3 NUMBER OF SEGMENTS: 5
STACK INFORMATION: 001 - STACK FOR BOILER 41
O
I
-O
STACK HEIGHT (FT) : 100
STACK DIAMETER (FT) : 5.00
PLUME HEIGHT (FT1 :
UTM HORIZONTAL : 0.00 KM
UTM VERTICAL : 0.00 KM
EXIT GAS TEMPERATURE (F) : 350
GAS FLOW RATE (ACFM) : 33000
EXIT GAS VELOCITY (FT/SEC) : 25.0
LATITUDE : 36:14:13
LONGITUDE : 080:59:19
STACK TYPE CODE: V - A STACK WITH AN UNOBSTRUCTED OPENING DISCHARGING IN A VERTE
POLLUTANT ESTIMATED UNITS MEASURED UNITS METHOD
N02 28.14000 TY
VOC 845.6000 PY
POLLUTANT CO DAILY UNITS OZONE DAILY UNITS ADJUSTED UHITS
N02
VOC
220.0000 PD
3.000000 PD
260.0000
4.000000
PD
PD
EMISSION RECORDER : N
STACK LINING : 2 - REFRACTORY
ROUGH.TERRAIN IND. : N
GEP STACK HEIGHT (FT) : 94
CEP BUILDING HEIGHT (FT) : 25
GEP BUILDING LENGTH (FT) : 85
GEP BUILDING WIDTH (FT) : 60
STACK INFORMATION: 002 - SPRAY BOOTH VENT
STACK HEIGHT (FT) : 50
'STACK DIAMETER (FT) : 2.00
PLUME HEIGHT (FT! :
UTM HORIZONTAL : 0.00 KM
UTM VERTICAL : 0.00 KM
EXIT GAS TEMPERATURE (F) : 100
GAS FLOW RATE (ACFM) : 9500
EXIT GAS VELOCITY (FT/SEC) : 50.0
LATITUDE : 36:14:12
LONGITUDE : 080:59:20
STACK TYPE CODE: H - A STACK DISCHARGING IN A HORIZONTAL OR NEARLY HORIZONTAL DI
POLLUTANT ESTIMATED UNITS MEASURED UNITS METHOD
VOC 205.0000 TY
POLLUTANT CO DAILY UNITS OZONE DAILY UNITS ADJUSTED UNITS
EMISSION RECORDER : N
STACK LINING : 1 - METAL
ROUGH TERRAIN IND. :'N
GEP STACK HEIGHT (FT) : 50
GEP BUILDING HEIGHT (FT) : 25
GEP BUILDING LENGTH (FT) : 85
GEP BUILDING WIDTH (FT) : 60
voc
1650.000 PD
1725.000
PD
-------
DATE: 01/29/92
XFS PUNT EMISSIONS INVENTORY
SAMPLE OF XFS WPS 4 4 REPORT
PGM: AFP644
PAGE: 3
PLANT: 9999 - SAMPLE PLANT
STATE: NC/37 CITY: 55000 - RALEIGH
COUNTY: 183 - WAKE CO MSA: -
YEAR OF EMISSIONS : 1990
SIP INVENTORY INDICATOR : 03 - CARBON MONOXIDE AND OZONE SIP INVENT
NUMBER OF STACKS: 2 NUMBER OF POINTS: 3 NUMBER OF SEGMENTS: 5
POINT INFORMATION: 001 E STACK t'S 001
O
I
oo
EMISSIONS POINT DESCRIPTION:
USER POINT ID :
CONFIDENTIAL INDICATOR : M
PERCENT THRUPUT1: PECjFEB: 331
f4ARrMAY: 271
JUN-AUd: 151
SBP-NOV: 25*
BUHNER TYPE MAKE : HAUCK MFC
MODEL : 4 - AIR ATOMIZER
INSTALLATION DATE : 88/02/15
CONTROL REGULATION
DESIGN CAPACITY :
OPERATING SCHEDULE:
HOURS PER DAY.: 16
DAYS PER KEEK: S
HOURS PER YEAR: 4000
DRAFT TYPE : 1 - FORCED
DRAFT CONTROL TYPE : 3 - BUTTERFLY
DRAFT CONTROL LOCATION : 4 - OTHER
990/1990/20000 SPACE HEAT
100 MILLION BTU/HOUR HEAT INPUT
25.0%
STATE DATA ELEMENT
OPERATION START TIME:
OPERATION END TIME :
0600
2200
POLLUTANT ESTIMATED UNITS STATE DEF'D UNITS MEASURED UNITS METHOD
NO2 28.14000 TY 28.14000 TY
VOC 845.6000 PY 845.6000 PY
SIP YEAR YEAR
POLLUTANT CO DAILY UNITS OZONE DAILY UNITS ADJUSTED UNITS LIMIT UNITS LIMIT DESCRIPTION RULE REG MOD
N02 220.0000 PD 260.0000 PD
VOC 3.000000 PD 4.000000 PD
POINT SEGMENT INFORMATION: 001 E/01 (STACK 001) - »2 OIL FOR BOILER »1
SOURCE CLASSIFICATION CODE: 1020050* - INDUSTRIAL BOILER - DISTILLATE OIL
- Grades 1 and 2 Oil
ANNUAL FUEt> PRQCE3S: RATE : 1400 1000 Gallon* Burned CONFIDENTIAL INDICATOR: N
MAXIMUM OPERATION RATE PER HOUR: 0.715 USDS
-------
DATE: 01/29/92
AFS PLANT EMISSIONS INVENTORY
SAMPLE OF MS AFP644 REPOUT
PGM: AFP644
PAGE: 4
PLANT: 9999 - SAMPLE PLANT
STATE: NC/37 CITY; 55000 - RALEIGH
COUNTY: 183 - HAKE CO MSA: -
YEAR OF EMISSIONS : 1990
SIP INVENTORY INDICATOR : 03 - CARBON MONOXIDE AND OZONE SIP INVENT
NUMBER OF STACKS: 2 NUMBER OF POINTS: 3 NUMBER OF SEGMENTS: 5
POINT SEGMENT INFORMATION: 001 E/01 (STACK 001) - #2 OIL FOR BOILER »t
POLLUTANT:
Q
I
VO
1102
VOC
METHOD
8 - XFS HATIOHAL EMISSION
8 - AFS NATIONAL EMISSION
EMISSIONS / UNITS
ESTIMATED : 14.00000 TY
OZONE: DAILY: 120.0000 PD
CONTROL : EQUIPMENT:
PRIMARY : 065 - CATALYTIC REOOCTIOH
SECONDARY: 024 - HODIF. FURNACE/BURNER
RULE EFFECTIVENESS: 80% METHOD : D - DEFAULT VALUE (80%)
SIP RULE IN 1'1-AOi : Y YEAR HEGULATEU: 8B YEAR LAST
TRACE ELEMENT : 0.0000000% METHOD:
EMISSIONS / UNITS / METHOD
ESTIMATED : .1400000 TY 8 - AFS NATIONAL EMISSION
OZONE"DAILY: 1.200000 PD 8 - AFS NATIONAL EMISSION
eOHTRQt. EQUIPMENT:
PRIMARY. : 019 - CATALYTIC AFTERBURNER
SECONDARY: 000 - NO EQUIPMENT
RULE EFFECTIVENESS: 80% METHOD
SIP RULE IN PLACE
TRACE ELEMENT
EMISSION FACTOR / ORIGIN / SOURCE
FACTOR (COHPUTER-C 20.0
FACTOR (COHPOTER-C
D - DEFAULT VALUE (80%)
Y YEAR REGULATED: 68 YEAR LAST
0.0000000% METHOD:
; 90.0001 ADJUSTED EFFICIENCY: 0.000%
METHOD: 4 - ENGINEERING ESTIMATE (GUESS)
ADJ METHOD:
MODIFIED : SEASONAL ADJUSTMENT FACTOR:
SDE8:
EMISSION FACTOR / ORIGIN / SOURCE
FACTOR (COHPUTER-C O.Z
FACTOR (COMPUTER -C
EFFICIENCY: 70.000% ADJUSTED EFFICIENCY: 0.000%
METHOD: 4 - ENGINEERING ESTIMATE (GUESS)
ADJ METHOD:
MODIFIED : SEASONAL ADJUSTMENT FACTOR:
SDE8:
POINT SEGMENT INFORMATION: 001 E/02 (STACK 001) - NATURAL GAS FOR BOILER #1
SOURCE CLASSIFICATION CODE: 10200602 - INDUSTRIAL BOILER - NATURAL GAS
- 10-100 MMBtu/Hr
ANNJJAL FUEL: ^ROCESS RATE : 202 Million Cubic Feel Burned
MAXIMUM OPERATION RATE PER HOUR: 0.100
PEAK CO SEASON DAILY PROCESS RATE : 1
PEAK OZONE SEASON PAILY PROCESS RATE: 1
FUEL DATA: SULFUR: 0.000% ASH:
ASH/SULFUR ORIGIN:
CONFIDENTIAL INDICATOR: N
MSDS (YR):
SDE6 :
O.OOt
TANK DATA:
VAPOR PRESSURE : 0.0000 PSIA
VAPOR MOL. HT. : 0 LB/LB MOLE
PEAK OZONE SEASON VAPOR PRESSURE
C - CALCULATED .
C - CALCULATED
HEAT CONTENT: 1030.00 MMBTU - Million Cubic Feet Burned
ASH/SULFUR SOURCE: SUPPLIER:
SOLVENT DATA: CONTROL EQUIPMENT:
PURCHASED (GAL) : 0 COST : 14000.00
REPROCESSED (GAL): 0 INSTALLATION DATE: 88/05/20
0.0000 PSIA
SDE7
-------
DATE: 01/29/92
AFS PLANT EMISSIONS INVENTORY
SAMPLE OF ATS AFP644 REPOST
PGM: AFP644
PAGE; 5
PLANT: 9999 - SAMPLE PLANT
STATE: NC/37 CITY: 55000 - RALEIGH
COUNTY: 183 - HAKE CO MSA: -
YEAR OF EMISSIONS : 1990
SIP INVENTORY INDICATOR : 03 - CARBON MONOXIDE! AMD OZONE 6IP INVENT
NUMBER OF STACKS: 2 NUMBER OP POINTS: 3 NUMBER OF SEGMENTS: 5
POINT-SEGMENT INFORMATION-. 001 E/02 (STACK 001 > - NATURAL GAS FOR BOILER
POLLUTANT:
H02
O
I
voc
METHOD
8 - AFS NATIONAL EMISSION FACTOR (COHPUTER-C
• 8 - AFS NATIONAL EMISSION FACTOR (COHPUTER-C
EMISSIONS / UNITS
ESTIMATED : 14.14000 TY
OZONE DAILY: 140.0000 PD
CONTROL EQUIPMENT:
PRIMARY : OSS - CATALYTIC REDUCTION
SECOMDPvRX: 024 - HODIF. FURNACE/BURNER
RULE EFFECTIVENESS: 80 % METHOD : D - DEFAULT VALUE (80%)
StP RULE IN PLACE : Y YEAR REGULATED: 88 YEAR LAST MODIFIED :
TRACE ELEMENT : 0.0000000* METHOD:
UNITS / METHOD
TY 6 - AFS NATIONAL EMISSION FACTOR (COHPUTER-C
PD 8 - AFS NATIONAL EMISSION FACTOR (COHPUTER-C
tMISSrON FACTOR
140.0
/ ORIGIN / SOURCE
EMISSIONS /
ESTIMATED : .2828000
OZONE DAILY.: 2.800000
CONTROL EQUIPMENT:
PRIMARY : 019 - CATALYTIC AFTERBURNER
SECONDARY: 000 - HO EQUIPMENT
80 % METHOD : D - DEFAULT VALUE (80*1
EFFICIENCY: 90.0001 ADJUSTED EFFICIENCY: 0.000%
METHOD: 4 - ENGINEERING ESTIMATE (GUESS)
ADJ METHOD:
: SEASONAL ADJUSTMENT FACTOR:
SDE8:
EMISSION FACTOR / ORIGIN / SOURCE
2.8
RULE EFFECTIVENESS:
SIP RULE IN PLACE
TRACE ELEMENT
EFFICIENCY.:
METHOD:
ADJ METHOD:
Y YEAR REGULATED: 88
0.00000001 METHOD:
YEAR LAST MODIFIED
70.0001 ADJUSTED EFFICIENCY: 0.000%
4 - ENGINEERING ESTIMATE (GUESS)
SEASONAL ADJUSTMENT FACTOR:
SDE8:
POINT INFORMATION: 002 E
EMISSIONS POINT DESCRIPTION:
USER POINT ID :
CONFIDENTIAL INDICATOR : N
PERCENT THRUPUT: DEC-PEB
MAR-MAY
JUN-AUG
BURNER TYPE MAKE
MODEL
INSTALLATION DATE
sot
20%
10%
SEP-NOV: 20%
HAUCK MFC
4 - AIR ATOMIZER
88/02/15
CONTROL REGULATION
DESIGN CAPACITY
OPERATING SCHEDULE
HOURS PER DAY:
DAYS PER KEEK
HOURS PEP YEAR
DRAFT TYPE : 1 - FORCED
DRAFT CONTROL TYPE : J -
DRAFT CONTROL LOCATION :
990/1990/2000 SPACE HEAT
12 THOUSAND BARRELS
00.0%
STATE DATA
24
7
8760
OPERATION START TIME:
OPERATION END TIME :
0600
2200
ELEMENT 2:
3:
4:
5:
BUTTERFLY
4- OTHER
-------
DATE: 01/29/92
AFS PLANT EMISSIONS INVENTORY
GAHPLE OF AFS ATP644 REPORT
PCM: AFP644
PAGE: 6
PLANT: 9999 - SAMPLE PLANT
STATE: NC/37 CITY: 55000 - RALEIGH
COUNTY: 183 - MAKE CO MSA: -
YEAR OF EMISSIONS : 1990
SIP INVENTORY INDICATOR : 03 - CARBON MONOXIDE AND OZONE SIP INVENT
NUMBER OP STACKS: 2 NUMBER OF POINTS: 3 NUMBER OF SEGMENTS: 5
POINT INFORMATION: 002 E
0
I
POLLUTANT ESTIMATED UNITS STATE DEF'D UNITS MEASURED UNITS METHOD
VCX: 282.0000 PY 282.0000 PY
POLLUTANT CO DAILY UNITS OZONE DAILY UNITS ADJUSTED UNITS LIMIT UNITS LIMIT DESCRIPTION
SIP YEAR YEAR
RULE REG MOD
VOC
.4700000 PD .5600000
PD
POINT SEGMENT INFORMATION: 002 E/01 (NO STACK)
SOURCE CLASSIFICATION CODE: 40301019 - PETROLEUM PRODUCT STORAGE - FIXED ROOF TANKS (VARYING SIZES)
- DISTILLATE FUEL 12: BREATHING LOSS (67000 BBL. TANK SIZE) FIXED ROOF
: 504 1000 Gallons Storage Capacity CONFIDENTIAL INDICATOR:
ANNUAL FUEL PROCESS RATE :
MAXIMUM OPERATION RATE PER HOUR:
PEAK CO SEASON DAILY PROCESS RATE
PEAK OZONE SEASON DAILY PROCESS RATE
FUEL DATA: SULFUR: 0.000% ASH:
ASH/SULFUR ORIGIN:
TANK DATA:
VAPOR PRESSURE : 0.0000 PSIA
VAPOR MOL. WT. : 130 LB/LB MOLE
PEAK OZONE SEASON VAPOR PRESSURE :
POLLUTANT:
0.000
MSDS (YR):
1 C - CALCULATED
1• C - CALCULATED
O.OOi HEAT CONTENT:
ASH/SULFUR SOURCE:
SOLVENT DATA:
PURCHASED (GAL) :
REPROCESSED
-------
DATE: 01/29/92
ATS PUNT EMISSIONS INVENTORY
SAMPLE OF AFS APP644 REPORT
PGM: AFP644
PAGE: 7
PLANT: 9999 - SAMPLE PLANT
STATE: HC/37 CITY; 55000 - RALEIGH
COUNTY: 183 - HAKE CO MSA: -
YEAR OF EMISSIONS : 1990
SIP INVENTORY INDICATOR : 03 - CARBON MONOXIDE AND OZONE SIP INVENT
NUMBER OF STACKS: 2 NUMBER OF POINTS: 3 NUMBER OF SEGMENTS: 5
POINT.SEGMENT INFORMATION: 002 E/01 (NO STACK)
SIP RULE IN PLACE
TRACE ELEMENT
N YEAR REGULATED:
0.0000000% METHOD:
YEAR LAST MODIFIED
SEASONAL ADJUSTMENT FACTOR:
SDE8:
POJNT SEGMENT INFORMATION: 002 E/02 [NO STACK)
I
NJ
SOURCE CLASSIFICATION CODE: 40301021 - PETROLEUM PRODUCT STORAGE
- DISTILLATE FUEL V2:WORKING
ANNUAL FUEL PROCESS:RATE : 1500 1000 Gallon! Throughput
MAXIMUM OPERATION RATE PER HOUR: 0.715
PEAK CO SEASOH DAILY PROCESS RATE ;
PEAK OZONE SEASON DAILY PROCESS -RATE;
FUEL DATA: SULFUR: 0.000% ASH:
ASH/SULFUR ORIGIN:
TANK DATA:
VAPOR PRESSURE : 0.0000 PSIA
VAPOR MOL. WT. : UO LB/LB MOLE
PEAK OZONE SEASON VAPOR PRESSURE :
POLLUTANT:
0.00%
C - CALCULATED
C - CALCULATED
HEAT CONTENT:
ASH/SULFUR SOURCE:
SOLVENT DATA:
PURCHASED (GAL) :
REPROCESSED (GAL):
0.0000 PSIA
FIXED ROOF TANKS (VARYING SIZES)
IOSS (TANK DIAMETER INDEPENDENT) FIXED HOOF
CONFIDENTIAL INDICATOR:
USDS (YR):
SDE6 :
0.00 MMBTU - 1000 Gallons Throughput
SUPPLIER:
CONTROL EQUIPMENT:
0 COST : 6500.00
0 INSTALLATION DATE: 87/11/22
SDE7
VOC
EMISSIONS / UNITS / METHOD
ESTIMATED : .0150000 .TY 9 -
OZONE DAILY: .0800000 PD 9 -
CONTROL EflUIP-MENT:
PRIMARY : 047 - VAPOR RECOVERY SYSTEM
SECOMDARK: 000 - NO EQUIPMENT
RULE EFFECTIVENESS: % METHOD :
StP RULE IN PLACE : N YEAR REGULATED:
TRACE ELEMENT : 0.0000000% METHOD:
EMISSION.FACTOR / ORIGIN / SOURCE
USER-SUPPLIED EMISSION FACTOR (COMPUTER-
USER-SUPPLIED EMISSION FACTOR (COMPUTER-
EFJflCIENCJf:
METHOD:
ADJ METHOD:
.02
LOCAL
YEAR LAST MODIFIED
9S.OOOI ADJUSTED EFFICIENCY: 0.000%
4 - ENGINEERING ESTIMATE (GUESS)
SEASONAL ADJUSTMENT FACTOR:
SDE8:
POINT INFORMATION: 003 E STACK »'S 002
EMISSIONS POINT DESCRIPTION:
USER POINT ID :
CONFIDENTIAL INDICATOR : N
CONTROL REGULATION : 990/1990/20000
DESIGN CAPACITY : 5 TONS PER DAY
SPACE HEAT : 00.0%
-------
DATE: 01/29/92
ATS PLANT EMISSIONS INVENTORY
SAMPLE OF XFS AFP644 REPORT
PGM: AFP644
PAGE: 6
PLANT: 9999 - SAMPLE PLANT
STATE: NC/37 CITY: 55000 - RALEIGH
COUNT*: 183 - WAKE CO MSA: -
YEAR OF EMISSIONS : 1990
SIP INVENTORY INDICATOR : OJ - CARBON MONOXIDE AMD O2ONE SIP INVENT
NUMBER OF STACKS: 2 NUMBER OF POINTS: 3 NUMBER OF SEGMENTS: 5
POINT INFORMATION: 003 E STACK »'S 002
PERCENT TJtRUPUTr-rBBCrWSB: 221
MARrMAY: 231
3UNrAUG: 281
SE?r«OV: 221
BURNER TYPE HAKE : HAUCK MFC
MODEL : 3 - STEAM ATOMIZER
INSTALLATION DATE : 88/02/15
OPERATING .iSCIlEDULB:
16
DAYBsPERJWEEK: 5
DRAFT TYPE : 3 - NATURAL
DRAFT CONTROL TYPE : 4 - GUILLOTINE
DRAFT CONTROL LOCATION : 2 - BREECHING
OPERATION START TIME: 0600
OPERATION END TIME : 2200
STATE DATA ELEMENT 2:
1:
4:
5:
POLLUTANT ESTIMATED UNITS STATE DEF'D UNITS MEASURED UNITS METHOD
VOC 205.0000 TY 205.0000 TY
POLLUTANT CO DAILY UNITS O10NE DAILY UNITS ADJUSTED UNITS LIMIT UNITS LIMIT DESCRIPTION
SIP YEAR YEAR
RULE REG MOD
O
I
U)
VOC
1650.000 PD
1725.000
PD
POINT SEGMENT INFORMATION: 003 E/01 (STACK 002) - SPRAY PAINTING OF HIDCETS
SOURCE CLASSIFICATION CODE: 40202501
ANNUAL FUEL PROCESS RATE :
MAXIMUM OPERATION RATE PER HOUR:
PEAK CO SEASON DAILY PROCESS RATE
PEAK OiOHE SEASOK: DAXLY PROCESS RATE
FUEL DATA: SULFUR: 0.000* ASH:
ASH/SULFUR ORIGIN:
TANK DATA:
VAPOR PRESSURE : 0.0000 PSIA
VAPOR MOL. WT. : 0 LB/LB MOLE
PEAK OZONE SEASON VAPOR PRESSURE :
POLLUTANT:
- SURFACE COATING OPERATIONS - MISCELLANEOUS METAL PARTS
- Coating Operation
420 Tons Solvent in Coating
0.165
: 2 I - USER INPUT
2 I - USER INPUT
0.00% HEAT CONTENT:
ASK/SULFUR SOURCE
SOLVENT DATA:
PURCHASED (GAL) :
REPROCESSED (GAL):
0.0000 PSIA
CONFIDENTIAL INDICATOR:
MSDS (YR):
SDE6 :
0.00 MMBTU - Tons Solvent in Coating
SUPPLIER:
CONTROL EQUIPMENT:
0 COST : 4000.00
0 INSTALLATION DATE: 86/01/10
SDE7
VOC
EMISSIONS / UNITS / METHOD
ESTIMATED : 205 TY 2 -
OZONE DAIUt: 1725 PD 2 -
LIMIT " : 1500 PD
CONTROL EQUIPMENT:
PRIMARY : 048 - ACTIVATED CARBON ADSORPTION
SECONDARY: 000 - NO EQUIPMENT
RULE EFFECTIVENESS: 80* METHOD : D - DEFAULT VALUE (80»)
EMISSION FACTOR / ORIGIN / SOURCE
MATERIAL BALANCE H/ KNOWLEDGE OF PROCESS
MATERIAL BALANCE »f KNOWLEDGE OF PROCESS
EFFICIENCY: 50.0001 ADJUSTED EFFICIENCY: O.OOOt
METHOD: 2 - TESTED EFFICIENCY, BASED ON OTHER
ADO METHOD:
SIP RULE IN PLACE
TRACE ELEMENT
Y YEAR REGULATED: 88
0.0000000* METHOD:
YEAR LAST MODIFIED
SEASONAL ADJUSTMENT FACTOR:
SDE8:
-------
APPENDIX G
Part 3
Example Instructions for Revision of the AFP644 Report
for Emission Statement Reporting
The AFP644 report provides information on your facility,
including emission data at the plant, point, and segment level.
The length of your facility's report will vary depending upon the
'number of points/ stacks, and segments and the number of
pollutants emitted. Therefore, it is not possible to provide the
exact location of the fields to be updated. These instructions
will describe the fields that are required for emission statement
reporting and provide the exact field name in uppercase text
enclosed in quotation marks. [In addition, the (State or local
agency) has highlighted the fields that your facility is required
to review] .
If your facility has added new points or segments during the
last year, the new information can be provided .to the State by
requesting the Emission Statement Initial Reporting Form for New
and Modified Sources. To request this form contact [insert
appropriate State or local contact and telephone number].
In order to comply with the [insert State statute or
regulation] for emission statement reporting, the following
information must be reviewed and updated, where appropriate. The
same information is required for each point and segment at the
facility. There-fore, careful attention should be paid to the
point and segment descriptors in the report to ensure that the
data are entered correctly for each point and segment. Any
changes to the information should be noted directly on the report
by striking the old information with one solid line and writing
the correct information to the right of the outdated information.
In addition, a signed and dated certification of data accuracy
must be included with the revised report.
For assistance with calculating your emission statement
data, contact [insert State or local contact] at [telephone
number] .
I. Plant Level Emission Data
1 • Source Identification: The fields to be reviewed are: plant
physical location and plant mailing address. The mailing
address information is differentiated from the physical
location information by the heading "MAILING ADDRESS:". The
physical location, fields are: "PLANT NAME", "ADDRESS", and
"CITY, STATE". The mailing address fields are: "NAME",
"ADDRESS", and "CITY, STATE".
G-14
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2. Calendar year of emissions: Correct the "YEAR OF EMISSIONS"
field to reflect the appropriate year of the emissions data.
3. SIC (Standard Industrial Classification) Code: Listed under
"STANDARD INDUSTRIAL CLASSIFICATIONS", check that the SIC
codes present are consistent with the type of economic
activity in which the facility is engaged. SIC codes and
their descriptions are listed in the Standard Industrial
Classification Manual, published by the Office of Management
and Budget. Depending upon its operation, your facility may
have more than one SIC code; up to three separate codes may
be entered.
4. Latitude and Longitude: The locational fields to be
reviewed are: "LATITUDE" and "LONGITUDE".
II. Point Level Emission Data
1. Percentage Annual Throughput: Termed "PERCENT THROUGHPUT",
The percent of annual throughput achieved in the seasons
specified ("DEC-FEE", "MAR-MAY", "JUN-AUG", and "SEP-NOV").
The first season (DEC-FEB) will actually encompass 2
calendar years (e.g., DEC '92 - FEE '93). However, the
percentages should not total greater than 100%. Annual
throughput can represent the amount of fuel used, the amount
of solvent consumed, or the amount of product produced.
2. Normal Operating Schedule: The annual average for the days
per week, hours per day, and hours per year that the
facility operates. The heading for the data is "OPERATING
SCHEDULE:", the field names are: "HOURS PER DAY", "DAYS PER
. WEEK", and "HOURS PER YEAR".
III. Segment Level Emissions Data
A source classification code (SCO is an EPA identifier for a
specific segment. The SCC is provided by the State and is
displayed on the report under the field "SOURCE CLASSIFICATION
CODE". The SCC and description are essential information for
maintaining your facility's emission data. Each SCC defines a
segment at your facility. Be certain that the information you
are providing at the segment level is specific to the SCC listed
for that segment on the AFP644 report.
1• Annual Process Rate: This number represents the amount of
product throughput, the amount of solvent consumed, or the
amount of fuel burned. The units for the annual process
rate depend upon the specific SCC. When updating the
"ANNUAL PROCESS RATE" field, be certain that the units
represented by the estimate are the same as noted on the
G-15
-------
report.
2. Peak Ozone Season Dally Process Rate: The average daily
process rate during the peak ozone season. The ozone season
is defined to be the period of the year during which the
conditions for the formation of ozone is most favorable.
The peak ozone season for the region in which your facility
is located is [insert appropriate peak ozone season]. The
peak ozone season covers a three month period during which
most ozone exceedances occur, while the ozone season can
extend much longer. The process rate should be determined
as above, except averaged to represent a day during the peak
ozone season instead of the annual total. The correct
reporting units should be determined as outlined above. The
information should be entered in the "PEAK OZONE SEASON
DAILY PROCESS RATE" field.
3. Pollutant Specific Data: Pollutant specific data are
required for the following pollutants: volatile organic
compounds (VOC) and oxides of nitrogen (NOx) [insert
additional pollutants, if applicable]. VOC and NOx have
been determined to be significant contributors to the
formation of ozone. Therefore, data on the sources of these
pollutants are necessary to assist in State air quality
planning. [The additional pollutants are required to
coordinate State reporting requirements. By providing data
for these pollutants, your facility will avoid duplicating
your required emission reporting efforts.] The same data
are required for each of the pollutants. The pollutant data
are provided under the heading "POLLUTANT". The field for
NOX emissions on the AFP644 report is marked "NO2", however,
NO, emissions (which include both NO and NO2) are the
emissions that need to be entered.
3A. Estimated Actual Annual Emissions: Actual emissions should
represent the actual emissions for the source for the
calendar year, including upsets, downtime, and fugitive
emissions. Emissions from significant and minor processes
within the plant must be part of the emissions estimate.
When VOC emission estimates are determined, methane, ethane
and chloroflourocarbons are not included in the estimate
because these compounds are considered to be photochemically
nonreactive. Units must be in tons of pollutant emitted per
year. The estimated actual annual emissions should be
entered in the "ESTIMATED" field for each of the pollutants
listed, in the "EMISSIONS" column. The "UNITS" column
should be checked to make sure that it accurately denotes
tons per year (TY). Actual emissions can be derived in a
number of ways. Emissions can be estimated based upon any
of the EPA's acceptable methods as- detailed by the following
emissions method codes.
G-16
-------
Estimated Emissions Method Code: This code denotes the
method used to calculate your facility's estimated actual
annual emissions. The correct method code should be noted
in the "ESTIMATED" field's "METHOD" column. Valid codes are
as follows:
1 - USER CALCULATED BASED ON SOURCE TEST OR OTHER EMISSION
MEASUREMENTS.
2 - USER CALCULATED BASED ON MATERIAL BALANCE USING
ENGINEERING KNOWLEDGE OF THE PROCESS.
3 - USER CALCULATED BASED ON AP-42 EMISSION FACTOR (OR SCC
EMISSION FACTOR).
4 - USER CALCULATED BY BEST ENGINEERING JUDGEMENT
5 - USER CALCULATED BASED ON A STATE OR LOCAL AGENCY
EMISSION FACTOR.
6 - NEW CONSTRUCTION, NOT YET OPERATIONAL. EMISSIONS ARE
ZERO.
7 - SOURCE CLOSED; OPERATION CEASED. EMISSIONS ARE ZERO
8 - COMPUTER CALCULATED BASED ON STANDARD EMISSION FACTOR.
(SCC EMISSION FACTOR FILE)
9 7 COMPUTER CALCULATED BASED ON OTHER APPROVED EMISSION
FACTOR.
All emissions calculated by a facility will be denoted by
codes 1 through 5. Codes 8 and 9 represent emissions that
were calculated by the EPA's data base system.
Emission Factor; The emission factor used to compute the
estimated annual emissions. If an emission factor was used
in the computation, it should be entered in the "ESTIMATED"
field's "EMISSION FACTOR" column. In the event that
emission factors are utilized in the calculation of
emissions, a source must use emission factors that are
approved by EPA or the State. Otherwise, the source must
petition the State for approval of their emission factors.
3B. Typical Ozone Season Day Emissions: These emissions must be
supplied in pounds per day and must represent actual
emissions during the peak ozone season. As mentioned under
estimated actual annual emissions, when estimating VOC
emissions, methane, ethane, and chloroflourocarbons are not
to be included in the estimation. To calculate the typical
ozone season day emissions, the throughput for a typical
ozone season day must be determined.. The peak ozone season
for the region in which your facility is located is [insert
• peak ozone season]. The throughput should be determined as
previously discussed. Actual emissions can be derived in a
number of ways. Acceptable EPA methods are the same as
those listed above. Estimates must account for both
significant and minor process emissions, and fugitive
emissions should also be included in the emissions report if
applicable. The typical ozone season day emissions should
G-17
-------
be entered in the "OZONE DAILY" field's "EMISSIONS" column.
Also, the "UNITS" column should be checked to ensure that it
correctly reflects pounds per day (PD).
Estimated Emissions Method Code: The emission method codes
are identical to the method codes presented in 3A. The
typical ozone season day emission method code should be
entered in the "OZONE DAILY" field's "METHOD" column.
Emission Factor; The EPA or State approved emission factor
used to compute the typical ozone season day emission
estimate. If an-emission factor was used in the
computation, it should be entered in the "OZONE DAILY"
field's "EMISSION FACTOR" column.
G-18
-------
3C.
000
001
002
003
004
005
006
007
008
009
010
011
012
013
014
015
016
017
018
019
020
021
022
023
024
025
026
054
Control Equipment Identification Code: Control equipment is
used to limit the emission of pollutants to the atmosphere.
Numerous types of control equipment may be in place at a
facility. For emission statement reporting, your facility
is required to report the primary and secondary control
equipment codes. The following list details the control
equipment codes for different control equipment. .For more
information on the correct code for the control equipment at
your facility, contact [insert appropriate State or local
contact and telephone number]. The control equipment
information should be entered under the "CONTROL EQUIPMENT:"
heading, in the "PRIMARY" and "SECONDARY" fields. Valid
codes are as follows:
NO EQUIPMENT 027
WET SCRUBBER HIGH EFFICIEN. 028
WET SCRUBBER MED EFFICIEN. 029
WET SCRUBBER LOW EFFICIEN. 030
GRAVITY COLL HIGH EFFICIEN. 031
GRAVITY COLL MED EFFICIEN. 032
GRAVITY COLL LOW EFFICIEN. 033
CENTRIF COLL HIGH EFFICIEN. 034
CENTRIF COLL MED EFFICIEN. 035
CENTRIF COLL LOW EFFICIEN. 036
ELECTRO PREC HIGH EFFICIEN. 037
ELECTRO PREC MED EFFICIEN. 038
ELECTRO PREC LOW EFFICIEN. 039
GAS SCRUBBER, GENERAL 040
MIST ELIMINATOR HIGH VELOC. 041
MIST ELIMINATOR LOW VELOC. 042
FABRIC FILTER HIGH TEMP. 043
FABRIC FILTER MEDIUM TEMP. 044
FABRIC FILTER LOW TEMP. 045
CATALYTIC AFTERBURNER 046
CAT. AFTERBURN - HEAT EXCH. 047
DIRECT FLAME AFTERBURN 048
D.F. AFTERBURN - HEAT EXCH. 049
.FLARING 050
MODIF FURNACE/BURNER DESIGN 051
STAGED COMBUSTION 052
FLUE GAS RECIRCULATION 053
PROCESS ENCLOSED 084
REDUC COMBUST.- PREHEAT
STEAM OR WATER INJECTION
LOW-EXCESS - AIR FIRING
FUEL - LOW NITROGEN CONTENT
AIR INJECTION
AMMONIA INJECTION
CONTRL OF % 02 IN COMB.AIR
WELL.-LORD/SODIUM SULF SCRB
MAGNESIUM OXIDE SCRUBBING
DUAL ALKALI SCRUBBING
CITRATE PROCESS SCRUBBING
AMMONIA SCRUBBING
CATAL, OXID-FLUE GAS DESULF
ALKALIZED ALUMINA
DRY LIMESTONE INJECTION
WET LIMESTONE INJECTION
SULF ACID PLNT-CONTACT PROC
SULF ACID PLNT-DBL CNT PROC
SULFUR PLANT
PROCESS CHANGE
VAPOR RECOVERY SYSTEM
ACTIVATED CARBON ADSORPTION
LIQUID FILTRATION SYSTEM
PACKED-GAS ABSORBION COLUMN
TRAY-TYPE GAS ABSORB COLUMN
SPRAY TOWER
VENTURI SCRUBBER
ACTIVATED CLAY ADSORPTION
G-1 9
-------
3C. Control Equipment Identification Code: (cont.)
ACTIVATED CLAY ADSORPTION
WET CYCLONIC SEPARATOR
WATER CURTAIN
NITROGEN BLANKET
CONSERVATION VENT
BOTTOM FILLING
CONVERSION TO VARIABLE
VAPOR SPACE TANK
CONVERSION TO FLOATING
ROOF TANK
CONVERSION TO PRESSURIZED
TANK
SUBMERGED FILLING
UNDERGROUND TANK
WHITE PAINT
VAPOR LOCK BALANCE RECOVERY
SYSTEM
INSTALLATION OF SECONDARY
SEAL FQR EXTERNAL FLOATING
ROOF TANK
MOVING BED DRY SCRUBBER
MISCELLANEOUS CONTROL
DEVICES
HIGH EFFICIENCY PARTICULATE
AIR FILTER
054 - PROCESS ENCLOSED 084 -
055 - IMPINGEMENT PLATE SCRUBBER 085 -
056 - DYNAMIC SEPARATOR (DRY) 086 -
057 - DYNAMIC SEPARATOR (WET) 087 -
058 - MAT OR PANEL FILTER 088 -
059 - METAL FABRIC FILTER SCREEN 089 -
060 - PROCESS GAS RECOVERY 090 -
061 - DUST SUPPRESS - WATER SPRAY
062 - D.S.- CHEM STAB./WET AGENTS 091 -
063 - GRAVEL BED FILTER
064 - ANNULAR RING FILTER 092 -
065 - CATALYTIC REDUCTION
066 - MOLECULAR SIEVE 093 -
067 - WET LIME SLURRY SCRUBBING 094 -
068 - ALKALINE FLY ASH SCRUBBING 095 -
069 - SODIUM CARBONATE SCRUBBING 096 -
070 - SODIUM-ALKALI SCRUBBING
071 - FLUID BED DRY SCRUBBER 097 -
072 - TUBE AND SHELL CONDENSER
073 - REFRIGERATED CONDENSER
074 - BAROMETRIC CONDENSER 098 -
075 - SINGLE CYCLONE 099 -
076 - MULTIPLE CYCLONE
W/O FLY ASH REINJECTION 101 -
078 - BAFFLE
079 - MULTIPLE CYCLONE
W/ FLY ASH REINJECTION
080 - CHEMICAL OXIDATION
081 - CHEMICAL REDUCTION
082 - OZONATION
083 - CHEMICAL NEUTRALIZATION
3D. Control Equipment Efficiency: The percent effectiveness of
the control device(s). It represents the actual total
control efficiency achieved by the control device(s). The
actual efficiency should reflect control equipment downtime
and maintenance degradation. If the actual control
efficiency is unavailable, the design efficiency or control
efficiency limit imposed by a permit should be used. The
control equipment efficiency should be entered in the
"EFFICIENCY" field.
In addition, the capture efficiency must be taken into
account when determining control efficiency. Capture
efficiency is a measure of the volume of pollutant captured
or recovered relative to the volume of pollutant generated.
The entire emission stream may not always pass through
the control equipment. A certain percentage of emissions
may escape as fugitive emissions and are therefore not
controlled, and the-calculated emissions must reflect this.
G-20
-------
APPENDIX H
Emission Statement Reporting Package for Nontraditional Sources
Appendix H is composed of 3 parts: an explanatory letter,
an example Emission Statement Initial Reporting Form, and example
instructions. These 3 elements complete the package of
information necessary for States to supply to nontraditional
sources for emission statement reporting.
H-1
-------
APPENDIX H
Part 1
Example State Letter to Nontraditional Sources
H-2
-------
Date
Owner/Operator
Fresh Coat Paint, Inc.
123 Main St.
City, State 99999
Dear Owner/operator:
Under the 1990 Clean Air Act Amendments (CAAA), States are
required to revise their State Implementation Plans to include the
requirement that certain firms submit annual stationary source
emission statements to the State in which they operate. Emission
statements will provide the State with an estimate of a source's
emissions, and are_ required from all sources in ozone nonattainment
areas emitting [.insert State cutoff, if applicable] nitrogen oxides
(NOX) or volatile organic compounds (VOC). The requirement also
applies to sources in attainment areas within ozone transport
regions which emit or have the potential to emit 50 tons per year
or more of VOC or 100 tpy or more of NOX.
Based upon [cite State statute or regulations] your firm is
required to submit an emission statement. The first emission
statement from your firm must be submitted to [insert name of
appropriate State or local agency] by [April 75 or whatever date is
required by the State]. The emission estimates must represent the
actual annual emissions of NOX and VOC for calendar year 1992. The
emission estimate must include an estimate of emissions from normal
operations as well as any emissions that may have resulted from
malfunctions.
Emissions data for your firm are not yet on file with the EPA.
Therefore, completion of the enclosed Emission Statement Initial
Reporting Form is required. The emission statement reporting form,
when complete, will contain all of the information necessary to
comply with the State's emission-statement requirement.
H-3
-------
Instructions regarding the information required in the Emission
Statement Initial Reporting Form are also provided.
Submission of the Emission Statement Initial Reporting Form is
required to enter your facility's emissions data into EPA's
Aerometric .Information Retrieval System (AIRS) database. Once your
emissions data are on file with the EPA, the annual emission
statement requirement will be met by updating your firm's previous
year's emissions data. The data will be obtained by the State from
EPA and sent annually to your firm for review and/or correction.
A certification of data accuracy must be included with your
firm's emission statement. The certification of data accuracy must
state that all information being submitted is complete, true, and
accurate to the best knowledge of the certifying individual. The
certifying individual is defined to be an official of the company
who will take legal responsibility for the emission statement's
accuracy. The certifying individual's signature on the
certification of data accuracy is essential for the completeness of
the emission statement. No emission statement will be accepted
without a signed statement.
Failure to comply with the emission statement requirement may
result in a civil action, a civil penalty, or both. State
sanctions for noncompliance include [insert sanctions].
Questions about the new CAAA emission statement requirement
and emission reporting should be directed to [the appropriate
contact at the State]. This contact can be reached at: [insert
phone number].
Sincerely,
Jane Smith
Director of Air Quality
H-4
-------
APPENDIX H
Part 2
Example Emission Statement Initial Reporting Form
H-5
-------
AAJ^ En
Emission Statement Initial Reporting Form
for New and Modified Sources
I. Plant Level Emission Data
* For State Use Only
AIRS cock
Slate County
JPiant
1. Source Identification
Facility Name (up to 40 characters)
Facility Address (up to 30 characters)
Mailing Address (up to 30 characters)
2. Calendar Year of Emissions
3. SIC code(s)
4. LocationaJ Coordinates
Latitude
Longitude
Above data elements all appear on AIRS update screen no. 300
-------
Emission Statement Initial Reporting Form
for New and Modified Sources
II. Point Level Emission Data
* For State Use Only
Point No.
(AIRS update screen no. 330).
1. Percentage Annual Throughput:
(AIRS update screen no. 330)
Dec - Feb:
Mar- May:
Jun - Aug:
Sep - Nov:
100%
2. Normal Operating Schedule
(AIRS update screen no. 330)
Days per Week
Hours per Day
Hours per Year
-------
Emission Statement Initial Reporting Form
for New and Modified Sources
III. Segment Level Emission Data
•
* For State Use Onlv
SCC Description
(AIRS update screen no.
Point No.
(AIRS update screen no,
Segment No.: 5
(AIRS update screen no^
Rule Effectiveness
for VOC
Rule Effectiveness
for NOx
(no AIRS update required)
f VOC Rule Effectiveness•%•
Method Code
] % NOx Rule Effectiveness'%
Method Code
(AlES update screen no. 341)
1. Annual Process Rate
2. Peak Ozone Season Daily Process Rate
3. Pollutant-specific Data
(AIRS update screen no. 340) units
(AIRS update screen no. 340) units
(AIRS update screen no. 341)
VOC
A. Estimated Actual Annual Emissions
Tons per Year
Emissions
Method Code
Emission
Factor
unit
B. Typical Ozone Season Day Emissions
Pounds per Day
Emissions
Method Code
Emission
Factor
unit
C. Control Equipment Identification Code
Primary Secondary
D. Control Equipment Efficiency <%)
NOx
A. Estimated Actual Annual Emissions
Tons per Year
Emissions
Method Code
Emission
Factor
unit
B. Typical Ozone Season Day Emissions
Pounds per Day
Emissions
Method Code
Emission
Factor
C Control Equipment Identification Code
Primary Secondary
D. Control Equipment Efficiency (%)
unit
-------
I Emission Statement Initial Reporting Form
for New and Modified Sources
III. Segment Level Emission Data
* For State i
sec
SCC Description
(AIRS update screen no, 34(8
(no AIRS update required)
Point No.
(AIRS update screen no,
Segment No.
Rule Effectiveness
•'. 'for :• -;-i '•••• '•
(pollutant*
Rule Effectiveness;:
(AIRS update screen no, 340)
% Rule Effectirertess Percent
Method Code
Rule Effectiveness Percent
Method Code
(pollutanu
IU (AIRS update screen w). 341)
Pollutant-specific Data (AIRS update screen no. 341)
Pollutant
A. Estimated Actual Annual Emissions
Tons per Year
Emissions
Method Code
Emission
Factor
unit
B. Typical Ozone Season Day Emissions
Pounds per Day
Emissions
Method Code
Emission
Factor
C Control Equipment Identification Code
Primary Secondary
D. Control Equipment Efficiency (%)
unit
Pollutant
A. Estimated Actual Annual Emissions
Tons per Year
Emissions
Method Code
Emission
Factor
unit
B. Typical Ozone Season Day Emissions
Pounds per Day
Emissions
Method Code
Emission
Factor
C. Control Equipment Identification Code
Primary Secondary
D. Control Equipment Efficiency (%)
unit
-------
APPENDIX H
Part 3
Example Instructions for Completion of the
Emission Statement Initial Reporting Form
This emission statement reporting form has been tailored to
meet the needs of your facility. Through coordination with
[insert State or local agency], it has been determined that your
facility consists of [#] points and [#] segments. As such, the
enclosed form consists of one plant page, [#] point pages and [#]
segment pages.
In order to comply with the [insert State statute or
regulation] for emission statement reporting, all of the pages
must be completed and returned to [insert State or local agency].
In addition, a signed and dated certification of data accuracy
must be included with the completed form.
The following text will instruct you how to accurately
complete the emission statement initial reporting form. Please
review the instructions carefully. Any questions should be
forwarded to (insert State contact and telephone number].
An example surface coating facility is used throughout these
instructions to help clarify some of the specific data
requirements. The example surface coating plant uses two types
of coatings and consists of one point and two segments.
I. Plant Level Emission Data
The shaded area is for [insert State or local agency] use only.
1- Source Identification: The complete facility name, physical
location (facility address), and mailing address.
2. Calendar year of emissions: Two digits representing the
calendar year for which the emissions data are applicable
(e.g., 91 for 1991 emissions).
3. SIC (Standard Industrial Classification] Code: The SIC code
is a four digit code which classifies sources according to
economic activity. SIC codes and their descriptions are
listed in the Standard Industrial Classification Manual,
published by the Office of Management and Budget. Depending
upon its operation, a facility may have more than one SIC
code; up to three separate codes may be entered.
4. Latitude and Longitude: Your facility must supply latitude
and longitude in accordance with EPA's Locational Data
Policy.
H-10
-------
II. Point Level Emission Data
The shaded area is for [insert State or local agency] use only.
1. Percentage Annual Throughput: The percent of annual
throughput achieved in the seasons specified (DEC-FEE, MAR-
MAY, JUN-AUG, and SEP-NOV). The first season (DEC-FEB)
will actually encompass 2 calendar years (e.g., DEC '92 -
FEE '93). However, the percentages should not total greater
than 100%. Annual throughput can represent the amount of
fuel used, the amount of solvent consumed, or the amount of
product produced.
The example surface coating plant applies 110,000 pounds of
coating annually: 25,000 pounds in December - February,
35,000 pounds in March - May, 20,000 tons in June - August,
and the remaining 30,000 tons in September - November. To
determine the percentage annual throughput, the amount of
coating applied during each season would be divided by the
total amount of coating applied. The resulting percentage
annual throughput in this example would be: 23% December -
February, 32% March - May, 18% June - August, and 27%
September - November.
2. Normal Operating Schedule: The annual average of the days
per week, hours per day, and hours per year that the
facility operates.
III. Segment Level Emissions Data
The shaded area is for [insert State or local agency] use only.
A source classification code (SCO is an EPA identifier for a
specific segment. The SCC and its description are provided by
the State and are displayed in the shaded box at the top of the
segment form.
The example surface coating plant uses two types of coatings and
as such has two SCCs. For coating number 1, a solvent based
paint, the SCC is 4-02-001-01. For coating number 2,.an enamel,
the SCC is 4-02-005-01. Data concerning each SCC should be
provided on separate segment level forms.
1• Annual Process Rate: This number represents the amount of
product throughput, the amount of solvent consumed, or the
amount of fuel burned. The units for the annual process
rate depend upon the specific SCC. The appropriate units
for reporting the annual process rate can be determined by
using the SCC and referencing the EPA publication AIRS
Facility Subsystem Source Classification Codes and Emission
Factor Listing for Criteria Air Pollutants, or by contacting
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[insert State/local contact and telephone number].
To determine the annual process rate, the example surface
coating facility should determine the amount of coating
number 1 applied. The facility does not process fuel, but
does throughput 110,000 pounds of coating annually. Of the
110,000 pounds, 70,000 pounds of coating are applied as a
solvent based paint, coating number 1. The SCC for coating
number 1, as provided by the State, is 4-02-001-01. By
referencing the above named document, or by contacting the
State, the appropriate units are determined to be "tons of
coating mix applied". Since the amount of coating applied
is known by the facility, the annual process rate may be
reported as 70,000/2,000, or 35 tons of coating applied.
Alternatively, the source may choose to compute an annual
process rate based on the gallons of coating applied, which
is listed under a separate SCC.
A similar process would be used to compute the annual
process rate for coating number 2. The data would be
reported on the second segment level emission data form, and
would correspond to the State provided SCC for coating
number 2.
2. Peak Ozone Season Daily Process Rate: The average daily
process rate during the peak ozone season. The ozone season
is defined to be the period of the year during which the
conditions for the formation of ozone is most favorable.
The peak ozone season for the region in which your facility
is located is [insert appropriate peak ozone season]. The
peak ozone season covers a three month period during which
most ozone exceedances occur, while the ozone season can
extend much longer. The process rate should be determined
as above, except averaged to represent a day during the peak
ozone season instead of the annual total. The correct
reporting units should be determined as outlined above.
3. Pollutant Specific Data: Pollutant specific data are
required for the following pollutants: volatile organic
compounds (VOC) and oxides of nitrogen (NOx) [insert
additional pollutants, if applicable]. VOC and NOx have
been determined to be significant contributors to the
formation of ozone. Therefore, data on the sources of these
pollutants are necessary to assist in State air quality
planning. [The additional pollutants are required to
coordinate State reporting requirements. By providing data
for these pollutants, your facility will avoid duplicating
your required emission reporting efforts.] The same data
are required for each of the pollutants.
3A. Estimated Actual Annual Emissions: Actual annual emissions
should represent the actual emissions for the source for the
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calendar year, including upsets, downtime, and fugitive
emissions. Emissions from significant and minor processes
within the plant must be part of the emissions estimate.
When estimating annual VOC emissions, it is necessary to
exclude methane, ethane and chloroflourocarbons from the
estimation because they are considered to be photochemically
nonreactive. Units must be in tons of pollutant emitted per
year. Actual emissions can be derived in a number of ways.
Emissions can be estimated based upon any of the EPA's
acceptable methods as detailed by the following emission
method codes.
The example surface coating facility has decided to use an
emission factor to estimate their emissions. An emission
factor is a number that, when multiplied by the appropriate
process data (such as tons of coating mix applied), will
yield the facility's estimated actual annual emissions. By
using the EPA document, AIRS Facility Subsystem Source
Classification Codes and Emission Factor Listing for
Criteria Air Pollutants, the facility has determined that
for SCC 4-02-001-01 (coating number 1), the emission factor
is 1120 pounds of VOC per ton of coating mix applied. As
previously determined, 35 tons of coating were applied as
coating number 1, therefore the amount of VOC emissions from
coating number 1 is 35 X 1120, or 39,200 pounds per year.
To achieve the required tons per year figure, 39,000 is
divided by 2,000, resulting in estimated actual annual
emissions of 19.6 tons per year. This figure should then be
entered on the segment level emission data form
corresponding to SCC 4-02-001-01. The same procedure should
be followed, using emission factors for the second coating,
to determine the emissions for coating number 2 (i.e., SCC
4-02-005-01), which is then entered on the second segment
level emission data form and for all other pollutants.
Estimated Emissions Method Code: This code denotes the
method used to calculate your facility's emissions. Valid
codes are as follows:
1 - USER CALCULATED BASED ON SOURCE TEST OR OTHER EMISSION
MEASUREMENTS.
2 - USER CALCULATED BASED ON MATERIAL BALANCE USING
ENGINEERING KNOWLEDGE OF THE PROCESS.
3 - USER CALCULATED BASED ON AP-42 EMISSION FACTOR (OR SCC
EMISSION FACTOR).
4 - USER CALCULATED BY BEST ENGINEERING JUDGEMENT
5 - USER CALCULATED BASED ON A STATE OR LOCAL AGENCY
EMISSION FACTOR.
6 - NEW CONSTRUCTION, NOT YET OPERATIONAL. EMISSIONS ARE
ZERO.
7 - SOURCE CLOSED; OPERATION CEASED. EMISSIONS ARE ZERO
8 - COMPUTER CALCULATED BASED ON STANDARD EMISSION FACTOR.
H-13
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(SCC EMISSION FACTOR FILE)
9 - COMPUTER CALCULATED BASED ON OTHER APPROVED EMISSION
FACTOR.
All emissions calculated by a facility will be denoted by
codes 1 through 5. Codes 8 and 9 represent emissions that
were calculated by the EPA's data base system.
The example surface coating facility used an emission factor
from the AIRS Facility Subsystem Source Classification Codes
and Emission Factor Listing for Criteria Air Pollutants.
Therefore, the emission method code entered by the example
facility is 3.
Emission Factor: The emission factor used to compute the
estimated annual emissions. If an emission factor was used
in the computation, it should be entered in the space
provided. The emission factor should include the
appropriate units (e.g., pounds of pollutant per ton of
coating applied). Up to 7 characters can be used to
indicate the emission factor. In the event that emission
factors are utilized in the calculation of emissions, a
source must use emission factors that are approved by EPA or
the State. Otherwise, the source must petition the State
for approval of their emission factors.
The example facility's emission factor for coating number 1,
SCC 4-02-001-01, is 1120 Ibs VOC/ton of coating mix applied.
Again, this emission factor was derived by examining the
AIRS SCC manual for the appropriate SCC, in this case 4-02-
001-01, and the correct pollutant, VOC. The emission factor
for coating number 2, SCC 4-02-005-01, is found to be 840
Ibs VOC/ton of coating mix applied.
3B. Typical Ozone Season Day Emissions: These emissions must be
supplied in pounds per day and must represent actual
emissions during the peak ozone season. As mentioned under
estimated actual annual emissions, when estimating VOC
emissions, methane, ethane, and chloroflourocarbons are not
to be included in the estimation. To calculate the typical
ozone season day emissions, the throughput for a typical
ozone season day must be determined. The peak ozone season
for the region in which your facility is located is [insert
peak ozone season]. The throughput should be determined as
previously discussed. Actual emissions can be derived in a
number of ways. Acceptable EPA methods are the same as
those listed above. Estimates should account for both
significant and minor process emissions, and fugitive
emissions should also be included in the emissions reported
if applicable.
The example surface coating facility has decided to use an
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emission factor to compute their typical ozone season day
emissions. The peak ozone season for their region has been
supplied by the State and the source has determined that on
an average day during the peak ozone season, they apply
approximately 165 pounds of coating. Using the emission
factor for SCC 4-02-001-01 (coating number 1) they have
determined that 1120 pounds of VOC are emitted for every ton
of coating number 1 applied. To calculate the daily
emissions, the tons per day of coating applied during the
ozone season is determined and multiplied by the emission
factor of 1120. The resulting daily emissions are:
165/2,000 = .0825 tons per day X 1120 pounds of VOC per ton
=92.4 pounds of VOC. The same process is repeated for
coating number 2 (and for any other pollutants).
Estimated Emissions Method Code: The emission method codes
are identical to the method codes presented in 3A.
Once again, the example source would enter 3 for the
estimated emissions method code.
Emission Factor: The EPA or State approved emission factor
used to compute the typical ozone season day emission
estimate. If an emission factor was used in the
computation, it should be entered in the space provided.
The emission factor should include the appropriate units
(e.g., pounds of pollutant per ton of coating applied). Up
to 7 characters can be used to indicate the emission factor.
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3C.
000
001
002
003
004
005
006
007
008
009
010
011
012
013
014
015
016
017
018
019
020
021
022
023
024
025
026
Control Equipment Identification Code: Control equipment is
used to limit the emission of pollutants to the atmosphere.
Numerous types of control equipment may be in place at a
facility. For emission statement reporting, your facility
is required to report the primary and secondary control
equipment codes. The following list details the control
equipment codes for different control equipment. For more
information on the correct code for the control equipment at
your facility, contact [insert appropriate State or local
contact and telephone number]. Valid codes are as follows:
NO EQUIPMENT 027
WET SCRUBBER HIGH EFFICIEN. 028
WET SCRUBBER MED EFFICIEN. 029
WET SCRUBBER LOW EFFICIEN. 030
GRAVITY COLL HIGH EFFICIEN. 031
GRAVITY COLL MED EFFICIEN. 032
GRAVITY COLL LOW EFFICIEN. 033
CENTRIF COLL HIGH EFFICIEN. 034
CENTRIF COLL MED EFFICIEN. 035
CENTRIF COLL LOW EFFICIEN. 036
ELECTRO PREC HIGH EFFICIEN. 037
ELECTRO PREC MED EFFICIEN. 038
ELECTRO PREC LOW EFFICIEN. 039
GAS SCRUBBER, GENERAL 040
MIST ELIMINATOR HIGH VELOC. 041
MIST ELIMINATOR LOW VELOC. 042
FABRIC FILTER HIGH TEMP. 043
FABRIC FILTER MEDIUM TEMP. 044
FABRIC FILTER LOW TEMP. 045
CATALYTIC AFTERBURNER 046
CAT. AFTERBURN - HEAT EXCH. 047
DIRECT FLAME AFTERBURN 048
D.F. AFTERBURN - HEAT EXCH. 049
FLARING 050
MODIF FURNACE/BURNER DESIGN 051
STAGED COMBUSTION 052
FLUE GAS RECIRCULATION 053
REDUC COMBUST.- PREHEAT
STEAM OR WATER INJECTION
LOW-EXCESS - AIR FIRING
FUEL - LOW NITROGEN CONTENT
AIR INJECTION
AMMONIA INJECTION
CONTRL OF % 02 IN COMB.AIR
WELL.-LORD/SODIUM SULF SCRB
MAGNESIUM OXIDE SCRUBBING
DUAL ALKALI SCRUBBING
CITRATE PROCESS SCRUBBING
AMMONIA SCRUBBING
CATAL. OXID-FLUE GAS DESULF
ALKALIZED ALUMINA
DRY LIMESTONE INJECTION
WET LIMESTONE INJECTION
SULF ACID PLNT-CONTACT PROC
SULF ACID PLNT-DBL CNT PROC
SULFUR PLANT
PROCESS CHANGE
VAPOR RECOVERY SYSTEM
ACTIVATED CARBON ADSORPTION
LIQUID FILTRATION SYSTEM
PACKED-GAS ABSORBION COLUMN
TRAY-TYPE GAS ABSORB COLUMN
SPRAY TOWER
VENTURI SCRUBBER
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3C. Control Equipment Identification Code: (cont.)
054 - PROCESS ENCLOSED 084 -
055 - IMPINGEMENT PLATE SCRUBBER 085 -
056 - DYNAMIC SEPARATOR (DRY) 086 -
057 - DYNAMIC SEPARATOR (WET) 087 -
058 - MAT OR PANEL FILTER 088 -
059 - METAL FABRIC FILTER SCREEN 089 -
060 - PROCESS GAS RECOVERY 090 -
061 - DUST SUPPRESS - WATER SPRAY
062 - D.S.- CHEM STAB./WET AGENTS 091 -
063 - GRAVEL BED FILTER
064 - ANNULAR RING FILTER 092 -
065 - CATALYTIC REDUCTION
066 - MOLECULAR SIEVE 093 -
067 - WET LIME SLURRY SCRUBBING 094 -
068 - ALKALINE FLY ASH SCRUBBING 095 -
069 - SODIUM CARBONATE SCRUBBING 096 -
070 - SODIUM-ALKALI SCRUBBING
071 - FLUID BED DRY SCRUBBER 097 -
072 - TUBE AND SHELL CONDENSER
073 - REFRIGERATED CONDENSER
074 - BAROMETRIC CONDENSER 098 -
075 - SINGLE CYCLONE 099 -
076 - MULTIPLE CYCLONE
W/O FLY ASH REINJECTION 101 -
078 - BAFFLE
079 - MULTIPLE CYCLONE
W/ FLY ASH REINJECTION
080 - CHEMICAL OXIDATION
081 - CHEMICAL REDUCTION
082. - OZONATION
083 - CHEMICAL NEUTRALIZATION
The example surface coating facility's primary control
device is a vapor recovery system. The facility has no
secondary control device. Therefore, the facility should
enter 047 for the primary control device and 000 for the
secondary control device.
3D. Control Equipment Efficiency: The percent effectiveness of
the control device(s). It represents the actual total
control efficiency achieved by the control device(s). The
actual efficiency should reflect control equipment downtime
and maintenance degradation. If the actual control
efficiency is unavailable, the design efficiency or control
efficiency limit imposed by a permit should be used.
In addition, the capture efficiency must be taken into
account when determining control efficiency. Capture
efficiency is a measure of the volume of pollutant captured
ACTIVATED CLAY ADSORPTION
WET CYCLONIC SEPARATOR
WATER CURTAIN
NITROGEN BLANKET
CONSERVATION VENT
BOTTOM FILLING
CONVERSION TO VARIABLE
VAPOR SPACE TANK
CONVERSION TO FLOATING
ROOF TANK
•CONVERSION TO PRESSURIZED
TANK
SUBMERGED FILLING
UNDERGROUND TANK
WHITE PAINT
VAPOR LOCK BALANCE RECOVERY
SYSTEM
INSTALLATION OF SECONDARY
SEAL FOR EXTERNAL FLOATING
ROOF TANK
MOVING BED DRY SCRUBBER
MISCELLANEOUS CONTROL
DEVICES
HIGH EFFICIENCY PARTICULATE
AIR FILTER
H-1 7
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or recovered relative to the volume of pollutant generated.
The entire emission stream-may not always pass through
the control equipment. A certain percentage of emissions
may escape as fugitive emissions and are therefore not
controlled, and the calculated emissions must reflect this.
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APPENDIX I
EPA FACILITY ID CODE
The Facility Identification Data Standard (FIDS) became
effective on April 9, 1990, after formal Agency-wide review, when
it became EPA Order #2180.3. The objective of the FIDS is to
unify facility data maintained by different EPA programs. The
FIDS institutes the assignment of a unique identifier to
facilities regulated under Federal environmental laws. In
addition, this "EPA facility identification code" is to be part
of every data collection, whether manual or automated, containing
information on that facility. The FIDS will improve the
compatibility of all Agency facility data by providing a
fundamental piece of "linkable" information, the EPA facility ID
code, to all facility-oriented data, allowing integration across
systems and data from different sources. Assignment of EPA
facility ID codes will be done using the Facility INDex System
(FINDS), an EPA data base containing an inventory of facilities
to which ID codes have been assigned.
EPA Headquarters media program staff (i.e., those staff
within programs directly mandated by Federal environmental laws)
are responsible for large-scale adoption and implementation of
the FIDS in all their program activities. These programs also
provide coordination for the FIDS in that they develop Program
FIDS Implementation Plans and implement FIDS and FINDS with their
Regional and State counterparts. EPA Regional FIDS participants
are responsible for ensuring that assignment and use of EPA
facility ID codes in all facility-related activities is complete,
that the necessary information is available and correct, and that
discrepancies are resolved. States must uphold the requirements
of the FIDS for facilities regulated under Federal environmental
laws, whether or not those facilities are also regulated under
state law. For such facilities, states must use EPA facility ID
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codes in all activities involving the EPA. State participants
may opt for either of two types of integration with FINDS: (1)
they may be indirect participants .through the EPA regional office
program and FINDS staff, or (23 they may be direct users of FINDS
by entering data and assigning ID codes.
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