STANDARDIZING REPORTING CODES FOR THE COMBINED AIR EMISSIONS REPORTING SYSTEM (CAERS) TEAM REPORT Contents 1 Project Description 3 1.1 Background and Purpose 3 1.2 Team Participants and Acknowledgements 4 2 List of Data Elements for Research 4 3 Survey of Codes in SLT El Systems 4 4 Analysis of Codes Used in the 2017 Draft NEI 5 5 Findings and Recommendations 5 5.1 Findings 5 5.2 Recommendations 6 5.2.1 Actions for CAERS 6 5.2.2 Actions for EIS 6 5.2.3 Recommendations for SLT codes use in CAERS 6 5.2.4 Recommendations for CAERS Code Tables 7 Appendix A Data Element for the Project A-l Appendix B Survey of Codes in SLT El Systems and Results B-l B.l Original Survey of Codes in SLT El Systems B-l B.2 Summary of Survey Results B-3 B.3 Survey Findings B-5 B.3.1 All Data Elements B-5 B.3.2 Unit Type Data Element B-5 B.3.3 Control Measure Data Element B-7 B.3.4 Calculation Material Data Element and Calculation Parameter Unit of Measure.B-7 B.3.5 Emissions Calculation Method Data Element B-8 1 ------- B.3.6 Others B-9 B.4 Recommendations B-9 Appendix C Analysis of Codes Used in the Draft 2017 NEI C-l C.I Summary Information on Data Elements for the Project C-l C.2 Unit Type Data Element C-l C.3 Calculation Parameter Unit of Measure Data Elements C-9 C.4 Calculation Material Data Element C-14 C.5 Emission Calculation Method Data Element C-7 C.6 Findings C-12 Appendix D Options for CAERS and Recommendations D-l D.l Options for How the Different SLT Codes Will Be Housed and Maintained D-l D.2 Proposed CAERS Tables D-3 Appendix E List of SLT Program System Codes in EIS E-l 2 ------- 1 Project Description 1.1 Background and Purpose In conducting research on the differences among State Local Tribal (SLT) emissions inventory (El) programs, the National Emissions Inventory (NEI), and the Toxics Release Inventory (TRI), the SLT- EI/NEI/TRI Research and Development (R & D) team noted differences in data field codes between SLT emissions inventory systems and EPA's Emissions Inventory NEI system (EIS), which houses data for the NEI. These differences were indicated in their final report, but were not pursued at the time, given the scope of their project. This report documents subsequent work by another R&D team as part of ongoing work by the Combined Air Emissions Reporting (CAER) Product Design Team (PDT), to identify those code differences and provide recommendations on how they should be dealt with to support the use of CAERS by SLTs. There are two broad categories of differences in codes between SLT emissions inventory systems and EIS. The first has to do with differences in nomenclature or naming conventions for similar data fields, such as a different name or number to represent the same unit type. The second has to do with codes that are unique for the SLT and are thus either missing from the EIS code lists or do not have a one-to- one match with the EIS codes. Work for this project consisted of identifying both types of differences and issuing recommendations for how CAERS should handle reporting codes development. Adoption of the recommendations for CAERS will help minimize the burden of collecting emissions data for facilities and SLTs. This report summarizes the results of our research. Results of specific analyses are organized as project deliverables, which are provided as appendices to this report. The Appendixes can be found at the end of this document, and are summarized below: • Data Elements for the Project (Appendix A): specifies the description of data elements selected for the project. • Survey of Codes in SLT El Systems and Results (Appendix B): includes the original survey sent to SLTs, summary responses from SLTs, analysis of survey responses, and findings. • Analysis of Codes Used in the 2017 Draft NEI (Appendix C): provides a comparison of codes used by SLTs and EPA for each specified data element in CAERS. • Options for CAERS and Recommendations (Appendix D): includes the business rules and the proposed CAERS tables for the 5 data elements in the study. The tables include information from SLTs that have code differences in their El systems compared to EIS. While CAERS takes program requirements both from federal and SLT programs as given, some coding issues impact SLTs not currently using or interested in using CAERS. Also, coding improvements that help make for more consistent data submissions within CAERS, can help make submitted data more consistent across SLTs submitting directly through EIS. Therefore, some recommendations for EIS codes are included where applicable. 3 ------- 1.2 Team Participants and Acknowledgements The following team members participated in the development and review of results for this project: • Chun Yi Wu (Minnesota Pollution Control Agency), Project Lead • Julia A. Gamas (U.S. EPA), Project Co-Lead • Jing Wang (Georgia Department of Natural Resources) • Benjamin Way (Wyoming Department of Environmental Quality) We would like to acknowledge the support from Kelly Poole, from the Environmental Council of the States (ECOS). 2 List of Data Elements for Research Data elements for research were determined as those essential to CAERS and with potential code differences between SLTs and EIS. These data elements were identified early so that they can be factored in the design of CAERS. The following five groups of data element codes were identified (Appendix A): • Unit Type Code • Control Measure Code • Calculation Material Code (also referred to as "Throughput") • Calculation Parameter Unit of Measure (also referred to as "Throughput Unit of Measure") • Emission Calculation Method Code Although varieties of pollutants have been collected in different programs, pollutant codes have been studied in previous R&D projects. The SLT Els/NEI/TRI Team developed cross walks of pollutants between NEI and TRI. The Data Model Team identified pollutants covered in SLT Els in addition to those in NEI. A direct link between CAERS and the Substance Registry Services (SRS), EPA's authoritative resource for information about chemicals, biological organisms, and other substances tracked or regulated by EPA, has already been incorporated into its design. Therefore, a research of pollutants codes will not be covered in this project. 3 Survey of Codes in SLT EI Systems A survey among SLTs was conducted to find whether they have additional codes than those of EIS, and/or SLT-specific naming conventions that are different from EIS's. This project uses EIS codes as starting points because EIS codes are more detailed than TRI codes. The following information was sought through the survey: • Codes that SLT systems include that are not included in EIS. • SLT codes that are conceptually the same as EIS codes but are used differently from how they are used in EIS (for example, the code numbering system is different for the SLT than for EIS.) • SLT codes that are not a one-to-one match with EIS codes and, thus, require that they be mapped to an EIS code so they can be reported to EIS. 4 ------- Among 82 SLTs that reported emissions to the NEl, 38 SLTs responded the survey. Results show 21 SLTs have one or more data elements with differences from the EIS codes. Other SLTs use the same codes as the NEI. Detail analysis, findings, and recommendations are shown in Appendix B. 4 Analysis of Codes Used in the 2017 Draft NEI Not all SLTs were able to respond to the survey. Therefore, 2017 NEI data reported by all SLTs were analyzed, to get a more complete picture of the nation. After collecting data from SLTs for the NEI, EPA also uses EIS codes to do emissions augmentation and to obtain emissions information from other available resources, such as the TRI. Therefore, analysis of the 2017 NEI was also extended to the use of codes by EPA. Results of this analysis can be found in Appendix C. 5 Findings and Recommendations This section summarizes the findings and recommendations from the project. Details, including examples, are provided in the Appendixes, and specifically in Appendix D. 5.1 Findings The following findings are based on observations from data provided by the SLTs that responded to the survey, as well as the analysis of data from the 2017 NEI. Note that additional use cases could exist from those SLTs that did not respond to the survey. 1. Among emission data for 92 SLTs listed as reporters to the 2017 NEI, 23 SLTs reported more than 50% of the emission records, 59 SLTs reported less than 50% of the emission records, and 10 locals and tribes did not report emissions to the NEI. 2. In general, codes used in SLT systems may have different conventions than EIS codes, including format, length, and the use of numerical values to represent data fields. 3. Overall, SLT systems may have more or fewer codes than EIS for data elements analyzed in this study. SLTs can have additional codes to EIS codes and, also, they may not use certain EIS codes. 4. Not all codes for Unit Type, Calculation Parameter Unit of Measure, and Calculation Material are shown in the 2017 draft NEI. However, large numbers of records are associated with the code "unclassified," or show up blank or null. This implies that SLTs do not collect the information, SLTs do not report the data element, or the EIS codes for those data elements might not be user-friendly. This implication is confirmed from the survey results. 5. SLTs may have more specific codes for the Control Measure and Unit Type data elements than EPA used in EIS. SLTs that do not report the Control Measure data element to EIS usually use fewer codes in their systems than EIS. 6. All 23 EIS codes for the emission calculation method data element are used by SLTs in the draft 2017 NEI. However, seven EIS codes are not used by EPA such as Trade Group Emission Factor, S/L/T Emission Factor, Vendor Emission Factor, and Emission Factor based on some other information sources. 7. Calculation Method is the most controversial data element among the five data elements studied in this project. Although this data element must be present when SLTs report emissions to the NEI with EIS codes, the use (and thus, interpretation) of the same EIS code can be different from SLT to SLT. 5 ------- 5.2 Recommendations 5.2.1 Actions for CAERS The following are actions that we recommend for the CAER system to assist in proper code use: 1. CAERS should enforce the requirement for reporting Unit Type, Calculation Parameter Unit of Measure, and Calculation Material data elements, where possible. 2. CAERS should include a reference table that links a process Source Classification Code (SCC) to default Unit Type data element codes, so that CAERS can automatically fill codes for the Unit Type date element when the information is missing or not required by SLTs. CAERS can take the SCC for the first process for an emission unit type code if the emission unit has multiple processes with different SCCs. For EIS the following would assist in making CAERS more complete: 5.2.2 Actions for EIS The following are actions that we recommend for EIS to assist in proper code use: • Add more detailed EIS codes for the Control Measure data element and modify descriptions to make them less confusing and thus, less subject to being interpreted in different ways by different SLTs. • Add "biomass solid," "biomass liquid" and "biomass dried" to the codes for Calculation Material. Additional clarification on individual items that are included in "biomass" would be helpful. 5.2.3 Recommendations for SIT codes use in CAERS CAERS will have to supply the different SLTs with reporting codes as follows (see Appendix D): • The SLT has the same codes as EIS so facilities from that SLT can enter those codes. This is the current default setting in CAERS. • The SLT has the same codes as EIS but the nomenclature and coding system for the SLT are different. The CAERS would have to contain a crosswalk so that the users can work with the SLT codes and then have the data sent with the corresponding EIS codes to EPA. • The SLT has additional codes that do not map to EIS codes. In this case, the CAERS will have to include the additional SLT codes and crosswalk to EIS codes in its SLT customization. • The SLT has codes that map to EIS codes but are not identical to an EIS code. The CAERS would have to crosswalk those codes to the nearest EIS match, with input from the SLT. • Additional use cases that will need to be accommodated into CAERS: E.g., an SLT does not want to offer a specific EIS calculation method to its facilities. The team also discussed how the different SLT codes should be provided to CAERS. Two options emerged through team discussions: 1. SLT provides its codes to CAERS. 2. Establish a standardized set of codes in CAERS. The team recommend Option 1 for the current development of CAERS with the business rules listed below. Option 2 could be a longer-term option. In fact, it would likely evolve over time as a result of more SLT and EPA systems integrating with CAERS, using the Agile approach. 6 ------- Business rules for an SLT providing its codes to the CAERS are listed as follows: 1. SLTs are only allowed to edit their respective codes. 2. SLTs take full responsibility for their respective codes in terms of maintenance (creating new codes, updating, and retiring codes overtime). 3. SLTs must map their codes to the corresponding EIS code, or closest match, if SLTs want to report the information to NEI but have codes that are different from the EIS codes for a data element. 5.2.4 Recommendations for CAERS Code Tables The recommended code tables for each data element are in Appendix D. Those tables contain information for SLTs that have codes different from EIS and responded to the survey. There are common fields in all five tables. Descriptions of those common columns and how they should be used in CAERS are explained below. • The column "Program System Code" represents the information management system which has responsibility for the SLT codes listed in the table, in a linked or interrelated information management system. It is the same as the Program System Code used in EIS. For example, the Program system code for Wyoming Department of Environmental Quality is WYDEQ. • The "Addition to EIS Codes" column shows how to use the SLT codes in CAERS: o "U" means the SLT does not use that specific EIS code. In this case, the SLT users will see all EIS codes but not those EIS codes marked as "U", in CAERS. o "Y" means that SLT codes exist for the SLT but do not exist in EIS. The code would need to be added to the list of codes in CAERS that the user from that SLT can choose from. If a code exists for many SLTs but it is not listed in EIS, EPA should consider adding that code to the list of codes in EIS. For example, EIS code 109 for Control Measure data element represents Catalytic Oxidizer/ Incinerator, but three states added a code only for Catalytic Oxidizer and a code only for Incinerator. That suggests EPA to consider a separation of EIS code 109 to two codes. In this case, the SLT users will see all EIS codes (except codes marked as "U"), as well as their corresponding SLT additional codes with "Y" in CAERS. o "N" means that the SLT uses its own codes in CAERS. In this case, the SLT users will only see their SLT codes in CAERS, regardless of all EIS codes. • The records that are marked "Y" and "N" in the "Addition to EIS Codes" column should have the "Map to EIS Codes" column filled up if an SLT wants to send data to NEI. Otherwise, the data will only be used in the SLT El, not in the NEI and TRI. • The "Last Updated" column contains an auto-generated timestamp that represents the date and time the record was last updated. • The "User" column is also auto-generated based on user log-in information. 7 ------- APPENDIXES - FULL DELIVERABLES Appendix A Data Element for the Project The following is a list of the data elements for the project: • Unit Type • Control Measure • Calculation (Throughput) Parameter Unit of Measure • Calculation (Throughput) Material • Emissions Calculation Method See the file: "List of DataFieldCodes.xIsx" A-l ------- Appendix B Survey of Codes in SLT El Systems and Results B.l Original Survey of Codes in SLT El Systems E-Enterprise for the Environment Combined Air Emissions Reporting (CAER) Codes for Data Fields Survey for State/LocaI/Tribal (SLT) Emission Inventories (Els) This survey seeks information on the codes used in your emission inventory system to determine whether in your system: • There are codes that your state system includes that are not included in the NEI. For example, Ml (Michigan) has an additional Emission Calculation Method Code, "Facility EF" that is specifically for emission factors that come from that facility because emission factors could come from a variety of sources. • There are codes that are the same as NEI codes but are used differently from the use of NEI. For example, for the NEI calculation method code 2, "Engineering judgement," NEI does not have a description. Some view it as a better factor to use than a "trade group emission factor" with respect to data quality, whereas others view it as the lowest level of data quality. • There are codes that are not in a one-to-one match with NEI codes and, thus, require you to transform (map) them in order to report to NEI. For example, Minnesota (MN) uses control measure codes 906 for Fiberglass Filter with Cardboard Frame and 907 for Fiberglass Filter without Cardboard Frame. Those codes are mapped to the same NEI code 58, Mat or Panel Filter. The survey will focus on five data fields: Unit Type Code, Control Measure Code, Calculation Parameter Unit of Measure, Calculation Material Code, and Emission Calculation Method Code. The "List of Data Field Codes.xlsx" file provides the definition of the data fields and the links to previous work done for the data fields. For your reference, the "NEI codes" file contains five sheets, each for NEI codes in each data field. Your participation is critical for the CAERS development and will be greatly appreciated. If you have questions, please contact Chun Yi Wu at chun.vi.wu@state.mn.us or (651)757-2833. 1. Does your state system contain codes from any of the following data fields that are not included in NEI? YES NO a. Unit Type Code ~ ~ b. Control Measure Code ~ ~ c. Calculation Parameter Unit of Measure ~ ~ d. Calculation Material Code ~ ~ e. Emission Calculation Method Code ~ ~ B-l ------- 2. Does your state system use code values in any of the following data fields that are the same as the NEI code values but have a different definition from that in the NEI? For example, your system has a data field called 'Unit Type Code/ in which your specific data value 1402 refers to a Unit Melter Furnace, whereas the NEI Unit Type Code value 1402 refers to a Storage Bin, and the NEI code value for a Unit Melter Furnace is 205. (Situations like these will require some cross- walking to be built into CAERS.) YES NO a. Unit Type Code ~ ~ b. Control Measure Code ~ ~ c. Calculation Parameter Unit of Measure ~ ~ d. Calculation Material Code ~ ~ e. Emission Calculation Method Code ~ ~ 3. Does your state system contain codes that are not in a one-to-one match with NEI codes, and thus, require you to transform (map) in order to report to the NEI. YES NO a. Unit Type Code ~ ~ b. Control Measure Code ~ ~ c. Calculation Parameter Unit of Measure ~ ~ d. Calculation Material Code ~ ~ e. Emission Calculation Method Code ~ ~ 4. If you answered YES to any of the above questions, please provide a URL where we can find your lists of codes and/or attach files that contain the corresponding code tables in your system, including codes, description, map to NEI codes (if applicable), comments, and other data fields if necessary. 5. Please provide the following applicable information for the SLT you represent. If you represent a state, only the FIPS State Code is needed. • FIPS State Code: • FIPS County Code: • Tribal Code: B-2 ------- B.2 Summary of Survey Results The survey was originally sent to SLT El contact people in November 2019 via e-mail. In December 2019, another e-mail was sent to remind them to complete the survey. After that, follow up calls and emails were sent to those SLTs that had not responded. Thirty-eight SLTs responded to the survey. The detailed response distribution from the 82 SLTs that reported emissions to the 2017 NEI is shown in Figure B. 1., where we can see that from those 82 reporting SLTs, 22 were Local, 52 were State, and 8 were Tribal authorities. Out of 22 local authorities, 6 responded to the survey. Out of 52 State authorities, 31 responded to the survey. Out of 8 tribal authorities, 1 responded to the survey. The data is also summarized in Table B. 1. Figure B. 1. Distribution of Survey Respondents 60 50 40 30 20 10 Local State Tribe ¦ Numbers Reported to NEI I Numbers Responded the Survey Table B. 1. Distribution of Survey Respondents Jurisdiction Type Numbers Reported to NEI Numbers Responded the Survey Local 22 6 State 52 31 Tribe 8 1 Total 82 38 Among 38 SLTs responded the survey, 21 SLTs (about 55%) indicated code differences between their systems and EIS, for one or more data elements. The other SLTs are using the same codes as those in EIS. Figure B. 2. and Table B. 2. show the number of SLTs that have differences with EIS codes for each data element. B-3 ------- Figure B. 2. Number ofSLTs that Have Differences from ElSfor Each Data Element i/i 13 O CL l/l LU QC Ll_ o QC LU CO 3 12 Emission Calculation Method 12 Control Measure 1 10 9 Unit Type Calc Para Unit Calc Material of Measure I Provided Detail Did not Provide Detail Table B. 2. Number ofSLTs that Have Differences from ElSfor Each Data Element Data Elements Provided Detail Did not Provide Detail Total Emission Calculation Method 12 1 13 Control Measure 12 12 Unit Type 9 1 10 Calc Para Unit of Measure 10 10 Calc Material 8 8 Table B. 3 shows detailed information for SLTs who have codes different from EIS for each data element. In the list, SLTs are represented by their unique codes that indicate information management systems which have responsibility for the codes. Those codes are the same as the Program System Codes used in EIS. A detailed list of the program system codes can be found in Appendix E. The SLTs in the brackets did not provide detail information on differences between the SLT codes and the EIS codes. Table B. 3. List ofSLTs that Have Codes Different from ElSfor Each Data Element Unit Type Control Measure Calculation Parameter Unit of Measure Calculation Material Emission Calculation Method CODPHE CODPHE CODPHE CTBAM Chattan CTBAM CTBAM CTBAM FLDEP CODPHE DNREC DNREC DNREC MIDEQ CTBAM FLDEP FLDEP FLDEP MNPCA LADEQ LADEQ IADNR Louisville NYDEC Louisville MNPCA LADEQ MNPCA OHEPA MIDEQ MTDEQ MNPCA MTDEQ SWCAA MNPCA B-4 ------- Unit Type Control Measure Calculation Parameter Unit of Measure Calculation Material Emission Calculation Method SWCAA NYDEC OHEPA WYDEQ NCDAQ WIDNR SWCAA WIDNR NYDEC (TXCEQ) Wl DNR WYDEQ OHEPA WYDEQ OKDEQ TXCEQ WYDEQ (TXCEQ) B.3 Survey Findings This section details the team's findings based on observations from those SLTs that responded to the survey. More items could exist from SLTs that did not respond the survey. B.3.1 All Data Elements 1. The codes in SLT systems could be in a different convention from the codes in EIS. For example: • EIS codes for four data elements (Unit Type, Control Measure, Calculation Material, and Emissions Calculation Method) are represented by numerical values but descriptive texts for Calculation Parameter Unit of Measure. However, the codes used by SLTs for all five data elements could be numerical values, descriptive texts, or a mixture of both. For example, Colorado uses text values to represent unit type codes. The length of the codes used by SLTs are different and could be as short as 2 or as long as 16. • The numerical values used by SLTs are in a different format, for example, Oklahoma (OK) system uses XX_X (e.g., 10_3) for code of emission calculation method while New York (NY) only uses XX (e.g., 08). 2. SLT systems could have more or fewer codes than EIS for the data elements in this study. For example, Michigan has 388 codes, Ohio (OH) has 644 codes, and MN has 667 codes for the calculation material while EIS has 637 codes. SLTs could have additional codes to EIS codes, and, meanwhile, not use certain EIS codes. For example, the Florida (FL) system has 18 additional codes to the EIS codes, uses 45 EIS codes, but does not use 24 EIS codes for the calculation parameter unit of measure. B.3.2 Unit Type Data Element 1. For some emission units it is difficult to determine the correct classification in the current EIS codes for the Unit Type data element. For example, a boiler that burns natural gas and hazardous waste (subject to the HWC MACT), could be a boiler (with EIS code 100), but could also be an incinerator (with EIS code 270). SLTs (such as Southwest Clean Air Agency or SCAA) have separated the fuels at the process level, but the code for Unit Type is applied at the emission unit level. 2. Reported unit type codes do not always represent the real emission unit types. Some SLTs do not have a unit type code reported from their facilities. For example: • The Montana (MT) system does not obtain unit type codes from any other resources. It tracks the SCC and ties the unit type code to the unit with a cross-reference table of SCCs. B-5 ------- • Connecticut (CT) does not have the data element in its system because the unit type code is not critical to its EIS reporting efforts. CT has not effectively populated the field (less than 6% of the data has a valid assignment). The SLT codes for CT facilities to report are only limited source type codes. CT manually adds other codes when it reports to NEI. • MN obtains unit type codes from the permitting database. However, the information is not complete. A cross reference table for SCC to unit type code has been generated to fill the missing values. If an emission unit has multiple processes, the SCC for the first process is used. • In the FL system, the mapping of state codes to EIS code is not only based on state codes but also on the description of the emission units. One state unit type code could be mapped to multiple EIS codes depending on the description of the unit. For example, FL code of 10.01, Electric Utilities, could be mapped to 4 EIS codes (see Table B. 4.). Table B. 4. Example of Florida Codes Mapping to EIS Codes for the Unit Type Data Element EIS Code Description Notes for Mapping to EIS FL Code and Description 100 Boiler w/ "boiler" in EU desc 10.01 Electric Utilities 10.02 Industrial 10.03 Commercial/Institutional, Residential 10.04 Resource Recovery Boiler 10.07 Cogeneration Boiler 10.08 Boiler, < lOmmBtu/Hour 10.09 Bagasse Boiler 120 Turbine w/ "turbine", but not "combined cycle", in EU desc 10.01 Electric Utilities 11.02 Gas Turbines 140 Combined Cycle (Boiler/Gas Turbine) w/ "combined cycle" in EU desc 10.01 Electric Utilities 160 Reciprocating IC Engine w/ "engine" in EU desc 10.01 Electric Utilities 10.02 Industrial 10.03 Commercial/Institutional, Residential 11.01 Reciprocating Engines If a state like FL were to adopt the CAER system, CAERS could be designed to assist the facility by providing the four EIS codes that correspond to the one state code so the user could pick the right one. B-6 ------- It would show the code name, then the EIS descriptions for the four EIS codes. For example, CAERS could display a drop-down menu for the user to select as follows: 10.01 Electric Utilities - Boiler 10.01 Electric Utilities-Turbine 10.01 Electric Utilities - Combined cycle (Boiler/Gas Turbine) 10.01 Electric Utilities - Reciprocating IC Engine 3. SLTs can have more specific codes than EIS codes for the Unit Type data element so that multiple codes from one SLT are mapped to one EIS code, for a number of SLTs. Seven out of nine SLTs that have difference with EIS codes for the Unit Type data element show that behavior, including Colorado (CO), FL, Louisiana (LA), MN, MT, SCAA, and Wisconsin (Wl). For example, "GENERATOR" and "IC ENGINE" from WIDNR, map to EIS code 160 for Reciprocating IC Engine. Similarly, "BURN OFF OVEN," "HEATER," "OVEN" and "HEATER, SPACE" map to EIS code 290 for Other Combustion. B.3.3 Control Measure Data Element 1. SLTs have more specific codes for control measures than EPA uses in EIS. Nine out of 12 SLTs that have differences with EIS codes for the Unit Type data element show this behavior. For example: • EPA retired detailed control measures and combined multiple control measures to a new control measure, such as EIS code 127 for Fabric Filter / Baghouse, code 213 for Water Injection, and many different types of wet scrubbers to code 141 for Wet Scrubber. • In LA and MN, codes with the same descriptions as EIS retired codes are still used in their systems, such as Baghouse (EIS code 100), Steam or Water Injection (EIS code 28), and scrubber (EIS code 129). • Some EIS control measure codes are ambiguous and lead to confusion as to how to apply them, such as code 109 for Catalytic Oxidizer / Incinerator and code 133 for Thermal Oxidizer / Incinerator. Delaware (DE), Iowa (IA), and LA use code 109 only for Catalytic Oxidizer and code 133 only for Incinerator. • Multiple SLT control measures could be mapped to one EIS code. For example, MN uses control measure codes 906 for Fiberglass Filter with Cardboard Frame, and code 907 for Fiberglass Filter without Cardboard Frame. Those codes are mapped to the same EIS code 58 for Mat or Panel Filter. 2. Several SLTs do not report the Control Measure data element to EIS and usually use fewer codes in their systems than EIS. For example, Wl and Wyoming (WY) do not report this data element to NEI. Wl has 26 codes and WY has 21 codes, compared with 211 codes in EIS. B.3.4 Calculation Material Data Element and Calculation Parameter Unit of Measure 1. Calculation Parameter Unit of Measure is not always a separate data element in SLT systems. For example, MT system uses a combination of a numerator and a denominator for an emission factors where the denominator represents the calculation parameter unit of measure. B-7 ------- 2. Some SLTs do not actually transmit any of the Calculation Parameter Unit of Measure or Calculation Material data fields (which would be reported to SLTs as throughput) to NEl, for example, Louisiana, Wisconsin, and Wyoming. 3. It is not possible to find good matches for biomass solid, biomass liquid, and biomass dried in the EIS codes for Calculation Material. This is because biomass can include so many things that the materials list includes those very detailed items such as EIS codes: 1 Waste Material, 15 Wood, 18 wood waste, 425 agricultural products, 79 ethanol, etc. Perhaps there are missing items on the list such as certain types of waste that could be obtained from the Department of Energy's Energy Information Administration, and/or from those used specifically by SLTs. B.3.5 Emissions Calculation Method Data Element 1. Calculation Method is the most controversial data element among five data elements studied in this project. Although this data element must be present in SLT reports to the NEI with EIS codes, the use of the same EIS code is different from one SLT to another. For example: • Ml has an additional Emission Calculation Method Code "Facility EF", that is specifically for emission factors that come from that facility because emission factors could come from a variety of sources. This code is mapped to EIS code 10 "Site-Specific Emission Factor (no Control Efficiency used)", and used if the source and emission factor are uncontrolled or if the emission factor itself accounts for controls without need to apply a control efficiency in the emissions calculation. • EIS code 28 for "USEPA Emission Factor (pre-control) plus Control Efficiency," should be used if the selected emission factor was before controls and, therefore, a control efficiency was also used in the emissions calculation. However, some SLT system codes do not align exactly with EIS codes. For example, CT's classification for "EPA ALTERNATIVE EMISSION FACTOR" and "EPA EMISSION FACTOR" do not explicitly mention controls in their description. CT's current mapping behavior for reporting uncontrolled processes (combustion or otherwise) to EIS from its system would result in using the EIS Code 28. CAERS might need to present several "map to" options that could apply in this case, so the user can make the correct choice. • EIS does not have a description for Calculation Method code 2 "Engineering judgement." Some view it as a better factor to use than a "trade group emission factor" with respect to data quality, whereas others view it as the lowest level of data quality. In this case, the SLT might indicate a preference for when and how the engineering judgement code is used by the facility. • EIS code 8 "USEPA Emission Factor (no Control Efficiency used)," should be used if the source and corresponding Emission Factor are uncontrolled or if the Emission Factor itself accounts for controls without need to apply a control efficiency in the emissions calculation. However, North Carolina (NC) does not use EIS code 8 as defined. Instead, it uses it for any AP42 or WebFIRE emission factor regardless of whether a control efficiency is also used or not. 2. Incorrect mappings found during the survey got the attention of SLTs and will be improved in the future. For example, WY only takes uncontrolled WebFIRE emission factors in its system. If a process is controlled, WY will use uncontrolled emission factors plus control efficiencies. WY defines this calculation method as a throughput-based calculation method with code 109 that is B-8 ------- mapped to EIS code 8 "USEPA Emission Factor (no Control Efficiency used)" that is used if the source and Emission Factor are uncontrolled or if the Emission Factor itself accounts for controls without the need to apply a control efficiency in the emissions calculation. This mapping is correct for a process that is uncontrolled. However, if a process is controlled, WY's method should be mapped to EIS code 28 "USEPA Emission Factor (pre-control) plus Control Efficiency." WY is aware of the mismatch and will map it correctly in the future. Others 1. Reasons for not submitting emission factors. For example: The SCAA currently does not submit emission factors to EPA. Part of the reason is that it has not yet transitioned to tracking factors in its local database; all emission factors are documented/verified on an annual basis as part of facility inspections. The other reason is that the rigid format of the EPA system does not necessarily translate well to many of the factors SCAA uses. For example, lumber kiln emission factors are based on variables such as wood species and temperature, which change throughout the year. At the end of the year all the emissions are summed, so there is no one factor that applies to the process on a continuous basis. SCAA could "brute force" a factor (total emissions divided by total wood processed) that would work mathematically, but that may not reflect the reality of the situation and is not useful for planning purposes. 2. Other use cases. As mentioned in Section B.2, there may be situations related to these codes and how they are used that this survey did not capture, given that not all SLTs responded to the survey. Recommendations 1. Have default unit type assignment based on process SCCs in CAERS to auto-populate unit type codes for emission units without codes. CAERS can take the SCC for the first process for an emission unit type code if the emission unit has multiple processes with different SCCs. This could reduce the number of units reported blank or "unclassified". 2. Add more detailed control measure codes to EIS, to help make their use less ambiguous and confusing. In addition, provide additional guidance to code definitions to assist the user in understanding the proper use of the code. 3. Add biomass solid, biomass liquid, and biomass dried to the codes for Calculation Material. One option is for CAERS map to and show as many EIS codes as apply to biomass for states whose codes are described as "biomass" of some kind. 4. Codes for Unit Type need to be defined more clearly. B-9 ------- Appendix C Analysis of Codes Used in the Draft 2017 NEI The analysis was conducted based on draft 2017 NEI for point sources downloaded in October 2019 from EPA Emission Inventory website. Please note that because the 2017 NEI had not been finalized at the time of this report, data in the final version of the 2017 NEI may be different from that presented here. C.l Summary Information on Data Elements for the Project A summary of data is shown in Table C. 1. It should be noticed unit type code records were accounted based on number of distinct emission units. Each emission unit can have multiple processes with emissions for multiple pollutants. Therefore, the total records for Unit Type data element are less than total records for other data elements. The released NEI data do not contain information on control measures. The following analysis could only be made for other four data elements. Table C. 1. Summary of Data in the Draft 2017 NEI for the 5 Data Elements Data Element Number in EIS Code Table Number of Codes in the 2017 NEI Data Total Emissions Records in the 2017 NEI Data Percent of Unclassified in the 2017 NEI Data (%) Unit Type 201 73 433,757 37.2 Control Measure 124 N/A N/A N/A Calculation Parameter Unit of Measure 69 63 6,312,347 48.9 Calculation Material 637 472 6,312,347 48.9 Emission Calculation Method 23 23 6,312,347 0 Note: In NEI an emissions unit can have multiple processes, each used to report multiple pollutants. An emission record is a reported process and pollutant combination. C.2 Unit Type Data Element For the Unite Type data element used in draft 2017 NEI reporting, about 37.2 % of emission units were not reported with meaningful codes, but instead, were reported as unclassified. On the other hand, for 26 unit type codes, less than 10 units were reported to each code (for example, "Dry Kiln" and "Smelt Dissolving Tank". In addition, 128 EIS codes do not show up in the 2017 NEI. The nationwide distribution of number of emission units by codes for the Unit Type data element is listed in Table C. 2. Table C. 2. Distribution of Number of Emissions Unit Type Codes Used Unit Type Number Percent (%) Unclassified 161,150 37.2 Storage Tank 44,452 10.2 Open Air Fugitive Source 33,309 7.7 Reciprocating IC Engine 30,573 7.0 Other process equipment 28,716 6.6 Boiler 23,818 5.5 Spray Booth or Coating Line 9,605 2.2 C-l ------- Unit Type Number Percent (%) Process Heater 9,312 2.1 Transfer Point 8,293 1.9 Process Equipment Fugitive Leaks 7,904 1.8 Silo 7,292 1.7 Conveyor 5,580 1.3 Other combustion 5,567 1.3 Turbine 5,056 1.2 Other fugitive 4,814 1.1 Dryer, unknown if direct or indirect. 3,918 0.9 Flare 3,788 0.9 Other bulk material equipment 3,716 0.9 Furnace 3,443 0.8 Other evaporative sources 3,201 0.7 Screen 3,068 0.7 Crusher 2,924 0.7 Cooling Tower 2,859 0.7 Gasoline Loading Rack or Arm 2,601 0.6 Open Storage Pile 2,251 0.5 Printing Line 2,125 0.5 Incinerator 1,849 0.4 Grinder 1,579 0.4 Kiln 1,417 0.3 Mixer or Blender 1,294 0.3 Chemical Reactor 1,226 0.3 Degreaser 1,103 0.3 Process Equipment and Process Area Drains 1,016 0.2 Direct-fired Dryer 991 0.2 Distillation Column/Stripper 780 0.2 Open Tank or Vat 621 0.1 Roof vents/Building vents 611 0.1 Engine Test Cell 459 0.1 Indirect-fired Dryer 399 0.1 Combined Cycle (Boiler/Gas Turbine) 358 0.1 Calciner 255 0.1 Oxidation Unit 198 0.0 Open Burning 64 0.0 Duct Burner 57 0.0 Saw 57 0.0 Sander 12 0.0 Fermenter 10 0.0 C-2 ------- Unit Type Number Percent (%) Miscellaneous Coating Operation 8 0.0 Chipper/Flaker/Hammermill 6 0.0 Debarking Drum 5 0.0 Dry Kiln 5 0.0 Lumber Dry Kiln 5 0.0 Transfer System 5 0.0 Curing Oven 3 0.0 Electric Furnace 3 0.0 Smelt Dissolving Tank 3 0.0 Storage bin 3 0.0 Dechlorination Basin 2 0.0 Dry Rotary Dryer 2 0.0 Oil-Water Separator 2 0.0 Process Vent 2 0.0 Chip Conveyer 1 0.0 Chip Pile 1 0.0 Green Rotary Dryer 1 0.0 Non-TSDF Treatment, Storage, Disposal System 1 0.0 Paper Machine 1 0.0 Raw Material Grinder 1 0.0 Rotary Kiln 1 0.0 Rotary Strand Dryer 1 0.0 Secondary Crusher 1 0.0 Settling Pit 1 0.0 Softwood Veneer Dryer 1 0.0 Solvent Extraction Unit 1 0.0 Figure C.l. and Table C. 3. show the Unit Type data element codes used to report more than 10% of emission units in 2017 NEI reporting. Among those Storage: Tank, Open Air Fugitive Source, Reciprocating IC Engine, Other process equipment, and Boiler, are the top codes that contribute to more than 5% of reported emission units in the NEI. C-3 ------- Figure C. 1. Unit Type Codes to Report More Than 10% of Total 2017 NEI Emission Units Other 58 unit types (each < 1%) Other fugitive Turbine Other combustion Conveyor Silo Process Equipment Fugitive Leaks Transfer Point Process Heater Spray Booth or Coating Line Boiler Other process equipment Reciprocating IC Engine Open Air Fugitive Source Storage Tank Unclassified 0.0 5.0 10.0 15.0 20.0 25.0 30.0 35.0 40.0 Percent Table C. 3. Unit Type Codes to Report More Than 10% of Total 2017 NEI Emission Units Unit Type Number Percent (%) Unclassified 161,150 37.2 Storage Tank 44,452 10.2 Open Air Fugitive Source 33,309 7.7 Reciprocating IC Engine 30,573 7.0 Other process equipment 28,716 6.6 Boiler 23,818 5.5 Spray Booth or Coating Line 9,605 2.2 Process Heater 9,312 2.1 Transfer Point 8,293 1.9 Process Equipment Fugitive Leaks 7,904 1.8 Silo 7,292 1.7 Conveyor 5,580 1.3 Other combustion 5,567 1.3 Turbine 5,056 1.2 Other fugitive 4,814 1.1 C-4 11.1 ¦ 1.1 ¦ 1.2 M 2.1 H 2.2 ------- Unit Type Number Percent (%) Other 58 unit types (each < 1%) 48,147 11.1 Dryer, unknown if direct or indirect. 3,918 0.9 Flare 3,788 0.9 Other bulk material equipment 3,716 0.9 Furnace 3,443 0.8 Other evaporative sources 3,201 0.7 Screen 3,068 0.7 Crusher 2,924 0.7 Cooling Tower 2,859 0.7 Gasoline Loading Rack or Arm 2,601 0.6 Open Storage Pile 2,251 0.5 Printing Line 2,125 0.5 Incinerator 1,849 0.4 Grinder 1,579 0.4 Kiln 1,417 0.3 Mixer or Blender 1,294 0.3 Chemical Reactor 1,226 0.3 Degreaser 1,103 0.3 Process Equipment and Process Area Drains 1,016 0.2 Direct-fired Dryer 991 0.2 Distillation Column/Stripper 780 0.2 Open Tank or Vat 621 0.1 Roof vents/Building vents 611 0.1 Engine Test Cell 459 0.1 Indirect-fired Dryer 399 0.1 Combined Cycle (Boiler/Gas Turbine) 358 0.1 Calciner 255 0.1 Oxidation Unit 198 0.0 Open Burning 64 0.0 Duct Burner 57 0.0 Saw 57 0.0 Sander 12 0.0 Fermenter 10 0.0 Miscellaneous Coating Operation 8 0.0 Chipper/Flaker/Hammermill 6 0.0 Debarking Drum 5 0.0 Dry Kiln 5 0.0 Lumber Dry Kiln 5 0.0 Transfer System 5 0.0 Curing Oven 3 0.0 C-5 ------- Unit Type Number Percent (%) Electric Furnace 3 0.0 Smelt Dissolving Tank 3 0.0 Storage bin 3 0.0 Dechlorination Basin 2 0.0 Dry Rotary Dryer 2 0.0 Oil-Water Separator 2 0.0 Process Vent 2 0.0 Chip Conveyer 1 0.0 Chip Pile 1 0.0 Green Rotary Dryer 1 0.0 Non-TSDF Treatment, Storage, Disposal System 1 0.0 Paper Machine 1 0.0 Raw Material Grinder 1 0.0 Rotary Kiln 1 0.0 Rotary Strand Dryer 1 0.0 Secondary Crusher 1 0.0 Settling Pit 1 0.0 Softwood Veneer Dryer 1 0.0 Solvent Extraction Unit 1 0.0 Grand Total 433,757 Table C. 4. lists the number of emission units reported as "Unclassified" for the Unit Type data element and the percentage they represent from the total number of reported emission units for each SLT. Table C. 4. Number of Emission Units Reported as "Unclassified" by SLTsfor the Unit Tyi lenient Program System Code Total number of Emission Units Unclassified Percent of Unclassified (%) ADEM 4,720 515 10.9 AKDEC 4,089 183 4.5 AUCBOH 915 888 97.0 ARDEQ 3,854 1,297 33.7 AZDEQ 704 286 40.6 AZMCAQD 960 182 19.0 CARB 79,261 76,332 96.3 CHC_APCB 544 235 43.2 CODPHE 10,096 499 4.9 COHDNREM 19 13 68.4 CTBAM 1,246 426 34.2 DEDNR 1,175 674 57.4 DOEE 162 12 7.4 FLDEP 5,671 1,791 31.6 C-6 ------- Program System Code Total number of Emission Units Unclassified Percent of Unclassified (%) GADNR 5,800 474 8.2 HIDOHCAB 791 45 5.7 IADNR 11,315 2,364 20.9 IDDEQ 1,251 73 5.8 ILEPA 31,379 10,626 33.9 INDEM 5,304 4,475 84.4 KC_DAQM 34 5 14.7 KSDOHE 5,222 1,362 26.1 KYDAQ 20,199 12,245 60.6 KYJCAPCD 453 40 8.8 LADEQ08 22,884 3,508 15.3 LRAPA 139 35 25.2 MADEP 2,349 335 14.3 MDDOE 3,184 109 3.4 MEDEP 1,421 62 4.4 MIDEQ 10,162 1,616 15.9 MNPCA 16,724 4,314 25.8 MODNR 5,918 987 16.7 MSC_HD 705 346 49.1 MSDEQ 5,298 1,683 31.8 MTDEQ 2,260 70 3.1 NCBCRAQA 79 4 5.1 NCDAQ 10,610 604 5.7 NCFCEAD 252 6 2.4 NCMCAQ 146 30 20.5 NDC_MPHD 801 498 62.2 NDDOH 965 73 7.6 NEDEQ 2,954 138 4.7 NELLCHD 57 14 24.6 NEOPWD 191 64 33.5 NHDES 448 54 12.1 NJDEP 6,570 1,036 15.8 NMCOA 557 378 67.9 NMED 1,797 267 14.9 NVBAQ 3,043 88 2.9 NVCCDAQM 427 121 28.3 NVWCAQMD 43 4 9.3 NYDEC 2,837 778 27.4 OHEPA 9,918 7,364 74.2 OKDEQ 14,414 342 2.4 C-7 ------- Program System Code Total number of Emission Units Unclassified Percent of Unclassified (%) ORDEQ 1,777 152 8.6 PAACHD 1,306 44 3.4 PACOP 1,391 19 1.4 PADEP 9,627 684 7.1 PAG 49 11 22.4 PIMA 347 17 4.9 Pinal 222 14 6.3 PREQB 916 79 8.6 RIDEM 1,263 1,212 96.0 SCDHEC 3,412 1,245 36.5 SDDENR 948 151 15.9 TNDEC 2,389 780 32.6 TR124 83 6 7.2 TR180 7 4 57.1 TR181 19 7 36.8 TR182 6 3 50.0 TR206 5 0.0 TR207 3 0.0 TR380 1 0.0 TR405 2 0.0 TR610 1 1 100.0 TR614 1 1 100.0 TR615 41 4 9.8 TR750 1,686 37 2.2 TR751 2 0.0 TR780 9 4 44.4 TXCEQ 57,702 12,491 21.6 UTDAQ 3,004 124 4.1 VADEQ 2,755 877 31.8 VTDEC 264 105 39.8 WAECY 1,274 161 12.6 WAORCAA 162 25 15.4 WAPSCAA 413 78 18.9 WASWCAA 317 30 9.5 WIDNR 10,250 500 4.9 WVDAQ 2,925 2,219 75.9 WYDEQ 6,828 86 1.3 (blank) 27 9 33.3 6 Grand Total 433,757 161,150 37.2 C-8 ------- Some SLTs provide almost no information for emission units besides "Unclassified" such as California (CA) and Rhode Island (Rl). A detailed look at the 161,150 unclassified units shows that the majority of the emission units are associated with descriptions that could be specified with codes of Unit Type. Only about 4 % (6,995) emissions units do not have descriptions. C.3 Calculation Parameter Unit of Measure Data Elements Information about the Calculation Material data element in the 2017 NEI was either reported directly by SLTs (46.7% or all emission records) or incorporated by EPA (53.3% of all emission records). About 74.1 % of emission records were shown as "unclassified", blank, or null. From all emission records in the draft 2017 NEI, 48.9 % were blank or null. On the other hand, emission records identified for 12 codes for Calculation Parameter Unit of Measure are less than 100 each (such as "E6TON" or million tons, of which there are 66 instances, and "E6TON" or million tons, of which there are 42 instances) . In addition, 63 out of 69 EIS codes appear in the 2017 draft NEI and another 6 EIS codes do not appear in the 2017 draft NEI. The top fifteen most used units of measure used nationwide are shown in Figure C. 2 and the entire distribution of nationwide use of units of measure is listed in Figure C. 3. in descending order, excluding blanks and null entries. Figure C. 2. Nationwide Distribution of Top 15 Codes (Excluding Blank and Null) Used in the 2017 NEI for the Calculation Parameter Unit of Measure Data Element KW-HR E3LB E3FT3 E6GAL LB HP-HR HR GAL E6FT3S E6BTU E3GAL TON E6FT3 EACH Number of Emission Records i . L EPA ¦ SLT ¦ ALL 400,000 800,000 1,200,000 1,600,000 C-9 ------- Figure C. 3. Distribution of Number of Emission Records by Codes for the Calculation Parameter Unit of Measure Data Element Distribution of Number of Emission Records by Codes for the Calculation Parameter Unit of Measure Data Element Calculation Parameter Unit of ALL SLT EPA Measure Code (blank) 1,830,044 764,871 1,065,173 EACH 1,588,149 190,389 1,397,760 Null 1,256,832 1,256,832 E6FT3 559,832 436,468 123,364 TON 340,730 218,632 122,098 E3GAL 268,754 211,407 57,347 E6BTU 95,981 59,841 36,140 E6FT3S 92,178 42,983 49,195 GAL 65,634 45,607 20,027 HR 61,514 35,902 25,612 HP-HR 31,927 14,005 17,922 LB 27,764 20,754 7,010 E6GAL 15,783 14,017 1,766 E3FT3 8,282 5,094 3,188 E3LB 7,445 5,211 2,234 KW-HR 7,362 2,991 4,371 BBL 6,506 6,387 119 FT3 6,032 4,573 1,459 MILE 6,000 2,706 3,294 E3FT2 3,614 2,424 1,190 E3BDFT 3,607 2,376 1,231 E3FT3S 3,571 2,052 1,519 FT3S 3,170 1,944 1,226 E3BBL 2,859 2,724 135 ACRE-YR 2,585 1,850 735 FT3S/M-Y 1,891 834 1,057 YD3 1,856 869 987 E3HP-HR 1,550 1,173 377 BDFT 1,052 664 388 E3TON 935 573 362 GPM-YR 855 504 351 E3EACH 781 473 308 ACRE 752 354 398 E6LB 723 536 187 FT2 470 312 158 FT3SD 460 317 143 E2LB 435 289 146 C-10 ------- Calculation Parameter Unit of ALL SLT EPA Measure Code E2TON 432 195 237 FT 390 251 139 THERM 331 193 138 YD2 321 255 66 E6FT2 315 182 133 BUSHEL 309 117 192 E6BDFT 309 178 131 DAY 253 174 79 E2BBL 226 226 BALE 212 48 164 M3 203 170 33 KG 175 109 66 E3AMP-HR 141 84 57 YD3-MILE 137 54 83 MEGAGRAM 135 100 35 AMP-HR 120 52 68 E3FT 79 61 18 E3YD3 70 43 27 E3MILE 66 32 34 E4FT2 61 36 25 E6TON 42 37 5 ACRE-DAY 27 10 17 E5HP-HR 25 5 20 E3BU 20 11 9 TON-MILE 16 6 10 HECTR 15 9 6 BBL50GAL 1 1 E3BBL31G 1 1 Total 6,312,347 3,361,578 2,950,769 From Table C. 3, we can see that the code "EACH" is the most popular one used, but mainly by EPA. About 98.5% of the records using the code "EACH" are associated with a calculation material of the Landing-Takeoff Cycle used in estimating airport emissions by EPA. On the other hand, code "E6FT3" representing Million Cubic Feet is the most popular one used by SLTs, probably for representing the use of natural gas in combustion. Other top used codes seem related to combustion processes as well, such as "E3GAL" or thousand gallons, and "E6BTU" or million British Thermal Units. Table C. 6. shows the distribution of the top 9 codes, including blank and null, for the Calculation Material Unit of Measure Data Element by reporting SLT in the draft 2017 NEI. It shows that 44 SLTs out of 82 did not report the Calculation Parameter Unit of Measure data element to the NEI, for example, C-ll ------- Alabama, California, Colorado, lllinoi, Wisconsin, and Wyoming. A detailed list of the SLTs that did not report this data element to the 2017 draft NEI is shown in Table C. 7. Table C 5. Distribution of Top 9 Codes (Including Blank and Null) for the Calculation Material Unit of Measure Data Element in the 2017 NEI Program System Code SLT Total Null (blank) E6FT3 TON E3GAL EACH E6BTU GAL E6FT3S ADEM 32,552 32,552 AKDEC 21,285 2,713 278 389 348 478 8,703 3,843 AUCBOH _____ _____ ARDEQ 19,031 128 2,605 4,879 539 235 2,470 813 1,519 AZDEQ 13,373 1,886 917 3,131 337 72 1,674 198 840 AZMCAQD 1,916 1,916 CARB 656,565 656,565 CHC_APCB 1,878 1,878 CODPHE 39,302 39,302 CTBAM 17,443 103 6,486 1,389 9,329 9 88 DEDNR ______ —— 5,938 _____ _____ ___ ___ ____ _____ DOEE 2,244 2,244 FLDEP _____ —— 8,043 _____ _____ 89 ___ GADNR 18,510 119 3,277 5,415 1,313 71 1,025 1,707 1,474 HIDOHCAB 7,324 138 11 595 4,639 111 133 1,571 IADNR 52,841 505 12,821 9,639 4,092 202 4,338 6,854 386 IDDEQ 4,048 1,240 1,249 1,077 187 10 ILEPA 317,766 317,766 INDEM 33,302 11,291 22,011 KC_DAQM 82 I 82 KSDOHE 36,167 1,316 6,202 | 4,433 3,996 306 I 7,135 709 ' ' KYJCAPCD 11,988 212 2,209 1,865 195 702 749 I 1,191 308 LADEQ08 100,100 100,100 LRAPA 399 399 MADEP 11,054 20 4,015 1,066 4,808 116 806 | 39 80 MDDOE 26,461 8,375 18,086 MEDEP 18,828 40 6,207 2,865 8,239 11 119 1,010 26 MIDEQ 98,464 1,665 56,665 15,476 22,005 112 98 1,567 MNPCA MODNR MSC_HD 305,798 25,037 _____ 25,037 20,046 _____ 131,986 48,329 69,692 14,026 2,454 649 MSDEQ 45,877 45,877 MTDEQ 7,849 7,849 NCBCRAQA 1,614 1,614 C-12 ------- Program System Code SLT Total Null (blank) E6FT3 TON E3GAL EACH E6BTU GAL E6FT3S NCDAQ 84,376 611 8,929 19,387 1,781 1,402 5,318 13,741 5,208 NCFCEAD 2,167 482 258 6 818 75 99 25 NCMCAQ 301 301 NDC_MPHD 5,004 5,004 NDDOH 1,890 1,890 NEDEQ 12,098 12,098 NELLCHD 197 197 NEOPWD 970 970 NHDES 3,164 123 1,103 465 1,408 33 NJDEP _____ 49,414 _____ 10 _____ NMCOA 2,596 476 180 88 185 125 35 NMED 7,583 2,504 27 222 4,830 NVBAQ 12,872 12,872 NVCCDAQM 1,835 1,835 NVWCAQMD 48 48 NYDEC 41,064 41,064 OHEPA 109,565 4,448 72,918 18,267 11,564 282 783 161 OKDEQ 75,586 647 7,711 3,697 13,529 723 14,727 1,268 18,880 ORDEQ 12,430 54 3,811 3,001 476 560 806 55 PAACHD _____ ___ _____ ____ _____ ___ —— PACOP _____ 5,243 —— 4,708 26~ —— PADEP 54,864 | 376 28,076 14,243 9,971 37 252 1,140 PIMA 1,323 1,323 | PREQB 5,109 5,109 RIDEM 8,278 8,278 SCDHEC 99,519 17,635 35,421 12,253 15,244 305 13,630 860 371 SDDENR 2,333 2,333 TNDEC 30,009 22,118 537 5,035 578 50 14 294 1,011 TR124 ___ ___ TR180 46 46 TR181 lgo 180 TR182 29 29 TR207 4 4 TR615 406 406 TR750 6,193 6,187 6 TR751 7 7 TXCEQ 381,365 238,500 142,865 UTDAQ 20,166 827 6,268 3,520 2,183 66 1,774 226 26 VADEQ _____ ________ C-13 ------- Program System Code SLT Total Null (blank) E6FT3 TON E3GAL EACH E6BTU GAL E6FT3S VTDEC 836 836 WAECY 7,930 1,085 2,879 1,332 1,071 6 137 121 60 WAORCAA 601 601 WAPSCAA 1,141 1,141 WASWCAA 1,448 88 214 115 139 592 38 41 16 WIDNR 23,570 23,570 WVDAQ 25,581 417 7,085 5,900 1,890 4,699 1,319 686 1,043 WYDEQ 132,336 132,336 Grand Total 3,361,578 1,256,832 764,871 436,468 218,632 211,407 190,389 59,841 45,607 42,983 Table C. 6. SLTs That Didri't Report to the 2017 Draft NEIfor the Calculation Parameter Unit of Measure Data Element Program System Code Program System Code Program System Code ADEM MTDEQ SDDENR AUCBOH NCBCRAQA TR124 AZMCAQD NCMCAQ TR180 CARB NDC_MPHD TR181 CHC_APCB NDDOH TR182 CODPHE NEDEQ TR207 DOEE NELLCHD TR615 ILEPA NEOPWD TR751 KC_DAQM NVBAQ VADEQ KYDAQ NVCCDAQM VTDEC LADEQ08 NVWCAQMD WAORCAA LRAPA NYDEC WAPSCAA MODNR PIMA WIDNR MSC_HD PREQB WYDEQ MSDEQ RIDEM C.4 Calculation Material Data Element For reporting, information for the Calculation Material data element is paired with the calculation parameter unit of measure. Therefore, distribution of emission records between the SLT and EPA is identical to the distribution of the Calculation Parameter Unit of Measure data element in the 2017 NEI. It was reported by either the SLTs (46.7% of emission records) or incorporated by EPA (53.3% or emission records). About 48.9 % of emission records were shown as blank (null is not there but combined with blank due to the data format in the draft 2017 NEI). On the other hand, emission records identified for 92 codes for the Calculation Material data element are less than 10 each. In addition, 473 out of 637 EIS codes show up in the 2017 NEI and another 224 EIS codes are not found. The nationwide distribution of C-14 ------- codes between SLT and EPA in the draft 2017 NEI for the Calculation Material data element is in Table C. 8. The number in the table represents emission records. C-15 ------- Table C. 7. Distribution of Codes between SLT and EPA for the Calculation Material Data Element in the 2017 Draft NEI Calculation Material Code ALL SLT EPA Calculation Material Code ALL SLT EPA (blank) 3,086,876 2,021,703 1,065,173 Grit 116 49 67 Landing-Takeoff Cycle 1,517,384 142,865 1,374,519 Jet Naphtha 112 94 18 Natural Gas 722,911 500,519 222,392 Sulfur 112 85 27 Fuel 101,325 74,964 26,361 Refinery Crude Feed 111 96 15 Distillate Oil (Diesel) 96,356 78,694 17,662 Make-Up Solvent 104 97 7 Diesel 81,391 47,794 33,597 Blast 100 75 25 Material 78,803 51,237 27,566 Boat 100 75 25 Distillate Oil (No. 2) 38,193 22,936 15,257 Overburden 95 32 63 Process Unit 28,117 20,062 8,055 Butane 92 86 6 Distillate Oil 20,713 16,600 4,113 Crushed Stone 92 29 63 Product 19,024 12,002 7,022 Charcoal 91 60 31 Residual Oil 16,247 9,861 6,386 Cottonseed 91 40 51 Wood 16,050 10,247 5,803 Isopropanol 89 87 2 Gasoline 15,403 14,250 1,153 Ethylene Glycol 87 83 4 Process Gas 14,814 12,894 1,920 Shingles 87 50 37 Body 14,400 13,495 905 Sulfuric Acid 85 47 38 Raw Material 14.053 7,395 6.658 Polyester/Alkyd Resin 84 60 24 Wastewater 13,345 13,256 89 Zinc 84 38 46 Grain 12,844 5,241 7,603 Alloy 80 44 36 Crude Oil 12,511 12,424 87 Sodium Carbonate 80 27 53 Wood/ Bark 9,663 6,405 3,258 Yeast 77 44 33 Coating 9,614 7,158 2,456 Cereal 76 26 50 Work 9,407 5,554 3,853 Lubrication 76 42 34 Metal 9,370 5,847 3,523 Thinning Solvent 75 64 11 Propane 8,510 6,660 1,850 Glaze 73 25 48 Distillate Oil (No. 1 & 2) 8,397 6,006 2,391 Polyvinyl Chloride 71 67 4 Coal 8,333 4,858 3,475 Pieces 69 63 6 C-l ------- Calculation Material Code ALL SLT EPA Calculation Material Code ALL SLT EPA Paint 7,710 5,489 2,221 Beans 67 19 48 Landfill Gas 7,634 6,176 1,458 Adipic Acid 66 30 36 Heat 7,354 5,811 1,543 Olefin 66 40 26 Asphalt 7,220 6,015 1,205 Resin or Wax 66 46 20 Refinery Gas 7,142 5,980 1,162 Fired Ceramic 64 28 36 Hot Mix Asphalt 6,989 6,085 904 Dextrose 63 34 29 Coating Mix 6,613 4,937 1,676 Nitric Acid 63 55 8 Residual Oil (No. 6) 6,540 4,590 1,950 Agent 62 34 28 Distillate 6,484 6,141 343 Extractor Feed Cake 62 37 25 Cement 6,433 2,721 3,712 Raw Beets 61 28 33 Solvent 6,359 5,661 698 Cans 60 42 18 Lime 6,113 4,187 1,926 Topsoil 60 16 44 Liquified Petroleum Gas (LPG) 5,996 4,728 1,268 Ethylene Oxide 59 59 Solvent in Coating 5,530 4,134 1,396 Glycol Ethers 59 45 14 Electricity 5,526 2,100 3,426 Wet Mixed Slurry 58 37 21 Unit 5,515 2,823 2,692 Petroleum Distillate 57 54 3 Equipment 5,411 3,487 1,924 Whiskey 57 55 2 Condensate 5,358 5,349 9 Pressed Wet Pulp 55 43 12 Bituminous Coal 5,280 4,420 860 Raw Coke 55 34 21 Clay 4,723 1,895 2,828 Storage Pile 55 21 34 Sand 4,577 1,825 2,752 Wax 55 28 27 Finished Product 4,349 2,516 1,833 Phosphate Rock 54 28 26 Vehicle 4,317 2,151 2,166 Carbon Dioxide 53 45 8 Ethanol 4,196 3,429 767 Saturated Felt 53 28 25 Energy 4,075 2,514 1,561 Slip 53 32 21 Steel 3,909 2,067 1,842 Sinter 52 25 27 Ink 3,768 3,543 225 Tank Truck 52 34 18 Liquid 3,761 3,623 138 Acid 51 30 21 C-2 ------- Calculation Material Code ALL SLT EPA Calculation Material Code ALL SLT EPA Cooling Water 3,705 1,797 1,908 Acetone 50 40 10 Solid Waste 3,566 2,911 655 Asphalt Shingles/Rolls 48 31 17 Ore 3,474 2,752 722 Reclaimed Solvent 48 38 10 Limestone 3,303 1,446 1,857 Triethylene Glycol 48 43 5 Brick 3,283 2,210 1,073 Area 47 30 17 Petroleum Liquid 3,239 3,111 128 Grader 47 29 18 VOCs 3,221 2,832 389 Coal Tar 46 26 20 Pellets 3,218 2,462 756 Cullet 45 15 30 Black Liquor Solids 3,184 2,911 273 Trichloroethylene 45 44 1 Subbituminous Coal 3,156 2,615 541 Seal 42 42 Corn 3,118 1,540 1,578 Hydrogen Sulfide 41 38 3 Waste Gas 2,863 2,360 503 Waste Liquid 41 35 6 Plastic 2,804 1,695 1,109 Flange 40 40 Item 2,773 1,699 1,074 Pipeline 40 14 26 Paper 2,692 2,466 226 Vacuum Feed 40 40 Soybeans 2,642 1,083 1,559 Dried Blood Meal 39 26 13 Clinker 2,627 1,590 1,037 Pure Acid 39 30 9 Steam 2,627 1,637 990 Vinyl Acetate 34 32 2 Air-Dried Unbleached Pulp 2,437 2.192 245 Carbon Tetrachloride 33 33 Feed Material 2,436 1,191 1,245 Methylene Chloride 32 32 Gas 2,383 1,975 408 Tank Car 32 26 6 Acrylonitrile 2,301 1,715 586 Zinc Oxide 32 19 13 Waste Oil 2,298 1,676 622 Tu rpentine 31 22 9 Average Airflow 2,289 961 1,328 Cold Cleaner 30 28 2 Wood Waste 2,255 923 1,332 Cotton 30 6 24 Exhaust Gas 2,071 1,427 644 Hole 30 23 7 Ash 2,041 1,033 1,008 Benzene 29 29 Landfill 1,987 1,704 283 Methyl Ethyl Ketone 29 29 Pulp 1,978 1,840 138 Sour Gas 29 25 4 C-3 ------- Calculation Material Code ALL SLT EPA Calculation Material Code ALL SLT EPA Starch 1,931 960 971 Acetylene 28 21 7 Iron 1,894 955 939 Solid Propellant 28 18 10 Waste 1.827 1,305 522 Wood/Vegetation/Leaves 28 15 13 Rock 1,769 794 975 Alkane 27 27 Styrene-Butadiene Rubber 1,650 1,294 356 Bauxite Material 27 15 12 Coke 1,601 1,199 402 Chloroform 27 27 Resin 1,524 1,186 338 Degreaser 27 24 3 Bark 1,498 774 724 Maleic Anhydride 27 27 Refinery Feed 1,487 1,433 54 Photoresist 27 27 Kerosene 1,433 1,052 381 Anhydrous Ammonia 26 23 3 Jet Fuel 1,395 1,100 295 Chromic Acid 26 8 18 Oil 1,311 1,031 280 Sodium Bicarbonate 26 11 15 Abrasive 1,298 474 824 Xylenes (Mixed) 26 26 ! Stone 1,298 432 866 Beaded Glass 25 13 12 Crude Gypsum 1,278 510 768 Green Beans 25 5 20 Exposed Area 1,264 918 346 Thinned Resin 25 18 7 Adhesive 1,252 986 266 Drum 24 12 12 Dried Sludge 1,249 1,084 165 Lead Product 24 13 11 Water 1,192 606 586 Specialty Steel 24 15 9 Glass 1,174 779 395 Wafers 24 24 Distillate Oil (No. 4) 1,151 989 162 n-Hexane 23 19 4 Methanol 1,149 1,050 99 Hydrogen 22 16 6 Soybean Meal 1,146 483 663 n-Propyl Alcohol 22 18 4 Produced Water 1,105 1,098 7 Phosphorous 22 19 3 Oven-dried Wood 1,028 714 314 Construction Activity 21 13 8 Aluminum 967 626 341 Fish 21 14 7 Specialty Chemical 959 677 282 Formaldehyde 21 21 Bituminous/Subbituminous 920 764 156 Alumina 20 6 14 Coal C-4 ------- Calculation Material Code ALL SLT EPA Calculation Material Code ALL SLT EPA Tires 906 783 123 Concentrate 20 13 7 Sawdust 878 503 375 Pipe 20 8 12 Slag 844 340 504 Ether 19 11 8 Methane 827 561 266 Ethyl Acetate 19 19 Electrode 825 403 422 Toner 19 13 6 Wood Refuse 804 757 47 Phenol 18 16 2 Jet Kerosene 786 654 132 Isopentane 17 17 Dual Fuel (Gas/Oil) 774 497 277 p-Cresol 17 17 Sludge 757 606 151 Phosphoric Acid 17 11 6 Refuse Derived Fuel 743 576 167 Amine 16 16 3/8-inch Plywood 742 485 257 Dried Grain 16 11 5 Welding Rod 736 337 399 EAF Dust 16 15 1 Gray Iron 733 504 229 Sulfur Dioxide 16 14 2 Facility 732 449 283 Coolant 15 9 6 Board 721 500 221 Dried Beans 15 3 12 Naphtha 706 689 17 Scraper 15 5 10 Diesel/Kerosene 704 505 199 Syrup 15 12 3 Lead 700 557 143 Perchloroethylene 14 13 1 Anthracite 662 467 195 Aqueous Ammonia 13 13 Coating Material 647 456 191 Propylene Oxide 13 13 Sugar 639 248 391 Solvent/Water 13 9 4 Solvents: All 629 608 21 Acetic Acid 12 12 Coke Oven Gas 607 520 87 Anhydride 12 4 8 Cores 604 411 193 Deadener 12 12 3/8-inch Oriented Strand Board 597 391 206 Propylene 12 12 Storage Area 592 374 218 Sump Area 12 12 Logs 589 241 348 Xylene 12 12 Residual Oil (No. 5) 578 442 136 Monomer 11 11 C-5 ------- Calculation Material Code ALL SLT EPA Calculation Material Code ALL SLT EPA Starting Monomer 562 537 25 Anthracite Culm 10 4 6 Castings 526 217 309 Forests 10 7 3 Chips 496 249 247 Halogenated Organic 10 10 3/4-inch Particleboard 473 364 109 MDI 10 10 Dry Material 469 223 246 Aromatic 9 9 Concrete 468 132 336 Creosote 9 5 4 Molten Aluminum 445 334 111 Final Acid 9 5 4 Liquid Waste 442 340 102 Hydrogen Chloride 9 6 3 Salt 436 288 148 Methyl Chloride 9 9 Tile 432 278 154 Acetaldehyde 8 5 3 Air-Dried Bleached Pulp 417 408 9 Acetic Anhydride 8 8 Bagasse 410 369 41 Hydrofluoric Acid 8 4 4 Benton ite 408 325 83 Isobutylene 8 5 3 Carbon Black 402 204 L98 Methyl Isobutyl Ketone 8 8 Medical Waste 393 325 68 n-Propyl Acetate 8 8 Urea 392 238 154 tert-Butyl Alcohol 8 8 Makeup 376 193 183 Butyl Acetate 7 7 Wafers/Chips 373 31 342 Crude Ore 7 7 Peanuts 358 150 208 Ester 7 3 4 Concentrated Ore 355 305 50 Hydrogen Fluoride 7 7 Digester Gas 340 232 108 Appliance 6 3 3 Dried Germ 340 221 119 Asbestos 6 2 4 TNT 330 250 80 Clothes 6 2 4 Refined Oil 327 321 6 Dimethylformamide 6 6 Batteries 323 143 180 Dryer Feed 6 3 3 Dyes/Pigments 321 246 75 o-Xylene 6 6 Jet A Fuel 317 264 53 Residues/Skimmings 6 3 3 Bread 315 255 60 Toluene Diisocyanate 6 6 Storage Tank 312 312 ABS Polymer 5 4 1 C-6 ------- Calculation Material Code ALL SLT EPA Calculation Material Code ALL SLT EPA Solvent in Ink 311 307 4 Casein 5 1 4 Parts 297 191 106 Diethylene Glycol 5 5 Pigment 293 183 110 Dried Malt 5 4 1 Sealer 291 203 88 Employee 5 2 3 Fresh Feed 285 248 37 Flue Dust 5 4 1 Product Surface Area 279 196 83 Land 5 2 3 Fiber 277 169 108 Methyl Amyl Ketone 5 5 Hydrated Lime 275 162 113 Mixing Material 5 1 4 Shot 270 102 168 n-Heptane 5 5 Charge 269 167 102 Silico manganese 5 2 3 Catalyst 262 152 110 Aerosol 4 4 Ammonium Nitrate 252 154 98 Butadiene 4 4 Hot Metal 250 138 112 Cellosolve 4 4 Lead Oxide 247 135 112 Formalin 4 4 Particleboard 247 139 108 Freon 4 4 Glycol 242 241 1 Isobutyl Alcohol 4 4 Solution 239 209 30 Neoprene 4 4 Coke Oven or Blast Furnace Gas 236 181 55 Thin Juice 4 4 Surface Area 226 159 67 Area Sludge Applied 3 3 Corn Gluten Feed 224 141 83 Carbon Monoxide 3 3 Ammonia 222 204 18 Drain 3 3 Refuse 222 159 63 Ketone 3 3 Beer 218 173 45 m-Xylene 3 3 Varnish 216 162 54 Printing Line 3 3 Feed 215 143 72 Propane/Butane 3 3 Meal 214 89 125 Propylene Glycol 3 3 Lube Oil 213 205 8 Pure Solvent 3 3 Fabric 210 187 23 p-Xylene 3 3 C-7 ------- Calculation Material Code ALL SLT EPA Calculation Material Code ALL SLT EPA Stock 210 110 100 Raw Juice 3 3 3/4-inch Medium Density 205 128 77 Solvent in Drawing 3 3 Fiberboard Compound Primer 205 145 60 2,4-Dichlorophenol 2 2 Dry Sawdust 200 147 53 Acrylic Acid 2 2 Dried Hulls 196 95 101 Butyl Cellosolve 2 2 Waste Material 194 101 93 Carbon Disulfide 2 2 Carpet 189 116 73 Containers 2 2 ! Meat 189 97 92 Dimethyl Sulfoxide 2 2 Wine 189 165 24 Dye 2 2 Coal Storage Area 184 80 104 Ethyl Acrylate 2 2 Fertilizer 182 77 105 Ethylene Dichloride 2 2 Sprayed Metal 179 77 102 Mercury 2 2 Dried Material 177 81 96 n-Butyl Alcohol 2 2 Asphaltic Concrete 176 70 106 Phthalic Anhydride 2 2 Soil 176 124 52 Tetrahydrofuran 2 2 Bulldozer 169 89 80 Well 2 2 Finished Pellet 167 69 98 1,4-Dioxane 1 1 Vegetation 167 104 63 1-Pentene 1 1 Scrap 162 89 73 Cyclohexanol 1 1 Natural Gas Liquids 160 140 20 Cyclohexanone 1 1 Valve 160 160 Dimethylamine 1 1 Gravel 159 44 115 Ethane 1 1 Distillate Oil (No. 1) 153 126 27 Ethyl Ether 1 1 Hydrochloric Acid L49 94 55 Ethylbenzene/Styrene 1 1 Styrene 148 144 4 Formic Acid 1 1 Liquor 147 130 17 Head of Cattle 1 1 Coating Line 145 102 43 Isobutyl-isobutyrate 1 1 Dry Product 138 68 70 Isopropyl Acetate 1 1 C-8 ------- Calculation Material Code ALL SLT EPA Calculation Material Code ALL SLT EPA Ethylene 138 125 13 Malted Grain 1 1 Toluene L36 L35 1 Methyl-tert-Butyl Ether 1 1 Corn Gluten Meal 135 81 54 Monoethanolamine 1 1 Wet Coal 129 115 14 Naphthalene 1 1 100% Sulfuric Acid 128 103 25 Nitrogen 1 1 Chlorine 127 91 36 n-Pentane 1 1 Alcohol 125 121 4 Perc & Trichloroethylene 1 1 Waferboard 125 93 32 sec-Butyl Alcohol 1 1 100% Sulfur 121 104 17 Solvents: NEC 1 1 Phosphate 120 48 72 Special Naphthas 1 1 P205 119 56 63 Vinyl Chloride 1 1 Total 6,312,347 3,361,578 2,950,769 C-9 ------- Figure C. 4. shows the nationwide distribution of the top 15 codes (excluding blank) used in the 2017 NEI for the Calculation Material data element. It shows that the code of Landing-Takeoff-Cycle is the most popular used one, but mainly by EPA. It is for the airport emissions that estimated mainly by EPA. On the other hand, the code of Natural Gas is the most popular one used by SLT, presenting the use of it in combustion processes. Other 13 out of the top 15 used codes are mainly used by SLTs. Most top 15 codes for the Calculation Material data element are related to combustion process as observed in the analysis for the calculation parameter unit of measure data element. Figure C. 4. Nationwide Distribution of Top 15 Codes (Excluding Blanks) Used in the 2017 Draft NEI for the Calculation Material Data Element Process Gas Gasoline Wood Residual Oil Product Distillate Oil Process Unit Distillate Oil (No. 2) Material Diesel Distillate Oil (Diesel) Fuel Natural Gas Landing-Takeoff. 0 400,000 800,000 1,200,000 1,600,000 Number of Emission Records Table C. 9 lists the distribution of the top 20 codes (excluding blanks) used by SLTs for the Calculation Material data element in the 2017 NEI. The order of the columns in the table indicates the order of code usage in all SLTs from the most used to the least used. The number in the table represents emission records. Table C. 8. Nationwide Distribution of Top 20 Codes (Excluding Blanks) Used in the 2017 Draft NEI for the Calculation Material Data Element Calculation Material ALL SLT EPA (blank) 3,086,876 2,021,703 1,065,173 Landing-Takeoff Cycle 1,517,384 142,865 1,374,519 Natural Gas 722,911 500,519 222,392 Fuel 101,325 74,964 26,361 C-l ------- Distillate Oil (Diesel) 96,356 78,694 17,662 Diesel 81,391 47,794 33,597 Material 78,803 51,237 27,566 Distillate Oil (No. 2) 38,193 22,936 15,257 Process Unit 28,117 20,062 8,055 Distillate Oil 20,713 16,600 4,113 Product 19,024 12,002 7,022 Residual Oil 16,247 9,861 6,386 Wood 16,050 10,247 5,803 Gasoline 15,403 14,250 1,153 Process Gas 14,814 12,894 1,920 Body 14,400 13,495 905 Raw Material 14,053 7,395 6,658 Wastewater 13,345 13,256 89 Grain 12,844 5,241 7,603 Crude Oil 12,511 12,424 87 Wood/Bark 9,663 6,405 3,258 C-2 ------- Table C.3. Distribution of Top 3 Codes (Excluding Blanksj Used by SLTsfor the Calculation Material Data Element Program System Code SLT Total (blank) Natural Gas Landing- Takeoff Cycle Distillate Oil (Diesel) Fuel Material Diesel Distillate Oil (No. 2) Process Unit ADEM 32,552 32,552 AKDEC 21,285 2,713 6,766 590 74 4 7083 126 AUCBOH 5,382 5,382 ARDEQ 19,031 128 5,973 581 45 1,445 1224 200 10 AZDEQ 13,373 1,886 2,174 758 2 960 349 63 AZMCAQD 1,916 1,916 CARB 656,565 656,565 CHC_APCB 1,878 1,878 CODPHE 39,302 39,302 CTBAM 17,443 103 6,477 33 119 3058 4,640 DEDNR 13,762 63 5,024 1,870 1 238 636 747 4 DOEE 2,244 2,244 FLDEP 27,091 382 7,211 4,329 33 1,606 1088 149 39 GADNR 18,510 119 6,352 239 99 31 491 1,351 7 HIDOHCAB 7,324 138 141 27 552 1,202 IADNR 52,841 505 16,161 I 239 83 4,530 5165 811 IDDEQ 4,048 1,099 | —— —— ____ IF" ILEPA 317,766 317,766 INDEM 33,302 11,291 8,040 697 49 2,073 321 90 55 KC_DAQM 82 82 KSDOHE 36,167 1,316 13,534 88 66 1,362 1667 616 251 KYDAQ 118,190 118,190 KYJCAPCD 11,988 212 2,719 676 290 152 LADEQ08 100,100 100,100 LRAPA 399 399 MADEP 11,054 20 4,432 21 201 2662 1,235 41 C-3 ------- Program System Code SLT Total (blank) Natural Gas Landing- Takeoff Cycle Distillate Oil (Diesel) Fuel Material Diesel Distillate Oil (No. 2) Process Unit MDDOE 26,461 8,375 9,093 199 MEDEP 18,828 40 5,961 4,042 225 452 149 8 MIDEQ 98,464 1,665 55,254 43 2,353 15973 18 35 MNPCA 305,798 20,046 128,218 | 49,853 22 9,786 47 614 | MODNR 25,037 _____ MSC_HD 5^359~ _____ MSDEQ 45,877 45,877 MTDEQ 7,849 7,849 NCBCRAQA 1,614 1,614 NCDAQ 84,376 611 | 73,153 10,612 NCFCEAD 2,167 696 32 433 22 234 NCMCAQ 301 301 NDC_MPHD 5,004 5,004 NDDOH 1,890 1,890 NEDEQ 12,098 12,098 NELLCHD 197 197 NEOPWD 970 970 NHDES 3,164 123 670 505 330 NJDEP 53,547 49,414 3,104 515 326 NMCOA 2,596 476 648 248 24 67 424 12 20 NMED 7,583 2,504 4,445 38 39 1 NVBAQ 12,872 12,872 NVCCDAQM 1,835 1,835 NVWCAQMD 48 48 NYDEC 41,064 41,064 OHEPA 109,565 4,448 69,345 6,016 1 4,805 20 34 OKDEQ 75,586 647 45,212 633 8 154 978 282 3 C-4 ------- Program System Code SLT Total (blank) Natural Gas Landing- Takeoff Cycle Distillate Oil (Diesel) Fuel Material Diesel Distillate Oil (No. 2) Process Unit ORDEQ 12,430 54 3,872 73 1,332 110 4 PAACHD 8,716 35 2,982 36 318 4,711 PACOP 10,847 4,685 428 2,315 2,627 PADEP 54,864 376 26,345 216 1519 4,724 7,648 PIMA 1,323 ___ PREQB 5,109 _____ RIDEM 8,278 8,278 SCDHEC 99,519 17,635 36,626 6,252 295 3,514 2532 904 215 SDDENR 2,333 2,333 TNDEC 30,009 22,118 1,582 45 590 99 662 1 TR124 294 294 TR180 46 46 TR181 180 180 TR182 29 29 TR207 __ 4 TR615 406 406 TR750 6,193 6,187 6 TR751 7 7 TXCEQ 381,365 238,500 142,865 UTDAQ 20,166 827 4,425 199 336 876 42 395 VADEQ 12,272 12,272 VTDEC 836 836 WAECY 7,930 1,085 1,114 159 76 361 58 54 WAORCAA 601 601 WAPSCAA 1,141 1,141 WASWCAA 1,448 88 244 37 174 WIDNR 23,570 23,570 C-5 ------- Program System Code SLT Total (blank) Natural Gas Landing- Takeoff Cycle Distillate Oil (Diesel) Fuel Material Diesel Distillate Oil (No. 2) Process Unit WVDAQ 25,581 417 9,889 505 2,235 311 36 4,349 WYDEQ 132,336 132,336 Grand Total 3,361,578 2,021,703 500,519 142,865 78,694 74,964 51,237 47794 22,936 20,062 C-6 ------- Table C.ll., 44 out 82 SLTs that reported emissions did not report the calculation parameter unit of measure data element to the NEl, for example, Alabama, California, Colorado, Illinois, Wisconsin, and Wyoming. This observation is the same as that for the calculation parameter unit of measure data element in the 2017 NEI. The detailed list of SLTs that did not report the Calculation Material data element to the 2017 draft NEI is the same as that in Table C.8. C.5 Emission Calculation Method Data Element Information about the emission calculation method is a required data element in NEI. Each emission record must be associated with the data element. The 2017 NEI contains emission data for 102 SLTs. Among those, 23 SLTs reported more than 50% of emission records, 59 SLTs reported less than 50% emission records, and 10 locals and tribes did not report emissions to the NEI. Detailed information for where emissions came from is shown in Table C.12 for each SLT. Table CIO. Emission Data Source in the 2017 Draft NEI for Each SLT Program System Code Total SLT EPA SLT % EPA % ADEM 68,610 32,552 36,058 47.4 52.6 AKDEC 135,395 21,285 114,110 15.7 84.3 AUCBOH 10,647 5,382 5,265 50.5 49.5 ARDEQ 61,083 19,031 42,052 31.2 68.8 AZDEQ 28,966 13,373 15,593 46.2 53.8 AZMCAQD 14,578 1,916 12,662 13.1 86.9 CARB 1,049,903 656,565 393,338 62.5 37.5 CHC_APCB 5,033 1,878 3,155 37.3 62.7 CODPHE 122,824 39,302 83,522 32.0 68.0 COHDNREM 967 967 0.0 100.0 CTBAM 28,074 17,443 10,631 62.1 37.9 DEDNR 21,207 13,762 7,445 64.9 35.1 DOEE 5,164 2,244 2,920 43.5 56.5 FLDEP 125,956 27,091 98,865 21.5 78.5 GADNR 76,252 18,510 57,742 24.3 75.7 HIDOHCAB 16,643 7,324 9,319 44.0 56.0 IADNR 115,102 52,841 62,261 45.9 54.1 IDDEQ 30,764 4,048 26,716 13.2 86.8 ILEPA 386,338 317,766 68,572 82.3 17.7 INDEM 94,287 33,302 60,985 35.3 64.7 KC_DAQM 727 82 645 11.3 88.7 KSDOHE 97,758 36,167 61,591 37.0 63.0 KYDAQ 245,852 118,190 127,662 48.1 51.9 KYJCAPCD 15,090 11,988 3,102 79.4 20.6 LADEQ08 236,546 100,100 136,446 42.3 57.7 LRAPA 3,286 399 2,887 12.1 87.9 MADEP 50,943 11,054 39,889 21.7 78.3 C-7 ------- Program System Code Total SLT EPA SLT % EPA % MDDOE 65,124 26,461 38,663 40.6 59.4 MEDEP 40,146 18,828 21,318 46.9 53.1 MIDEQ 160,925 98,464 62,461 61.2 38.8 MNPCA 366,293 305,798 60,495 83.5 16.5 MODNR 83,075 25,037 58,038 30.1 69.9 MSC_HD 11,854 5,359 6,495 45.2 54.8 MSDEQ 77,329 45,877 31,452 59.3 40.7 MTDEQ 40,143 7,849 32,294 19.6 80.4 NCBCRAQA 2,690 1,614 1,076 60.0 40.0 NCDAQ 147,338 84,376 62,962 57.3 42.7 NCFCEAD 3,098 2,167 931 69.9 30.1 NCMCAQ 2,914 301 2,613 10.3 89.7 NDC_MPHD 10,942 5,004 5,938 45.7 54.3 NDDOH 24,568 1,890 22,678 7.7 92.3 NEDEQ 41,283 12,098 29,185 29.3 70.7 NELLCHD 1,689 197 1,492 11.7 88.3 NEOPWD 4,697 970 3,727 20.7 79.3 NHDES 16,546 3,164 13,382 19.1 80.9 NJDEP 87,671 53,547 34,124 61.1 38.9 NMCOA 6,680 2,596 4,084 38.9 61.1 NMED 30,875 7,583 23,292 24.6 75.4 NVBAQ 55,046 12,872 42,174 23.4 76.6 NVCCDAQM 8,665 1,835 6,830 21.2 78.8 NVWCAQMD 1,870 48 1,822 2.6 97.4 NYDEC 97,815 41,064 56,751 42.0 58.0 OHEPA 184,907 109,565 75,342 59.3 40.7 OKDEQ 165,613 75,586 90,027 45.6 54.4 ORDEQ 43,074 12,430 30,644 28.9 71.1 PAACHD 16,513 8,716 7,797 52.8 47.2 PACOP 22,934 10,847 12,087 47.3 52.7 PADEP 144,200 54,864 89,336 38.0 62.0 PAG 2,591 2,591 0.0 100.0 PIMA 3,333 1,323 2,010 39.7 60.3 Pinal 2,522 2,522 0.0 100.0 PREQB 15,803 5,109 10,694 32.3 67.7 RIDEM 18,106 8,278 9,828 45.7 54.3 SCDHEC 139,416 99,519 39,897 71.4 28.6 SDDENR 18,156 2,333 15,823 12.8 87.2 TNDEC 60,807 30,009 30,798 49.4 50.6 TR124 707 294 413 41.6 58.4 C-8 ------- Program System Code Total SLT EPA SLT % EPA % TR180 77 46 31 59.7 40.3 TR181 362 180 182 49.7 50.3 TR182 45 29 16 64.4 35.6 TR206 304 304 0.0 100.0 TR207 97 4 93 4.1 95.9 TR380 63 63 0.0 100.0 TR405 85 85 0.0 100.0 TR610 9 9 0.0 100.0 TR614 1 1 0.0 100.0 TR615 589 406 183 68.9 31.1 TR750 16,409 6,193 10,216 37.7 62.3 TR751 21 7 14 33.3 66.7 TR780 177 177 0.0 100.0 TXCEQ 550,398 381,365 169,033 69.3 30.7 UTDAQ 41,969 20,166 21,803 48.0 52.0 VADEQ 60,497 12,272 48,225 20.3 79.7 VTDEC 6,929 836 6,093 12.1 87.9 WAECY 31,684 7,930 23,754 25.0 75.0 WAORCAA 5,359 601 4,758 11.2 88.8 WAPSCAA 15,038 1,141 13,897 7.6 92.4 WASWCAA 5,608 1,448 4,160 25.8 74.2 WIDNR 89,676 23,570 66,106 26.3 73.7 WVDAQ 47,984 25,581 22,403 53.3 46.7 WYDEQ 160,976 132,336 28,640 82.2 17.8 (blank) 2,037 2,037 0.0 100.0 Grand Total 6,312,347 3,361,578 2,950,769 53.3 46.7 There are 23 EIS codes. All of them are used by SLTs in the draft 2017 NEl, but not by EPA. Seven EIS codes were not used by EPA, including those from trade groups and vendors, some SLTs, and special resources. A distribution of codes between SLT and EPA in the 2017 NEI for the emission calculation method data element can be found in Table C.13. The number in the table represents emission records. C-9 ------- Table C.ll. Distribution of Codes between SLT and EPA for the Calculation Material Data Element in the 2017 Draft NEI Code for Emission Calculation Method Description ALL SLT EPA Emission Calculation Method 1 Continuous Emission Monitoring System 17,020 16,542 478 2 Engineering Judgment 494,945 381,557 113,388 3 Material Balance 136,716 132,545 4,171 4 Stack Test (no Control Efficiency used) 105,763 104,094 1,669 5 USEPA Speciation Profile 1,947,088 570,136 1,376,952 6 S/L/T Speciation Profile 73,006 72,883 123 7 Manufacturer Specification 54,409 54,171 238 8 USEPA Emission Factor (no Control Efficiency used) 907,789 891,693 16,096 9 S/L/T Emission Factor (no Control Efficiency used) 283,733 283,436 297 10 Site-Specific Emission Factor (no Control Efficiency used) 43,968 39,899 4,069 11 Vendor Emission Factor (no Control Efficiency used) 9,924 9,915 9 12 Trade Group Emission Factor (no Control Efficiency used) 24,048 24,048 13 Other Emission Factor (no Control Efficiency used) 1,514,727 92,103 1,422,624 24 Stack Test (pre-control) plus Control Efficiency 11,497 11,495 2 28 USEPA Emission Factor (pre-control) plus Control Efficiency 443,724 443,567 157 29 S/L/T Emission Factor (pre-control) plus Control Efficiency 86,092 86,092 30 Site-Specific Emission Factor (pre-control) plus Control Efficiency 14,148 14,146 2 31 Vendor Emission Factor (pre-control) plus Control Efficiency 632 632 32 Trade Group Emission Factor (pre-control) plus Control Efficiency 1,917 1,917 33 Other Emission Factor (pre-control) plus Control Efficiency 141,089 130,595 10,494 40 Emission Factor based on Regional Testing Program 20 20 41 Emission Factor based on data available peer reviewed literature 90 90 42 Emission Factor based on Fire Emission Production Simulator (FEPS) 2 2 Total 6,312,347 3,361,578 2,950,769 C-10 ------- Figure C.4 shows a distribution of the top 20 codes used by SLTs and EPA in the 2017 NEI for the emission calculation method data element. EPA only contributes more records than SLTs for two codes, for that data element in the 2017 NEI, code 5, "USEPA Speciation Profile", and code 13, "Other Emission Factor (no Control Efficiency used)". Contributions to other codes are dominated by SLTs. The most popularly used code by SLTs is 8, "USEPA Emission Factor (no Control Efficiency used)", followed by code 5, "USEPA Speciation Profile", and code 28, "USEPA Emission Factor (pre-control) plus Control Efficiency". Figure C.5. Distribution of Top 20 Codes between SLT and EPA in the 2017 Draft NEI for the Emission Calculation Method Data Element Other Emission Factor (pre-control) plus Control Efficiency Trade Group Emission Factor (pre-control) plus Control- Vendor Emission Factor (pre-control) plus Control Efficiency Site-Specific Emission Factor (pre-control) plus Control... S/L/T Emission Factor (pre-control) plus Control Efficiency USEPA Emission Factor (pre-control) plus Control Efficiency Stack Test (pre-control) plus Control Efficiency Other Emission Factor (no Control Efficiency used) Trade Group Emission Factor (no Control Efficiency used) Vendor Emission Factor (no Control Efficiency used) Site-Specific Emission Factor (no Control Efficiency used) S/L/T Emission Factor (no Control Efficiency used) USEPA Emission Factor (no Control Efficiency used) Manufacturer Specification S/L/T Speciation Profile USEPA Speciation Profile Stack Test (no Control Efficiency used) Material Balance Enginee ri ng Judgment Continuous Emission Monitoring System ¦ SLT ¦ EPA ¦ I 1 0 400,000 800,000 1,200,000 1,600,000 2,000,000 Number of Emission Records Table showing all numbers from figure. Table C.12. Distribution of Top 20 Codes between SLT and EPA in the 2017 Draft NEI for the Emission Calculation Method Data Element Emission Calculation Method Code Emission Calculation Method Description ALL SLT EPA 1 Continuous Emission Monitoring System 17,020 16,542 478 2 Engineering Judgment 494,945 381,557 113,388 3 Material Balance 136,716 132,545 4,171 C-ll ------- Emission Emission Calculation Method Description ALL SLT EPA Calculation Method Code 4 Stack Test (no Control Efficiency used) 105,763 104,094 1,669 5 USEPA Speciation Profile 1,947,088 570,136 1,376,952 6 S/L/T Speciation Profile 73,006 72,883 123 7 Manufacturer Specification 54,409 54,171 238 8 USEPA Emission Factor (no Control Efficiency used) 907,789 891,693 16,096 9 S/L/T Emission Factor (no Control Efficiency used) 283,733 283,436 297 10 Site-Specific Emission Factor (no Control Efficiency used) 43,968 39,899 4,069 11 Vendor Emission Factor (no Control Efficiency used) 9,924 9,915 9 12 Trade Group Emission Factor (no Control Efficiency used) 24,048 24,048 13 Other Emission Factor (no Control Efficiency used) 1,514,727 92,103 1,422,624 24 Stack Test (pre-control) plus Control Efficiency 11,497 11,495 2 28 USEPA Emission Factor (pre-control) plus Control Efficiency 443,724 443,567 157 29 S/L/T Emission Factor (pre-control) plus Control Efficiency 86,092 86,092 30 Site-Specific Emission Factor (pre-control) plus Control Efficiency 14,148 14,146 2 31 Vendor Emission Factor (pre-control) plus Control Efficiency 632 632 32 Trade Group Emission Factor (pre-control) plus Control Efficiency 1,917 1,917 33 Other Emission Factor (pre-control) plus Control Efficiency 141,089 130,595 10,494 40 Emission Factor based on Regional Testing Program 20 20 41 Emission Factor based on data available peer reviewed literature 90 90 42 Emission Factor based on Fire Emission Production Simulator (FEPS) 2 2 Total 6,312,347 3,361,578 2,950,769 C.6 Findings 1. Not all codes for the Unit Type, calculation parameter unit of measure, and calculation material appear in the 2017 draft NEI. However, large amounts of records are associated with the code "unclassified", blank, or null. This implies that SLTs do not collect the information, SLTs do not report the data element, or the EIS codes for those data elements might not be user-friendly. 2. Most of the emission units reported as "Unclassified" are associated with descriptions that could be specified with existing codes for the Unit Type element data element. C-12 ------- 3. Codes used in the 2017 NEI could be reported by SLTs or by EPA for the calculation parameter unit of measure data element and Calculation Material data element. The same distribution between SLTs and EPA behavior is observed for the two data elements, 46.7% reported directly by SLTs and 53.3% by EPA. About 48.9 % of emission records were appeared as blank/null. Out of 82 SLTs that reported emissions to the 2017 draft NEI, 44 did not report anything for the calculation parameter unit of measure data element and Calculation Material data element. 4. Twelve out of 63 EIS codes in the 2017 NEI for the calculation parameter unit of measure data element were used in less than 100 emission records each. In addition, 6 EIS codes do not show up in the 2017 NEI. 5. The code of EACH for the calculation parameter unit of measure data element is the most popularly used one, but mainly by EPA. On the other hand, the code of E6FT3 is the most popular one used by SLTs, probably for representing the use of natural gas in combustion. Other top 10 used codes seem related to combustion processes as well. 6. Ninety two out of 473 EIS codes in the 2017 NEI for the Calculation Material data element were used in less than 10 emission records each. In addition, 224 EIS codes do show up in the 2017 NEI. 7. The code of Landing-Takeoff-Cycle is the most popular one used in the 2017 NEI for the Calculation Material data element, but mainly by EPA. It is for the airport emissions that are usually estimated by EPA for SLTs. On the other hand, the code of Natural Gas is the most popular one used by SLTs, presenting the use of it in combustion processes. Most top 15 codes for the Calculation Material data element are related to combustion process as observed in the analysis for the calculation parameter unit of measure data element. 8. All 23 EIS emission calculation method codes are used by SLTs in the draft 2017 NEI. However, 7 EIS codes are not used by EPA. Among emission data for 92 SLTs in the 2017 NEI, 23 SLTs reported more than 50% of emission records, 59 SLTs reported less than 50% emission records, and 10 locals and tribes didn't report emissions to the NEI. 9. EPA only contributes more than SLTs to two codes for the emission calculation method data element in the 2017 NEI: code 5, "USEPA Speciation Profile", and code 13, "Other Emission Factor (no Control Efficiency used)". Contributions to other codes are dominated by SLTs. The most popular code used by SLTs is 8, "USEPA Emission Factor (no Control Efficiency used)", followed by code 5, "USEPA Speciation Profile", and code 28, "USEPA Emission Factor (pre- control) plus Control Efficiency". C-13 ------- Appendix D Options for CAERS and Recommendations D.l Options for How the Different SLT Codes Will Be Housed and Maintained The CAER system will have to supply the different SLTs with their codes as follows: 1. The SLT has the same codes as EIS so facilities from that SLT can enter those codes. This is the current default setting in CAERS. States such as Georgia only use NEI code for their El system, 100 % matched and one-to-one relationship; so an SLT like Georgia uses NEI codes as they are. 2. The SLT has the same codes as EIS, but the nomenclature and coding system for the SLT is different. CAERS would have to contain a crosswalk so that the users can work with the SLT codes and then have the data sent with the corresponding EIS codes to EPA. E.g. Wyoming's Calculation Method definitions align with EIS, but code IDs do not match. Currently the Bridge Tool is used to map the WY IDs to EIS IDs before sending to EIS. See Table D. 1. Table D. 1. IMPACT to EIS Comparison for Two Codes IMPACT Code IMPACT Description IMPACT Long Description Map to EIS Code EIS Description 4 Time-based factor - Allowable Emissions that are estimated by using the allowable emission rate. 10 Site-Specific Emission Factor (no Control Efficiency used) 2 Time-based factor - Stack Test Emissions measured by periodic stack emission tests which have been accepted by the Division as being representative of normal source operation. Actual emissions are the hourly emission rates multiplied by the annual hours of operation. Note that estimated emissions for Title V facilities derived from measurements from portable analyzers cannot be accepted. For stack tests, older than one year, performed on reciprocating engines, the allowable emission limit will be used to calculate emissions, unless a more valid means of determining emissions has been established. 4 Stack Test (no Control Efficiency used) 201 Emissions Emissions that are based on an engineering estimate. 2 Engineering Judgment Note the overlap of t ie WY IMPACT code IDs (2 and 4) with the same EIS code IDs; i.e., same numbers but associated with different calculation methods. 3. The SLT has additional codes that do not map to EIS codes. In this case the CAERS will have to include, in its SLT customization, the additional SLT codes. If several states have additional codes that are not in EIS, the team recommends that these codes be reviewed by EPA and consider them for inclusion in the EIS codes. For example, 14 control measure codes were retired in EIS and are mapped to a more generic EIS code 141, Wet Scrubber, such as: • Wet Scrubber - High Efficiency (EIS code 1) • Impingement Type Wet Scrubber (EIS code 115) • Packed Scrubber (EIS code 117) • Floating Bed Scrubber (EIS code 120) D-l ------- Some SLTs may retain those detailed codes in their state systems. Those codes need to be contained in the CAERS for the specified SLTs. They would be displayed for the facility reporting to that SLT and mapped to the EIS code accordingly. 4. The SLT has codes that map to EIS codes but are not identical to an EIS code. The CAERS would have to crosswalk those codes to the nearest EIS match, with input from the SLT. For example, Colorado uses unit type codes to support construction permit tracking activities and are not highly correlated with EIS types. In Colorado, 4 unit type codes are mapped to one EIS code 270, Incinerator, including Cremator, Hazardous Waste Incinerator, Incinerator, and Thermal Oxidizer. 5. Additional use cases that will need to be accommodated into CAERS: E.g., an SLT does not want to offer a specific EIS calculation method to its facilities. For example, OH does not use EIS code 8, USEPA Emission Factor (no Control Efficiency used), because Ohio already incorporated all UAEPA emission factors to their state-specific factors, OEPA (Ohio EPA) factors. The Ohio system performs auto calculation based on the OEPA factor if there is no process-specific emission information. In this case the SLT would request that the CAERS be customized so that calculation method code is not offered when the user is working with a facility from that state. The team discussed the following two options for SLTs who use CAERS. The team also discussed how the different SLT codes should be provided to CAERS. Two options emerged: 1. SLT provides its codes to CAERS. The SLTs would have ownership of their codes. As such, the SLTs would update their codes and provide the updates to EPA for inclusion in CAERS. • Benefits of this approach: o Facilities will see the same codes when the report to CAERS as they report to the SLTs o It is easy to implement. • Potential downsides of this approach: o In the long term there is a potential opportunity for an integrated coding system that everyone can adhere to. This opportunity may be lost with option 1. • Information about the codes that would need to be provided for the CAERS would have to adhere to the following business rules in this case: a. The codes and use cases for each onboarded state would have to be located in a place where onboarded states can access it so they may update their codes as appropriate. b. SLTs should not update codes for other SLTs. However, if an SLT finds a code from another SLT that it would like to adopt, it can include it in its own SLT codes. c. SLTs take full responsibilities for their respective codes only, including adding, deleting, and modifying. d. EPA's responsibility will be limited to maintaining the EIS codes, such as adding, deleting, and modifying those codes. e. SLT codes must be mapped to EIS codes if the SLT wants to report data to NEI. SLT codes that are not mapped to EIS codes will be used by the SLT inventory only. f. Design for all code tables under this project are included in the Appendix. A similar design concept could be applicable for other CAERS code tables. D-2 ------- 2. Establish a standardized set of codes in CAERS. In this case, EPA would have ownership of the codes and would maintain them. The EPA would have to conduct out-reach educational work to train facilities with CAERS codes: • Benefits: o There would be one centralized, standardized set of codes that everyone knows, understands, and can refer to. • Downsides (potential) of this approach: o Similar to the first case, these CAERS codes would still need to be mapped to SLT codes if data is going to flow from the CAERS back to the SLT. It will be difficult for a map from CAERS codes to SLT codes when SLT codes are more detailed than the CAERS codes. o SLTs may choose to keep their coding systems and not adopt a new standardized system. o It would take time create and promote a new coding system to all within EPA models and systems that use these codes. o EPA would need to devote resources to maintaining this new coding system and accommodate SLT requests. NOTE: Option 2 could be a longer-term option. In fact, it would likely evolve over time as a result of more SLT and EPA systems integrating with CAERS, using the Agile approach. D.2 Proposed CAERS Tables Proposed tables for CAERS can be found in the file: "Proposed CAERS Tables.xlsx". D-3 ------- Appendix E List ofSLT Program System Codes in EIS Agency Name Program System Code Program System Description Alabama Department of Environmental Management ADEM Alabama Department of Environmental Management Alaska Department of Environmental Conservation AKDEC Alaska Department of Environmental Conservation Allegheny County Health Department PAACHD Allegheny County Health Department Arapahoe Tribe of the Wind River Reservation TR281 Arapahoe Tribe of the Wind River Reservation, Wyoming Arizona Department of Environmental Quality AZDEQ Arizona Department of Environmental Quality Arkansas Department of Environmental Quality ARDEQ Arkansas Department of Environmental Quality Assiniboine and Sioux Tribes of the Fort Peck Indian Reservation TR206 Assiniboine and Sioux Tribes of the Fort Peck Indian Reservation, Montana Blackfeet Tribe of the Blackfeet Indian Reservation of Montana TR201 Blackfeet Tribe Blue Lake Racheria TR558 Blue Lake Rancheria Cabazon Band of Cahuilla Mission Indians Reservation TR568 Cabazon Band of Cahuilla Mission Indians of the Cabazon Reservation, California California Air Resources Board CARB California Air Resources Board Catawba Indian Nation, South Carolina T032 Catawba Indian Nation Chattanooga Air Pollution Control Bureau (CHCAPCB) CHC_APC B Chattanooga-Hamilton Cty APCB E-l ------- Agency Name Program System Code Program System Description Cherokee Nation, Oklahoma CNEP Cherokee Nation, Oklahoma Chickasaw Nation, Oklahoma TR906 Chickasaw Nation, Oklahoma Citizen Potawatami Nation, Oklahoma TR821 Citizen Potawatami Nation, Oklahoma City of Albuquerque NMCOA City of Albuquerque City of Huntsville Division of Natural Resources and Environmental Mgmt COHDNR EM City of Huntsville Division of Natural Resources and Environmental Mgmt Clark County Department of Air Quality and Environmental Management NVCCDA QM Clark County Department of Air Quality and Management Coeur dAlene Tribe TR181 Coeur d'Alene Tribe Colorado Department of Public Health and Environment CODPHE Colorado Department of Public Health and Environment Confederated Salish & Kootenai Tribes TR203 Confederated Salish & Kootenai Tribe Confederated Tribes of the Colville Reservation, Washington TR101 Colville Reservation Confederated Tribes of the Umatilla Reservation, Oregon TR143 Confederated Tribes of the Umatilla Reservation, Oregon Connecticut Department of Energy and Environmental Protection CTBAM Connecticut Department Bureau of Air Management Cortina Band of Wintun Indians TR513 Cortina Band of Wintun Indians Coyote Valley Band of Pomo Indians of California TR638 Coyote Valley Band of Pomo Indians Crow Tribe TR202 Crow Tribe DC-District Department of the Environment DOEE District Department of the Environment E-2 ------- Agency Name Program System Code Program System Description Delaware Department of Natural Resources and Environmental Control DEDNR Delaware Department of Natural Resources Eastern Band of Cherokee Indians TR001 Eastern Band of Cherokee Indians Florida Department of Environmental Protection FLDEP Florida Department of Environmental Protection Fond du Lac Band of Lake Superior Chippewa TR405 Fond du Lac Band of the Minnesota Chippewa Tribe Forest County Potawatomi Community TR434 Forest County Potawatomi Community Forsyth County Office of Environmental Assistance and Protection NCFCEAD Forsyth County Environmental Affairs Department Fort Mojave Indian Tribe Reservation TR604 Fort Mojave Indian Tribe of Arizona, California & Nevada Georgia Department of Natural Resources GADNR Georgia Deparment of Natural Resources Gila River Indian Community TR614 Gila River Indian Community of the Gila River Indian Reservation, Arizona Grand Portage of the Minnesota Chippewa Tribe TR406 Grand Portage of the Minnesota Chippewa Tribe Hawaii Department of Health Clean Air Branch HIDOHCA B Hawaii Department of Health, Clean Air Branch Idaho Department of Environmental Quality IDDEQ Idaho Department of Environmental Quality Illinois Environmental Protection Agency ILEPA Illinois Environmental Protection Agency Indiana Department of Environmental Management INDEM Indiana Department of Environmental Management Iowa Department of Natural Resources IADNR Iowa Department of Natural Resources, Air Quality E-3 ------- Agency Name Program System Code Program System Description Jefferson County (AL) Department of Health AUCBOH Jefferson County Board of Health (Alabama) Kansas Department of Health and Environment KSDOHE Kansas Department of Health and Environment Kaw Nation of Oklahoma TR810 Kaw Nation of Oklahoma Kentucky Division for Air Quality KYDAQ Kentucky Division of Air Quality Kickapoo Tribe of Indians of the Kickapoo Reservation in Kansas TR861 Kickapoo Tribe of Indians of the Kickapoo Reservation in Kansas Kickapoo Tribe of Oklahoma TR823 Kickapoo Tribe of Oklahoma Knox County Department of Air Quality Management KC_DAQ M Knox County DAQM Kootenai Tribe of Idaho TR183 Kootenai Tribe of Idaho LaPosta Band of Mission Indians TR577 La Posta Band of Diegueno Mission Indians of the La Posta Indian Reservation, California Lac Vieux Desert Band of Lake Superior Chippewa Indians, Michigan TR479 Lac Vieux Desert Band of Lake Superior Chippewa Indians, Michigan Lane Regional Air Pollution Authority LRAPA Lane Regional Air Pollution Authority Leech Lake Band of Ojibwe Reservation TR407 Leech Lake Band of Ojibwe Lincoln/Lancaster County Health Department NELLCHD Lincoln-Lancaster County Health Department Little River Band of Ottawa Indians, Michigan TR482 Little River Band of Ottawa Indians, Michigan Little Traverse Bay Bands of Odawa Indians, Michigan TR483 Little Traverse Bay Bands of Odawa Indians, Michigan E-4 ------- Agency Name Program System Code Program System Description Louisiana Department of Environmental Quality LADEQ08 Louisiana Department of Environmental Quality 2008 Louisville Metro Air Pollution Control District KYJCAPC D Air Pollution Control District of Jefferson County (Kentucky) Maine Department of Environmental Protection MEDEP Maine Department of Environmental Protection Makah Indian Tribe of the Makah Indian Reservation TR108 Makah Indian Tribe Maricopa County Air Quality Department AZMCAQ D Maricopa County Air Quality Department Maryland Department of the Environment MDDOE Maryland Department of Environment Massachusetts Department of Environmental Protection MADEP Massachusetts Department of Environmental Protection Mecklenburg County Air Quality NCMCAQ Mecklenburg County Air Quality Memphis and Shelby County Health Department - Pollution Control MSC_HD Memphis-Shelby County Health Dept Metro Public Health of Nashville/Davidson County N DC_M P HD Nashville-Davidson County MPHD Michigan Department of Environmental Quality MIDEQ Michigan Department of Environmental Quality - Air Quality Mille Lacs Band of Ojibwe TR408 Mille Lacs Band of Ojibwe Minnesota Pollution Control Agency MNPCA Minnesota Pollution Control Agency Mississippi Dept of Environmental Quality MSDEQ Mississippi Department of Environmental Quality E-5 ------- Agency Name Program System Code Program System Description Missouri Department of Natural Resources MODNR Missouri Department of Natural Resources, Air Pollution Control Program Mohegan Tribe of Indians of Connecticut TR033 Mohegan Tribe of Indians of Connecticut Montana Department of Environmental Quality MTDEQ Montana Department of Environmental Quality Morongo Band of Cahuilla Mission Indians of the Morongo Reservation, California TR582 Morongo Band of Cahuilla Mission Indians of the Morongo Reservation, California Navajo Nation TR780 Navajo Nation Nebraska Environmental Quality NEDEQ Nebraska Department of Environmental Quality Nevada Division of Environmental Protection NVBAQ Nevada Bureau of Air Quality New Hampshire Department of Environmental Services NHDES New Hampshire Department of Environmental Services New Jersey Department of Environment Protection NJDEP New Jersey Department of Environmental Protection New Mexico Environment Department Air Quality Bureau NMED New Mexico Environmental Department New York State Department of Environmental Conservation NYDEC New York State Department of Environmental Conservation Nez Perce Tribe TR182 Nez Perce Tribe North Carolina Department of Environmental Quality NCDAQ North Carolina Department of Air Quality North Dakota Department of Environmental Quality NDDEQ North Dakota Department of Environmental Quality Northern Cheyenne Tribe TR207 Northern Cheyenne Tribe Ohio Environmental Protection Agency OHEPA Ohio Environmental Protection Agency E-6 ------- Agency Name Program System Code Program System Description Oklahoma Department of Environmental Quality OKDEQ Oklahoma Department of Environmental Quality Olympic Region Clean Air Agency WAORCA A Olympic Region Clean Air Agency Omaha Air Quality Control Division NEOPWD City of Omaha Public Works Department Omaha Tribe of Nebraska TR380 Omaha Tribe of Nebraska Oneida Nation of Wisconsin TR433 Oneida Tribe of Wisconsin Oregon Department of Environmental Quality ORDEQ Oregon Department of Environmental Quality Pechanga Band of Luiseno Mission Indians of the Pechanga Reservation, California TR586 Pechanga Band of Luiseno Mission Indians of the Pechanga Reservation, California Pennsylvania Department of Environmental Protection PADEP Pennsylvania Department of Environmental Protection Penobscot Indian Nation TR018 Penobscot Tribe of Maine Philadelphia Air Management Services PACOP City of Philadelphia Pima Association of Governments PAG Pima County Association of Governments Pima County PIMA Pima County Pinal County Pinal Pinal County, Arizona Poarch Band of Creek Indians of Alabama TR028 Poarch Band of Creek Indians of Alabama Prairie Band of Potawatomi Indians TR862 Prairie Band of Potawatomi Indians Pueblo of Laguna, New Mexico TR707 Pueblo of Laguna, New Mexico E-7 ------- Agency Name Program System Code Program System Description Pueblo of Pojoaque TR710 Pueblo of Pojoaque Pueblo of Santa Ana, New Mexico TR715 Pueblo of Santa Ana, New Mexico Pueblo of Tesuque, New Mexico TR719 Pueblo of Tesuque, New Mexico Puerto Rico PREQB Puerto Rico Puget Sound Clean Air Agency WAPSCA A Puget Sound Clean Air Agency Pyramid Lake Paiute Tribe of the Pyramid Lake Reservation, Nevada TR651 Pyramid Lake Paiute Tribe Quapaw Tribe of Indians, Oklahoma TR920 Quapaw Tribe Red Lake Band of Chippewa Indians, Minnesota TR409 Red Lake Band of Chippewa Indians Regional Air Pollution Control Agency OHRAPC A Regional Air Pollution Control Agency (Dayton, Ohio) Reno-Sparks Indian Colony, Nevada TR653 Reno-Sparks Indian Colony, Nevada Rhode Island Department of Environmental Management RIDEM Rhode Island Department of Environmental Management, Office of the Air Resource Sac & FoxTribe of the Mississippi in Iowa TR490 Sac & FoxTribe of the Mississippi in Iowa Sac and Fox Nation of Missouri in Kansas and Nebraska Reservation TR863 Sac and Fox Nation of Missouri Saginaw Chippewa Indian Tribe of Michigan TR472 Saginaw Chippewa Indian Tribe of Michigan E-8 ------- Agency Name Program System Code Program System Description Saint Regis Mohawk Tribe TR007 St. Regis Band of Mohawk Indians of New York Salt River Pima Maricopa Indian Community (SRPMIC) EPNR TR615 Salt River Pima-Maricopa Indian Community of the Salt River Reservation, Arizona Santee Sioux Nation TR382 Santee Sioux Nation, Nebraska Sault Ste. Marie Tribe of Chippewa Indians of Michigan and Wisconsin TR469 Sault Ste. Marie Tribe of Chippewa Indians of Michigan and Wisconsin Shoshone-Bannock Tribes of the Fort Hall Reservation of Idaho TR180 Shoshone-Bannock Tribes of the Fort Hall Reservation of Idaho South Carolina Department of Health and Environmental Control SCDHEC South Carolina Department of Health and Environmental Control South Dakota Department of Environment and Natural Resources SDDENR South Dakota Department of Environment and Natural Resources Southern Ute Indian Tribe TR750 Southern Ute Indian Tribe Southwest Clean Air Agency WASWCA A Southwest Clean Air Agency Spirit Lake Nation TR303 Spirit Lake Nation Swinomish Indians of the Swinomish Reservation, Washington TR122 Swinomish Indians of the Swinomish Reservation, Washington Tennessee Department of Environmental Conservation TNDEC Tennessee Department of Environment and Conservation, Air Pollution Control Bureau Texas Commission on Environmental Quality TXCEQ Texas Commission on Environmental Quality E-9 ------- Agency Name Program System Code Program System Description Tohono O-Odham Nation Reservation TR610 Tohono O'Odham Nation Reservation Torres-Martinez Band of Cahuilla Mission Indians of California TR595 Torres-Martinez Band of Cahuilla Mission Indians of California Twenty-Nine Palms Band of Mission Indians of California TR598 Twenty-Nine Palms Band of Mission Indians of California Utah Division of Air Quality UTDAQ Utah Division of Air Quality Ute Mountain Tribe of the Ute Mountain Reservation, Colorado, New Mexico, Utah TR751 Ute Mountain Tribe of the Ute Mountain Reservation, Colorado, New Mexico & Utah Vermont Department of Environmental Conservation VTDEC Vermont Department of Environmental Conservation Virginia Department of Environmental Quality VADEQ Virginia Department of Environmental Quality Washington State Department of Ecology WAECY Washington Emission Inventory Repository Database Washoe County Health District NVWCAQ MD Washoe County Air Quality Management Division Washoe Tribe of California and Nevada TR672 Washoe Tribe of California and Nevada West Virginia Division of Air Quality WVDAQ West Virginia Division of Air Quality Western North Carolina Regional Air Quality Agency (Buncombe Co.) NCBCRA QA Western North Carolina Regional Air Quality Agency - Buncombe County White Mountain Apache Tribe of the Fort Apache Reservation, Arizona TR607 White Mountain Apache Tribe Winnebago Tribe of Nebraska TR383 Winnebago Tribe of Nebraska Wisconsin Department of Natural Resources WIDNR Wisconsin Department of Natural Resources E-10 ------- Agency Name Program System Code Program System Description Wyoming Department of Environmental Quality WYDEQ Wyoming Department of Enviromental Quality Yakama Nation Reservation TR124 Yakama Nation Yavapai-Apache Nation of the Camp Verde Indian Reservation, Arizona TR601 Yavapai-Apache Nation E-ll ------- |