May 18, 2018
2017 NEI Final Plan: Revised May 2018
1 Introduction
The National Emissions Inventory (NEI) is a comprehensive and detailed estimate of annual total air emissions of
both criteria and hazardous air pollutants (HAPs) from all significant air emissions sources. The NEI is prepared at
least every three years by the U.S. EPA based primarily upon emissions estimates and emissions model inputs
provided by State, Local and Tribal (SLT) air agencies, and supplemented by data developed by the EPA. The NEI
is created to provide EPA, federal and state decision makers, the U.S. public, and other countries the U.S.'s best
and most complete estimates of criteria air pollutants and precursors (CAPs) and HAP emissions. The NEI is used
by the EPA in support of evaluating National Ambient Air Quality Standards (NAAQS), assessing interstate
transport of air pollutants, air toxics programs, and for international reporting. It is also used by state and local
air agencies as a starting point for State Implementation Plan (SIP) development, other federal agencies,
researchers, and environmental groups to understand sources and impact of air pollution.
The NEI is created based on both regulatory and technical components. The Air Emissions Reporting
Requirements (AERR) (40 CFR Part 51) is the rule that requires states to submit emissions of CAP emissions and
provides the framework for voluntary submission of HAP emissions. The AERR, revised in 2015, requires
agencies to report all sources of emissions, except fires and biogenic sources. The AERR also lowers the
reporting threshold for lead emissions as point sources to 0.5 tons per year of actual emissions and, except for
California, requires agencies to report the inputs needed to model emissions from onroad mobile and nonroad
equipment mobile sources. Sources are divided into large groups called "data categories": stationary sources
are reported in "point" or "nonpoint" (county totals) and mobile sources in onroad (cars and trucks), nonroad
(off-road vehicles and nonroad equipment such as lawn and garden equipment), point (airports and railyards),
or nonpoint (marine and locomotives). Large fires (wild and prescribed) are reported in a data category called
'EVENTS." The AERR specifies emissions thresholds above which states must report stationary emissions as
"point" sources with the remainder of the stationary emissions reported as "nonpoint" sources.
Since the 2008 NEI, the Emissions Inventory System (EIS) has been the data system for collecting and storing
current and historical emissions inventory data. The AERR requires the submission of data electronically to the
EIS through the Central Data Exchange (CDX), and the EIS is used to receive and store emissions data and to
select the data to be included in the NEI. The EIS not only holds the emissions data, it also provides all reporting
codes, and EIS quality assurance (QA) checks, and there are Bridge Tools available to allow agencies to report
NEI datasets to the EIS. The EIS also includes agency organization profiles such as a list of agency staff and
contact information who are responsible for submitting or reviewing data. Lastly, the EIS provides feedback
reports to agencies with results of EIS QA checks on reported data as well as reports on facilities and emissions
useful for summarizing and reviewing agency data and the NEI.
Since the inception of the EIS, the EPA has worked to ensure that all changes to business processes, codes, QA
checks, etc., are provided to the SLT air agencies by June 1 of the year that the submission window opens. For
the 2017 inventory, this date is June 1, 2018. However, air agency feedback indicated that this timeline did not
give SLTs enough time to implement associated changes into SLT data systems. In response to those comments,
the EPA posted changes by July 1, 2017, approximately one year before the submission window opens (18
months before the data are due). This revised NEI Plan highlights some necessary changes to the initial 2017 NEI
Plan that was provided in October 2017.
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The NEI team staff are sensitive to the impact that these changes have on SLTs and are interested in comments
from the SLT air agency staff. The NEI team will assist SLT staff wherever possible to implement any needed
changes into your system. While we try to minimize changes to the EIS, these improvements are intended to
help the EPA to create a more complete, accurate, and timely inventory, which is ultimately also in the best
interest of SLT agencies as well.
2 Schedule
The detailed 2017 NEI schedule, revised in May 2018, is provided in Table 2-1 for general activities, point and
events data categories, and onroad and nonroad mobile data categories. The schedule for the nonpoint data
category is provided in Table 2-2. A key change to the 2017 NEI schedule from the 2014 NEI is that most of the
nonpoint inventory will be created using a staggered schedule and we will also encourage submittal of input
activity date for many nonpoint sources. For the 2017 NEI, EPA has decided to divide the nonpoint tools into
four categories to allow more resources and time for collaboration on the most important and complicated
tools. This staggered schedule of EPA nonpoint tools will allow more focus on specific nonpoint tools in discrete
timeframes during the 2017 NEI development cycle, and will avoid dumping an overwhelming number of new
and revised EPA estimates at once on the SLT inventory developers. These nonpoint tools are encouraged for
use by SLTs for improving emissions calculations using consistent and defensible methods. SLTs who choose to
have the EPA calculate their nonpoint sector data using these tools will need to send that data by one of the two
submittal deadline date(s) shown in the detailed schedule. Otherwise, SLTs may submit nonpoint emissions data
by March 31, 2019, 3 months later than the usual AERR required schedule. More details on the multiple-
category staggered schedule of EPA nonpoint tools and input activity submittals are provided in Section 5.4.
We provide a refined schedule for releasing data in the EIS, which precedes the public NEI release by several
months for some data categories. Barring some possible last-minute changes in data, data in the EIS release will
be identical to the public release data for the NEI. We provide the EIS data early because some data category
inventories will be finalized and thus available sooner than others, and also because it takes a few weeks to
build all data summaries and documentation that accompany the public release of the NEI. Only SLT and EIAG
inventory developers, RPOs, EPA Regional Offices and other EPA users have access to the EIS datasets, which are
available in EIS when finalized but before public website dissemination can occur.
As was done for the 2014 NEI, comments on the draft 2017 NEI will be focused strictly on issues identified by QA
and not be permitted to include SLT agencies submitting wholesale replacement data. In the past, allowing
wholesale replacements had the unintended effect of delaying the NEI release by many weeks or months and
increasing EPA costs to unsustainable levels. SLT agencies will still be able to send data corrections during a QA
period. We are not including a placeholder for a second version ("v2") of the 2017 NEI since it is unknown if a
version 2 of the 2017 NEI would be scheduled.
Significant changes to the 2017 NEI schedule from the October 2017NEI Plan include:
• The Point inventory submittal window will open on July 1, 2018 rather than June 15, 2018 to allow the
2016 Point inventory to be completed and "locked" before potential changes to the facility inventory
related to year 2017 are submitted.
• The emissions submittal deadline for all nonpoint sources except for commercial marine vessels (CMV)
and rail is now March 31, 2019. The CMV and rail submittal deadline is January 15, 2019, the same
extended-AERR deadline as all other data categories: Point, onroad and nonroad mobile and events.
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• Nonpoint activity data for most source categories that do not utilize point source subtraction ("Cat 3"
sources) is due March 31, 2019, rather than the earlier deadlines for some nonpoint sources in the
original NEI Plan.
• The public release of the 2017 NEI is postponed a month to March 31, 2020
Table 2-1: 2017 NEI Schedule for general activities, point, events and mobile data categories
General Activities
Item
Who
Details
Deadline
Finalize changes to codes and QA routines for 2017
EPA
Code changes and QA routines to be reflected in EIS
11/15/2017
EPA posts expected pollutants list to website
EPA
Point, Nonpoint and Events only
11/15/2017
Submission Window Opens for SLT submittals
SLT
All data categories, delayed to allow 2016 NEI completion
7/1/2018
SLTs last day for EIS submittal of Point, Onroad Mobile,
Nonroad Mobile and Events data category emissions
SLT
The regulatory deadline for emissions data and model inputs
is December 31, 2018. However, the EPA provides a grace
period because of the holidays at the end of the season, and
also has later dates for nonpoint sources, which have
underlying data available at later dates.
1/15/2019
2017 vl Public Release
Includes functioning NEI Data page with query tools,
summaries and Technical Support Documentation
3/31/2020
Point Inventory Development
Item
Who
Details
Deadline
Provide SLT List of Priority Pollutants/Facilities
EPA
On 2017 NEI Documentation website orSharePoint
7/1/2018
EPA 2017 landing/takeoff (LTO) data available for SLT
review period
EPA
On 2017 NEI Documentation website orSharePoint
6/30/2018
SLT comments on EPA LTO data due
SLT
8/30/2018
SLTs last day for submittal of Facility Inventory edits to
EIS
SLT
SLT throughput data will be used to help compute EPA
Nonpoint estimates that rely on point inventory subtraction
1/8/2019
SLTs last day for submittal of Point emissions to EIS
SLT
1/15/2019
EPA loads EPA-estimated 2017 EGU Emissions to EIS
EPA
1/15/2019
EPA provides feedback to SLTs on data completeness
and outliers
EPA
Window open on a case-by-case basis for corrections only
2/15/2019
SLT corrections based on EPA feedback due
SLT
completeness and outliers check
5/15/2019
2017 draft NEI Point Release in EIS
EPA
6/1/2019
2017 NEI Point Release in EIS
EPA
Selection name will have a date stamp
7/1/2019
Onroad/Nonroad Inventory
Development
Item
Who
Details
Deadline
Post instructions and 2017 default inputs for onroad and
nonroad
EPA
On 2017 NEI Documentation website orSharePoint
6/1/2018
SLTs last day for submittal of Onroad/Nonroad activity
input data to EIS
SLT
1/15/2019
EPA provides feedback to SLTs on data completeness
and outliers
EPA
Window open on a case-by-case basis for activity data
corrections only
5/1/2019
SLT corrections based on EPA feedback due
SLT
Activity data only
7/1/2019
EPA solicits corrections on case by case basis
SLT
Starting May 15, 2019
7/31/2019
2017vl NEI release in EIS
EPA
9/15/2019
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Events Inventory Development
Item
Who
Details
Deadline
Re-assembly of Fires workgroup
We will start up the workgroup as we had for the 2014 NEI
with new members added as requested
5/30/2018
Request 2017 activity data from SLTs and other local
organizations
SLT
EPA will send Excel-based template for SLT use via email
5/30/2018
Memo to all SLTs on how EVENTS will be done for 2017
EPA
Memo to explain EPA methods and why activity data are
preferred and what is needed with emissions if they are
submitted
5/30/2018
Questionnaire to all SLTs
EPA
Used to help EPA assess SLT-submitted activity data
6/10/2018
Draft activity data and answers to questionnaire
SLT
Due date for draft activity data from SLTs and answers to
questionnaire
9/1/2018
Provide SMARTFIRE2 (SF2)-based draft emission
estimates
EPA
A draft methodology will also be provided
9/1/2018
EPA communication back to SLTs on the quality of the
submitted activity data
EPA
10/15/2018
Review of draft emission estimates
SLT
Due data to submit new inputs and/or comments on
estimates and methods
12/15/2018
EPA posts rerun of SF2 with documentation outlining
changes from draft
EPA
Will reflect suggested revisions/comments from draft review
as resources allow
3/1/2019
Final SF2 results review by SLTs
SLT
Only minor changes will be allowed due to resource
limitations
5/1/2019
Develop final EPA-based WLF emission estimates for the
US, including final documentation
EPA
These will be the final EPA estimates. See Section 7.1.
7/1/2019
2017vl NEI release in EIS
EPA
9/15/2019
Table 2-2: 2017 NEI Sc
ledule
or event and nonpoint data categories
Nonpoint Inventory Development
Item
Who
Details
Deadline
Catl: EPA posts draft vl tools and methodology for
Category 1 sources
EPA
Based on similar methods to EPA methods developed for the
2014v2 NEI -posted on NOMAD (Nonpoint Method Advisory)
SharePoint site
3/31/2017
Catl: SLT comments on Cat 1 draft tools due
SLT
Comments submitted via email to NEI team lead
5/31/2017
Catl: EPA posts vl tools + input templates for Category
1 sources
EPA
Includes any SLT inputs submitted by 1/15/2017
4/30/2018
Catl: EPA posts 2017 nonpoint emissions from Category
1 tools in EIS
EPA
Reflects EPA estimates plus any SLT inputs submitted by
11/30/2018
12/31/2018
Post list of nonpoint sectors where EPA will develop
estimates
EPA
See Section 5.4
5/31/2017
EPA works with NOMAD group to refine and post
updated Nonpoint Survey and point-nonpoint
reconciliation table
EPA
Nonpoint Survey posted in EIS and Point-Nonpoint
Reconciliation spreadsheet posted to NEI website or
SharePoint
9/1/2018
Cat 2a: EPA posts draft vl tools and methodology for
Category 2a sources
EPA
Methodology revisions dependent on resource limitations
6/15/2018
Cat 2a: SLT comments on Cat 2a draft tools due
SLT
Comments submitted via email to NEI team lead
7/15/2018
Cat 2a: EPA posts Final Methodology + input templates
for Category 2a tools
EPA
On SharePoint
9/15/2018
Cat 2a: EPA posts vl tools for Category 2a sources
EPA
Includes any SLT inputs submitted by 11/15/2018
12/31/2018
Cat 2a: EPA posts 2017 nonpoint emissions from
Category 2a tools in EIS
EPA
Reflects EPA estimates plus any SLT inputs submitted by
11/15/2018
12/31/2018
EPA posts commercial marine vessel shapefile fractions
to CHIEF
EPA
9/30/2018
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Nonpoint Inventory Development
Cat 2b: EPA posts draft vl tools and methodology for
Category 2b sources
EPA
Methodology revisions dependent on resource limitations
11/15/2018
Cat 2b: SLT comments on Cat 2b draft tools due
SLT
Comments submitted via email to NEI team lead
12/15/2018
Cat 2b: EPA posts Final Methodology + input templates
for Category 2b tools
EPA
On SharePoint
2/15/2019
Cat 2b: EPA posts vl tools for Category 2b sources
EPA
Includes any SLT inputs submitted by 2/15/2019
3/15/2019
Cat 2b: EPA posts 2017 nonpoint emissions from
Category 2b tools in EIS
EPA
Reflects EPA estimates plus any SLT inputs submitted by
1/31/19
2/28/2019
Cat 3: EPA posts draft vl tools for Category 3 sources
EPA
Methodology revisions dependent on resource limitations,
posted on NOMAD SharePoint site
2/28/2019
SLT submittal date for CMV and rail estimates
SLT
all other nonpoint emissions submittals due 3/31/2019, Cat 3
inputs due 5/31/19
1/15/2019
SLT deadline for submitting ALL portions of Nonpoint
Survey
SLT
3/31/2019
SLT deadline to submit inputs for Category 1, 2a and 2b
tools used in 2017 NEI
SLT
Though not required, we will allow final SLT input submittals
until the extended-AERR deadline 1/15/2019
3/31/2019
SLT deadline for submitting ANY/ALL nonpoint emissions
SLT
If SLT chooses not to submit inputs
3/31/2019
Cat 3: SLT comments on Cat 3 draft tools due
SLT
Comments submitted via email to NEI team lead
4/30/2019
Cat 3: EPA posts vl tools for Category 3 sources
EPA
SLTs have to decide if they want to submit emissions instead
of either accepting EPA estimates, or submitting inputs by
5/31/2019
6/30/2019
Cat 3: SLTs submit inputs for Category 3 tools, starting
12/1/2018
SLT
Note that we are allowing beyond the extended-AERR
deadline for Category 3 input submittals only. All EMISSIONS
(regardless of Category) and non-Category 3 inputs are due
3/31/2019.
5/31/2019
EPA provides feedback to SLTs on data completeness
and outliers, starting 5/1/2019
EPA
Window open on a case-by-case basis for emissions only with
non-Cat 3 sources earliest. We will note where SLTs
submitted acceptable inputs rather than emissions
9/1/2019
Cat 3: EPA posts final nonpoint emissions for Category 3
tools in EIS
EPA
includes SLT inputs submitted through 5/31/19
8/31/2019
Release Draft NP selection in EIS for all nonpoint
EPA
Should be close to final vl except perhaps for Category 3
SLTs submitted inputs
9/30/2019
SLT provides corrections on case by case basis, starting
5/15/2019
non-Cat 3 sources can and should be provided earlier than
11/30/19
11/30/2019
2017 vl NEI Release in EIS for all nonpoint
EPA
Including Category 3 sources
2/28/2020
Note: The 2018 NEI submission window for the point source inventory will open on June 15, 2019, and close on
January 13, 2020. The 2018 NEI Point inventory will be released in EIS on July 13, 2020. Also, the 2016 NEI
submission window for the point source inventory opened on July 1, 2017, and will close on January 15, 2018.
The 2016 NEI Point inventory will be released in EIS on July 13, 2018.
2.1 How will agencies make data corrections to the NEI data during the QA period?
EPA inventory developers will work with SLT agency staff to provide feedback on their data and allow
corrections on a case by case basis. Corrections will be done similarly to what was done for the 2014 NEI vl
review during early 2016. SLT agencies will submit their corrections to the EIS "QA Environment" and select
"Request Assistance" on their clean feedback report. EPA staff then will review the corrections and open the
window for SLT submission to Production.
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A common issue with previous NEI submissions has been SLTs needing to remove previously-submitted
emissions. There are two methods for removing previously-submitted SLT-submitted data:
1. SLT-based corrections: Submit zero emissions for any single pollutant at the process. For nonpoint
sources, this would be at the state-county FIPS, SCC (and shape ID if applicable). For point sources, this
would be at the emissions process. This method will ensure that SLT emissions for this process are zero
(or null); however, this method will not prevent EPA data from potentially "gap-filling" missing SLT
pollutants at this process. SLTs can either submit zero emissions for all "expected" pollutants that EPA
generates, or, contact EPA with specific processes so EPA can develop "tags" to ensure EPA data do not
gap-fill missing SLT pollutants.
2. Ask EPA to resolve: SLTs contact EPA and request EPA "tag out" their submission (SLT tags). This method
requires information on specific processes and is less-desirable because it relies strictly on email transfer
of information which has proven to be a resource drain during the NEI development cycle. In addition,
these SLT tags will not prevent EPA data from potentially gap-filling the resulting missing SLT data unless
SLTs direct EPA to do so.
2.2 Why has EPA eliminated wholesale data replacements?
EPA inventory developers do extensive QA on data received by the submission due date. Allowing wholesale
replacements, or initial submissions long past the original due date, causes EPA staff to run the complete QA
procedure on all data again. This process delays the NEI release, increases EPA's use of resources, and does not
provide the benefit of the draft review and correction process described above. This change places a lot of
importance on the end of the submission grace period: January 15, 2019 for point, mobile and event sources
and, as discussed in Section 5.4.1, between March 31 and May 31, 2019 for nonpoint sources. It is very
important that SLTs meet the submission deadlines with their best data in order that the QA review and
correction process can proceed.
2.3 What best practices will help my agency meet the deadlines in this schedule?
To assist you in allocating your time and resources to complete this requirement, we are including a suggested
timeline for the facility, point and nonpoint data categories in "Appendix 1 - Suggested SLT Timeline and QA
Checks" on the 2017 National Emissions Inventory Documentation website. Also, included in Appendix 1 are
suggested QA reports to run upon completion of your production submission. To take advantage of these
reports, your data will need to have been submitted early enough that you can check for data quality and adjust
your previously submitted file. Remember that when submitting batch XML file corrections to your emissions
data that you must report the full suite of required pollutants and not just the pollutant emissions needing
correction.
3 General changes to the 2017 NEI process
This section provides some general changes to the 2017 NEI process that affect all or several data source
categories. The subsequent sections of this plan include additional information regarding sector-specific
changes.
3.1 AERR
While the AERR requirements result in a December 31, 2018 deadline for submitting the 2017 NEI data, we
understand the difficulties this presents to SLTs agency staff due to holiday schedules. Therefore, we are
proposing an additional two-week grace period that will end on January 15, 2019. In addition, as discussed in
Section 5.4, we are extending the deadline for nonpoint sources to March 31, 2019 for most non-commercial
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marine vessels and locomotives sources and to May 31, 2019 for SLT-submitted inputs for nonpoint sources that
are covered by EPA tools that rely on point inventory subtraction
A significant change to the 2017 NEI, will be imposing the AERR requirement (via Table 2b to Appendix A of
Subpart A in 40 CFR 51.30) for throughput data necessary for computing nonpoint fuel combustion from
industrial and commercial/institutional (ICI) sources.
The EPA will modify the existing ICI tool used to create nonpoint ICI estimates to compute nonpoint ICI
estimates only from SLT-provided or ICI-tool-computed state-total fuel from nonpoint ICI activity data. We will
no longer support nonpoint ICI emissions computed from point inventory emissions subtraction. We are working
with SLTs on flexible options for SLTs to report either nonpoint activity data, or point activity data used to
reconcile with overall consumption data from the Energy Information Agency (EIA). More information on this
requirement is discussed in Section 4.6 and Section 5.4.3. It is important to note however, that the nonpoint (or
point) ICI input activity data will not be required if SLTs submit nonpoint ICI emissions.
These NP ICI inputs will not be required if SLTs submit NP ICI emissions; however, EPA will no longer support the
point inventory emissions subtraction to compute nonpoint ICI emissions in the ICI tool.
3.2 EIS Reporting Codes
EIS code tables that have been updated are listed below; these code changes are provided in separate
worksheets in the "Appendix 2 -2017 NEI Plan Code Changes" workbook on the 2017 National Emissions
Inventory Documentation website. Refer to the "readme" spreadsheet in Appendix 2 for information on each of
these code change spreadsheets, including an initial release date, a last updated date, spreadsheet description,
and a field describing updates, or expected updates, to the initial spreadsheet. As these updates become
available, we will update both the Appendix 2 worksheet(s) and will send emails to the existing NEI/EIS listserv
contact list -consisting primarily of EIS inventory developers for each agency.
1. Control Measure Codes: All active codes in EIS are provided with new descriptions and/or codes
highlighted.
2. Unit Type Codes: New unit type codes are provided in red font in the spreadsheet. New codes later for
Printing, Refineries, Waste Disposal and Pulp and Paper are highlighted.
3. Source Classification Code (SCC) Changes
a. Point: There have been several changes since the 2014 NEI that are already in the EIS SCC table.
Currently, SCCs for Printing, Refineries and Waste Disposal sources are being reviewed as part of
a periodic effort to streamline SCCs in some sectors. EPA is evaluating creating new SCCs or
modes to capture aircraft cruising emissions by aircraft type for better emission distributions in
ambient modeling. We will update the spreadsheet in Appendix 2 once we have the proposed
changes for these SCCs. Additionally, specific sector SCCs may be reviewed as part of upcoming
Risk Technology Review (RTR) rules that could happen in the next three years. They are listed in
"Appendix 3 - The "Draft Schedule for Potential Point SCC Revisions" can be found on the 2017
National Emissions Inventory Documentation website. If any SCC revisions from these reviews
occur before the submission deadline, we will update the Appendix 2 spreadsheet. There will be
an opportunity to comment on any of these SCC changes if and when they happen.
b. Nonpoint: Many SCCs are being retired, and several new SCCs either are being created or
brought back from retirement. Most of the SCCs we are retiring were not used by SLTs in their
2014 submittals, and those that were can be mapped to different existing SCCs. The primary
reason for removing these extraneous SCCs is to prevent possible double-counting of emissions
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and confusion over what the SCC is intended to capture. A live list of all SCCs can be found on
the Source Classification Codes (SCCs) web service page.
c. Events: For 2017, we have added an SCC in EVENTS separately for pile burns. We will work with
SLTs on this new NEI data source as SLTs have already indicated that activity data (e.g., tons
burned via permits) may be available for inputs to this new source/SCC. EPA will likely not
estimate these emissions, but SLTs will be able to submit emissions to a new SCC for this source.
d. Onroad: No new SCCs are expected
e. Nonroad: New SCCs for MOVES are expected but timing is unknown.
4. Pollutant Codes
a. Recent efforts to incorporate test data from regulations into EIS have resulted in the need to
revisit the current pollutant codes. The rule data require a more expansive list than the current
EIS list. To allow for future selections to include these data, we may make changes to the
pollutant table. Discussions are currently underway on which changes will be needed to support
rule data and if these will affect agency submissions. These changes would result in additional
pollutant codes and would not result in retiring any pollutant codes.
b. Eighteen (18) Glycol Ether pollutants are no longer classified as HAPs but have been changed to
a classification of "OTH" or "Other". These pollutants did not meet the CAA definition of glycol
ether established by the final rule "Redefinition of Glycol Ethers Category under Section
112(b)(1) of the Clean Air Act and Section 101 of the Comprehensive Environmental Response,
Compensation and Liability Act (40 CFR 63)". We chose to allow agencies to continue reporting
these to prevent unimportant EIS error messages; however, these 18 pollutants will not be
selected for the 2017 NEI because they are not HAPs. The only "OTH" pollutants to be selected
for the 2017 NEI are hydrogen sulfide, tert-butyl acetate and the species listed in the following
item.
c. New pollutant "N590" representing polycyclic aromatic compounds, a pollutant reported by TRI
that represents up to 25 specific PAH compounds.
d. New pollutant 106945, 1-Bromopropane, also known as n-propylbromide was added. The
pollutant type is "OTH" (other).For the 2014 NEI, we added 5 PM2.5 species (EC, OC, N03, S04
and PMFINE) and 2 diesel PM species to the NEI that are generated only by EPA through PM
speciation. These pollutants will also be in the 2017 NEI, but as with 2014, they cannot be
reported by SLT.
e. Extractable Organic Matter (EOM): For the 2011 NEI and later, we un-retired pollutant code 284,
Extractable Organic Matter (EOM). Emissions from a variety of source categories have used
measurements of BSO, MCSO and other solvent extraction methods to characterize complex
emissions. As with coke oven emissions, the solvent selection is not as important as the
characteristics of the emissions from the specific source category. EPA has developed several
rules (including primary and secondary aluminum) for which this pollutant is required to be
reported in compliance testing and these compliance data will be used to develop emission
factors. EOM is typically measured using EPA Method 315 and is one component of EPA Method
202. It is conservatively considered an indicator of polycyclic organic matter, which is a listed
hazardous air pollutant. EOM should not be reported with polycyclic aromatic hydrocarbons
(PAH) for the same process, as it could be considered as double counting. EOM should NOT be
reported for processes associated with coke batteries such as battery charging; battery lid,
offtake and door leaks; pushing, quenching, and combustion stacks, as pollutant code 140 (coke
oven emissions) should be used for these.
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5. NAICs Codes: The list of NAICS codes that will be valid and acceptable in EIS was updated in January
2018 to reflect the retirements and additions made by the US Census Bureau for their 2017 revision. In
addition, for EIS, we will not accept any of the 1-, 2-, or 3-digit level NAICS codes in the Census Bureau's
list. Note that in the past we have accepted the 3-digit NAICs in EIS. A small number of actively reporting
EIS facilities have been edited to a minimum of 4-digits.
While the above is the extent of known retired and additional codes, new codes for these and other EIS datasets
may be added later in the year if deemed necessary. No codes will be retired after the publication of this revised
plan.
3.3 Expected Pollutants and Data Categories
SLT agencies have requested that EPA provide a list of expected pollutants by process (SCC), and we provided
these for the point and nonpoint data categories in preparation for the 2014 NEI. For the 2017 NEI cycle, the
EPA will be starting with the same list of expected pollutants for both point and nonpoint sources. New nonpoint
SCCs are expected, and EPA will provide an updated expected pollutant list for the 2017 nonpoint NEI before the
submittal window opens on July 1, 2018. The current lists of expected pollutants are available on the 2014
National Emissions Inventory Documentation website.
The reporting of criteria air pollutants (CAPs) is required under the AERR for all data source categories, while the
reporting of hazardous air pollutants (HAPs) is not. However, HAPs are critical to complete the NEI, and will be
supplemented by EPA if SLTs do not provide these data, and therefore, HAPs are also included in these lists.
An SLT's agency data submittal will not be considered "incomplete" if it does not voluntarily report HAP
emissions, but it will be augmented with EPA estimates of HAPs using EPA data augmentation procedures.
The purpose of the expected pollutants list depends on the data category. Each data category is discussed in the
following subsections.
3.3.1 Point
For point sources, the expected pollutants list indicates where other agencies have reported non-trivial amounts
of a pollutant for each SCC, based on the following criteria:
1. The SCC contributes at least 0.1% of the total national emissions for that pollutant, and includes an
existing emissions factor (e.g., AP-42), OR
2. The SCC contributes at least 0.01% of the total national emissions for that pollutant, and 75% of the
processes using that SCC reported that pollutant (with a minimum sample size of 3 processes), and the
SCC does not include a nebulous catch-all "Other" or "Miscellaneous - NEC" in the description;
3. For fuel combustion SCCs, we include the same pollutants across all related SCCs for the same fuel.
SLT-submitted pollutants that are not in the expected pollutants list for point sources will be used in the NEI. We
may however tag out pollutants which are clearly not only not expected, but also nonsensical, such as VOC or
NOx emissions from rock crushing SCCs.
EPA will add HAPs to facilities where they are not reported by SLTs by first using the TRI-reported data and
second by relying on SLT-submitted VOC or PM values via HAP augmentation. EPA may use other sources of
data, where available, including carrying forward previous-year data for gap filling. The database providing the
HAP augmentation factors is in the Emissions Inventory System Gateway. This database is updated based on
comments from the NATA reviews, and may be further updated if new factors become available or if errors are
found. SLTs should use their existing emission factors, or preferably source tests, prior to the submittal deadline,
and not rely on EPA's HAP augmentation dataset for inventory construction. The version of the HAP
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augmentation database to be used for the 2017 NEI will be finalized by 1/15/2019. As with the 2014 NEl, SLT-
reported chromium will be speciated into chromium (VI) and chromium (III) using chromium speciation factors
provided in the HAP augmentation database.
3.3.2 Nonpoint
One of the goals in developing the NEI is to have as cohesive and congruent of a picture of the air pollutants in
the nation for a particular inventory year. In order to create this cohesiveness, EPA has to treat data in a
consistent way when emissions data submitted by states looks too large in comparison to the rest of the data, or
incorrect. Therefore, for the nonpoint sources, the expected pollutants list has a more active role in what ends
up in the NEI, and a set of business rules has been proposed to streamline this process. The expected pollutants
list from all 2014v2 NEI EPA estimates includes HAPs and CAPs that EPA will gap fill if these data are not
submitted by the SLT agencies. If EPA does not estimate emissions for a particular source type, there will be no
expected pollutants list for comparison, as EPA acknowledges that those source categories that are not
estimated on a national basis are not well-assessed by EPA at this point in time.
For the expected pollutants list, all pollutants for each nonpoint SCC are provided. We will map expected
pollutants to most active SCCs in sectors where EPA estimates exist for other like-process/fuel SCCs based on
data in the existing EIS HAP Augmentation table.
For the 2017 NEI, we are proposing the following set of business rules in Table 3-1 to be used in conjunction
with the nonpoint expected pollutants list. Note each of the items in Table 3-1 has accompanying explanatory
text following the table.
Table 3-1: Nonpoint inventory pollutant SLT-submittal business rules
Item
If an agency submits...
EPA will...
Unless...
1
Emissions that exceed EPA
expected outlier check values
Use EPA estimates in lieu of
SLT data
State provides supporting
material on how the emissions
were estimated, including
activity and emission factor
details where available
2
Pollutants not in expected
pollutant list
Remove these pollutants
(e.g., VOC from road dust,
metals from evaporative
processes)
SLT provides documentation on
these unexpected pollutants
3
VOCbut no HAPs
Run HAP augmentation off
of the SLT-submitted VOC,
and this data will take
precedence over any EPA
tool data
The VOC submitted falls outside
of EPA's expected outlier check
4
Total VOC-HAPs > VOC
(the sum of all of the HAPs
that are VOCs adds up to
more than the submitted VOC
value)
Remove all state submitted
VOC-HAP data and instead,
use HAP augmentation off of
the SLT VOC value
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Item
If an agency submits...
EPA will...
Unless...
5
VOC and different VOC-HAPs
than our expected pollutant
list
Gap fill using HAPs
generated by HAP
augmentation off the SLT
VOC value
The sum of augmented + SLT-
submitted VOC-HAPs adds up to
more than the VOC value; (see
4 above); in this case, all SLT
HAPs will be removed and
replaced with HAP
augmentation off the SLT VOC
value
6
An incomplete set of expected
criteria pollutants
Supplement using EPA tool
data for the pollutants that
are not submitted
SLT provides documentation to
why those emissions should not
exist
7
VOC data for different SCCs,
but similar process
characteristics to what EPA
uses
EPA will augment VOC-HAPs
with similar profiles
State also submits HAPs with
that VOC
For item 1, regarding emissions greater than outlier checks, the intention is to prevent inconsistencies when
looking at the nation as a whole, which may not really exist, and may instead be due to a mistake in calculations
or data entry. EPA will initiate a dialogue with reporting agencies where submitted emissions exceed expected
ranges, particularly for rapidly changing sectors such as oil and gas. These outlier checks will be based on county-
SCC-pollutant level statistical analysis of the EPA estimates generated for the 2014v2 NEI. Supporting
documentation requirements are not intended to be onerous, but can serve as a path for EPA to get
confirmation that SLTs intend for significantly larger than expected emissions to be included in the NEI, may help
inform EPA's tools, and can allow EPA to revise the outlier checks where needed. Outlier limits can be found by
pollutant/SCC combinations in EIS under Reporting Code Tables, Emission QA Values.
Item 2, regarding unexpected pollutants, is intended to prevent inconsistencies or incongruent data from
showing up in the inventory, which may not be "real." Sometimes an agency submits pollutants that no other
state agency reports, and this may appear as an anomaly on the map for a particular pollutant when looking at a
source category as a whole. For example, one state agency reported lead as a pollutant from commercial
cooking. While this may be a real pollutant from the restaurant griddles, it also may be a misassigned SCC or
pollutant code. In any case, if EPA deems it an "unexpected pollutant," EPA may not have a good emission
factor or may not have the data to support that a certain pollutant is part of a source category. In these cases,
when comparing the EPA dataset to SLT datasets, a hotspot may show up, highlighting the submitting state, in
this example, as the only place in the country where you could find lead being emitted from restaurants.
Item 3, regarding VOC submitted without their corresponding HAPs, is straightforward; the goal is to fill in
missing HAPs in the inventory where EPA expects them to exist but they were not provided by the submitting
agency. HAP augmentation on SLT-submitted VOC will be used when it does not exceed the outlier check and
VOC is reported but VOC-HAPs are not. Item 1 would apply where the outlier check is violated.
Item 4, regarding VOC-HAPs summing to greater than VOC, is the broad check for where the sum of all SLT-
submitted VOC-HAPs must be less than SLT-submitted VOC. EPA is conducting this analysis to prevent
nonsensical data, since the parts should not add up to more than the whole. If a violation occurs, SLT-submitted
VOC is retained, but all SLT-submitted VOC-HAPs are not used (tagged out) and replaced with HAP augmentation
VOC-HAPs after scanning for obvious outliers.
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Item 5, regarding different HAPs being reported than EPA's expected pollutants, builds off item 4 in complexity,
dealing with the messy scenario where we end up with a mix of SLT-reported VOC-HAPs and VOC-HAPs from
HAP augmentation. Like item 4, the intention is to prevent nonsense data where the parts sum up to more than
the whole. This happens when SLTs submit VOC and some but not all expected VOC-HAPs, and HAP
augmentation, based on SLT-submitted VOC, is used to "gap fill" the remaining unreported VOC-HAPs. It is
understandable that SLTs may only have emission factors for some VOC-HAPs and that the method may be
different from the VOC emission factor. However, air quality modeling based on the NEI assumes a level of VOC-
HAP to VOC mass closure. Therefore, if SLTs do not want EPA to generate "missing" VOC-HAPs, they should
submit emissions for VOC-HAPs that are in the expected pollutants list. SLT could submit zero emissions if these
pollutants are not emitted from these processes in a particular area due to controls, bans or other location-
specific information.
Item 6, regarding missing criteria pollutants, is intended to provide a cohesive inventory; for example, if NOx is
not submitted for a combustion category, EPA has the need to gap fill. This rule is simply a reflection of how the
NEI has been built in the past: SLT data takes precedence over EPA-submitted emissions. If EPA data exist for
pollutants that SLTs do not submit, then EPA data "gap fills" and appears in the NEI selection. If SLTs do not want
EPA data, that are in the expected pollutants list, to appear in the NEI, they have a couple options:
1. Submit emissions, which could be zero if these pollutants are not emitted from these processes in
your jurisdiction for these "expected" pollutants, to ensure EPA emissions data do not appear in the
NEI, or
2. Contact EPA to request removal (tag-out) of EPA emissions for these pollutants, if they are not
emitted.
Option 1 is more automated and easier to track. This item is most important for CAPs and "high risk" HAPs.
Option 2 has been the standard approach in previous NEI cycles; however, it complicates QA and has led to
numerous errors in the past.
Item 7, regarding running HAP augmentation on similar SCCs to those for which EPA has profiles, is also intended
to fill missing pollutants in the inventory, and this has been standard procedure in previous NEI cycles. Where
SLTs report emissions for SCCs that EPA does not report, EPA data will be used if SLTs do not report all
pollutants, and this goes beyond just HAP augmentation for VOC-HAPs.
Voluntary reporting for HAPs, particularly, VOC HAPs, gets complicated for some nonpoint sources where EPA
provides tools that include point source (inventory) emissions subtraction. For example, the Solvent tool only
subtracts point inventory CAPs for some sources, and not VOC HAPs, when choosing to subtract point emissions
and not activity data. The Solvent tool in this case will compute nonpoint VOC via point subtraction of emissions,
then use HAP augmentation (matching augmentation profiles in the EIS, but also built into the tool) to compute
nonpoint VOC HAPs. The reason EPA built the Solvent tool to not subtract VOC HAP point emissions is because
the material balance for point subtraction (reconciliation) is ideally based on activity/throughput of the material
being balanced. Emissions, or emission factors, from any source, have no validity in such a material balance. SLTs
are free to recompute their VOC HAP emissions for nonpoint solvents, and so long as these VOC HAP emissions
satisfy the checks discussed above, they will be accepted.
None of these business rules impact what is stored in the EIS for each agency-only what will appear in the NEI
selection. EIS reports run off SLT datasets will still capture what SLTs submit. However, the final 2017 Inventory
will reflect a converged set of data, with EPA tool data, SLT submitted data, and augmentation datasets
included.
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3.3.3 Mobile and Events
Onroad and nonroad expected pollutants are the CAPs and HAPs generated by MOVES.
The expected pollutants for the EVENTS category are those that we estimate in EPA's methods. It is expected
that this list will remain the same as it was for the 2014 NEI. That list can be found in Section 7 of our 2014 NEI
Technical Support Document.
3.4 New Cross-dataset business rules for selecting pollutant data across different
datasets
Business rules have been developed for the 2017 NEI to allow different datasets in a selection to be blended
together while avoiding double-counting due to overlapping HAPs. There are several HAPs that belong to
pollutant groups or represent a pollutant group itself. Therefore, EPA has developed a set of business rules to
prevent both individual pollutants and a group of pollutants from different sources being in the inventory for the
same process or facility. These business rules, except for PAH POM code 250, already apply to each individual
dataset within EIS and will now extend to all datasets within a selection in EIS. PAH POM is the exception: this
pollutant can be submitted with other PAHs in an individual dataset, but cannot be combined with any PAH
across datasets. More details on this set of business rules is provided in "Appendix 5 - Cross dataset tagging
proposed rules" on the 2017 National Emissions Inventory Documentation website. These rules have been
implemented in earlier NEI years via the use of data tagging for point sources.
3.5 HIS QA Checks
A list of QA checks performed on data submittals can be found in the Emissions Inventory System Gateway. The
following QA checks are not yet implemented but will be prior to the 2017 submittal window opening on July 1,
2018:
1. Update critical QA check 517 stack exit velocity from low-threshold of 0.01 feet per minute to 0.06
feet per minute.
2. New critical QA check on stack flow rate: when velocity is computed from flowrate and diameter,
velocity needs to satisfy current velocity check range 0.001 to 1000 ft/second.
The following new QA changes are in place for the 2017 NEI cycle.
3. Additional critical QA checks.
a. New requirement for reporting "heat values" when SLTs report events inputs -see Section
7.2.2.
b. "CURIES" can now only be used as the unit of measure for radioactive pollutants.
4. Additional warning QA checks. There are no new warning checks.
5. Update from Warning to Critical
Check 511 - Release Point Stack Temperature Measure Range will be upgraded from warning to
critical.
6. Deleted QA checks
a. Check 1152 - Release Point Exit Gas Velocity Measure Critical Range - duplicate check of
checks 512 and 517
b. Check 1153 - Release point Exit Gas Flow Rate Measure Critical Range - duplicate check of
checks 518 and 519
c. Check 2211 - Release Point Exit Gas Temperature Measure Outer Range - duplicate check of
check 511
The remaining changes pertain only to fires in both the Nonpoint and Event data categories:
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7. Check for valid Emission Calculation Method Code (Critical) - When reporting emissions for SCCs
2810001000, 2811015000, and 2811020000 in the Event Inventory, data submitted will be required
to use either Emissions Calculation Method Code 40 - Emission Factor based on Regional Testing
Program; 41 - Emission Factor based on data available peer reviewed literature; or, 42 - Emission
Factor based on Fire Emission Production Simulator (FEPS).
8. Check for present Event Staging Code (Critical) - Event Staging Code has been raised to a "critical"
check, making this data field required.
9. Ensure Activity values are reported (Critical) - For all SCCs with a Tier 3 description of Agricultural
Fires, the following EIS fields will now be required: Calculation Parameter Type Code (I), Calculation
Parameter Value (number of acres burned), Calculation Parameter Unit of Measure (Acre), and
Calculation Material Code (Ill-Fire). See Appendix 4 in the 2014 NEI Plan on the 2014 NEI
Documentation website for these SCCs.
3.6 EPA Completeness Feedback
The NEI data are the foundation for key EPA regulatory and other analyses. Due to the importance of this
inventory, the EPA will again provide completeness reports. In the 2017 NEI cycle, the completeness reports will
be available through the EIS Gateway to SLT agency staff and the EPA regional offices. Allowing SLT agency staff
to run these reports themselves will provide SLTs with the greatest possible time to address any incomplete
findings. SLT agencies will only be able to see completeness reports for their own agency and delegated
agencies. With the release of the 2017 NEI, letters based on the final completeness reports will also be provided
to state and local Air Directors.
The completeness checks will be based on the following criteria:
Point:
1. Check that all facilities with an operating status of OP (Operating) have been reported. This will be
done using the Agency Submission History Report available on the EIS Gateway.
2. Percent of completeness based on SCC/expected CAPs. Voluntary HAP data submission will be noted,
though lack of HAP data will not count against a completeness percentage. These checks will be
available via a completeness report function in the EIS Gateway.
Nonpoint:
1. Completion of a nonpoint survey.
This survey has been simplified from that which was implemented in 2014. It will only have one
question with a few choices of answers: either EPA should supplement the SLT submission or not;
and this question can be answered at the level of: 1) the entire nonpoint data category, 2) for all
SCCs in a particular EPA tool/database, or 3) at an SCC basis. The reasons for not supplementing SLT
data with EPA data would be: 1) SLT does not have this type of source in the state (i.e., no coal fired
residential boilers), 2) SLT covers this category in point (i.e., gas stations are all covered in point in
the state of Colorado), or 3) SLT uses a different SCC that covers the same process covered by the
SCC used by EPA that also covers additional processes (e.g., composting under SCC 2680002000
where this SCC covers both green waste, which EPA methods cover, as well as other materials being
composted). In addition, there is a 4th no option "Supplement only at reported location -SCCs"
where EPA data will only supplement pollutants where SLT reported some but not all expected
pollutants at a given county and SCC, but will not supplement with EPA data where SLTS reported no
data (pollutants). This nonpoint survey is under development and should be available in August
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2018. Once implemented, the nonpoint survey, in conjunction with the Option Group/Option Set
functionality, will eliminate potential EPA-SLT duplicates from overlapping nonpoint SCCs.
2. Percent of completeness based on SCC/expected CAPs.
Voluntary HAP data submission (or acceptance of EPA data) will be noted, though lack of HAP data
will not count against a completeness percentage. These checks will be available via a completeness
report function on the EIS Gateway.
Onroad/Nonroad:
1. Completeness is based on an agency either submitting inputs or accepting EPA estimates.
Events:
1. Completeness is based on an agency either submitting inputs or accepting EPA estimates. In the
cases where they do submit emissions, completeness will be based on submitting all the pollutants
we estimate in EPA's methods. This includes CAPs, HAPs, and GHGs. Additional efforts to provide fire
activity data from state forestry programs will be noted. For agencies submitting actual emissions,
HAP emissions factors will be provided by EPA.
The table below provides an example feedback table that would be compiled from the EIS completeness reports
and included in the letters to the Air Directors. Ongoing work to resolve the details on the final feedback letter
may change this example.
Data Category
Status
Percent
Complete1
Voluntary
HAP level2
What to do
Point sources
75% of facilities
reported
60%
Modest
Report remaining facilities or
indicate facility shutdowns.
Reporting all expected criteria
pollutants for reported SCCs or
correct SCCs.
Nonpoint sources
Survey submitted,
Data partly complete
80%
High
Report remaining expected
criteria pollutants for SCCs
reported.
Onroad mobile
Inputs not provided
0%
No data
Submit model inputs or accept
sources
EPA inputs/emissions.
Nonroad equipment
Inputs not provided
0%
No data
Submit model inputs or accept
sources
EPA inputs/emissions.
Events
Inputs provided
EPA data accepted
200%
High
1 Based on expected SCC/pollutant combinations for pollutants required by the Air Emissions Reporting Rule.
2 Level as compared to all other agencies submitting data. High = Submitted and highly complete; Modest = Between 40% and 70%
expected HAPs provided for SCCs reported; Low = few SCCs reported with HAPs or less than 70% of expected HAPs for SCCs reported;
No data = no HAP data or model inputs were reported.
urces
4.1 Overview
Air agency point source data are the predominant source of point source data in the NEI. Point source reporting
includes both the "facility inventory" and "emissions" as separate reporting steps, each with their own set of
tables defined for electronic reporting. The following subsections provide a road map to the requirements from
the AERR and the best practices for submitted data. Additional subsections provide specific information on
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point-source specific practices for the 2017 NEl, including a discussion on how EPA intends to include
Greenhouse Gas (GHG) emissions for 2017 and treatment of fugitive release point parameters in EIS for
modeling.
As in past NEI cycles, the EPA intends to augment state point source emissions when needed. Augmentation
includes PM augmentation, HAP augmentation (factors to ratio HAPs from CAPs), chromium speciation, and
including emissions from the TRI.
4.2 AERR Requirements
Please refer to 40 CFR Part 51, Subpart A for the point source submission requirements. Key requirements for
your attention include:
• The data fields required by the AERR are provided in Table 2a and 2b to Appendix A of the AERR. The
field definitions are provided in Section 51.50 of the AERR.
• The point source reporting thresholds are specified as part of Section 51.50 definition of point sources.
The emissions thresholds are specified as "potential to emit" emissions (except for lead) and are lower
for sources within nonattainment area boundaries for ozone, PM10, and CO nonattainment areas. The
reporting threshold for lead emissions as point sources is 0.5 tons per year of actual emissions.
4.3 Inclusion of Greenhouse Gas Emissions for Point Sources
The 2014 NEI included emissions for some Greenhouse Gases (C02, CH4 and N20) in some data categories (on-
road, non-road and events). For point sources, EIS has included an emissions data set containing the point
source GHG (C02, CH4, N20 and SF6) emissions as reported by facilities to the EPA GHG Reporting Program
(GHGRP) beginning with the 2013 emission year. These GHGRP emissions were not included in the 2014 NEI vl.
For the 2017 NEI, we plan to include point source emissions of those four GHGs in the published NEI. The
primary source of the selected GHG data will be the direct facility reporting to the GHGRP. We will also use S/L/T
reports of the same four GHGs if they have been reported for facilities which do not appear in the 2017 GHGRP
data. We expect that any such S/L/T reports which are so used will be for smaller emitters of GHGs, given the
reporting requirements of the GHGRP. We will use the GHGRP data preferentially over S/L/T-reported data
because the GHGRP data is required of the facilities, the calculation procedures have been prescribed by
regulation, and the facility-reported data is reviewed by the EPA GHGRP to be EPA's authoritative source of GHG
emissions for those facilities. Note that we are not requiring S/L/Ts to report GHGs to EIS for any facilities, but
we plan to include any voluntarily reported S/L/T point source data in the NEI if it appears to be valid and if we
do not have any GHGRP data for that facility.
For 2017 we plan to use as a minimum the facility-level totals for each of the four GHGs. We will investigate
using unit-level emissions for C02 where they are available from the EPA CAMD emissions reporting system. We
will store the facility-level non-biogenic C02 emissions as reported to the GHGRP, along with the CH4, N20, and
SF6 emissions. Biogenic C02, which is reported as a separate element to the GHGRP, will not be included in EIS
or the NEI. As with the earlier years, we will convert the values as published on the GHG Reporting Program Data
Sets website from C02-equivalent mass to actual mass, for consistency with the rest of the NEI and its
applications. The conversion factors used for 2014 were obtained from Table 1 of the IPCC's Fourth Assessment
Report (25 for methane, 298 for nitrous oxide, 22,800 for sulfur hexafluoride), per the documentation given on
the GHG Reporting Program web page.
A crosswalk of which GHG facility IDs correspond to which EIS Facility IDs for the purposes of writing the GHGRP
emissions values into EIS is available in EIS. The GHGRP facility IDs are stored as Alternate Facility IDs for each EIS
facility. These Alternate Facility IDs can be seen on the EIS Gateway screens for a particular facility, or a bulk
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report can be obtained from EIS by using the Facility Configuration reports, Alternate Facility IDs, and filtering
for Program System Code = "EPAGHG". The 2014 GHGRP facility summary file contained 7289 facilities as
identified by the GHG Facility ID. Of those 7289 GHG facilities, 5396 have been matched to EIS facility IDs. In
some cases, more than one GHG facility was matched to a single EIS facility ID. In those cases, the sum of the
multiple GHG facilities will be written to the EIS facility. Based on the 2014 reporting year, 95 percent of the
total C02 reported to the GHGRP is matched and stored to an EIS facility.
We will review the 2017 GHGRP facility summary file when it is available to update the EIS crosswalk for any
additional facilities that can be matched with reasonable certainty. We do not plan to add GHGRP facilities that
cannot be readily matched as new EIS facilities, based upon the limited additional GHG emissions that would be
accounted for by these facilities and the increasing possibility that the facility may be accounted for in EIS in
some fashion by S/L emissions submittals, whether as point, non-point, or non-road sources.
Based upon the 2014 datasets it appears that the largest reporters of C02-equivalent that cannot be found in
EIS are underground coal mines. These sources can emit enough methane to surpass the GHGRP minimum
thresholds without having much criteria air pollutant emissions. We do not plan to attempt to calculate GHG
emissions for EIS facilities where we have neither a GHGRP value nor a S/L/T value. While combustion C02
emissions might be reasonably estimated if provided a valid annual fuel throughput, we do not believe that the
ElS-reported fuel throughputs should be relied upon without significant new QA review, particularly for the
smaller combustion sources that would not already be matched to a GHGRP facility. An augmentation of C02 or
CH4 emissions based upon a ratio to NOx, CO, or other ElS-reported criteria emissions would likely be extremely
uncertain given how much larger C02 emissions would be than the criteria pollutants and how variable the
ratios might be given the sensitivity of the criteria pollutants to controls or operational parameters.
We will look for S/L/T reported facilities with NOx emissions greater than some threshold where we would
expect a GHGRP value but none is available. EPA will contact the SLT for these occurrences to confirm whether
the NOX values are correct.
EPA will not be adding any C02 emissions values not reported by either the facility directly to the GHGRP or by
the SLTs to EIS. Note that the reporting of any GHGs by SLTs to the EIS is not intended to supplant the required
reporting by facilities, and SLTs are not required to use the GHGRP protocols if they choose to report values to
the EIS. SLTs should not report GHGs to EIS if they are concerned about them appearing in the NEI. Any facility-
reported GHG values to the GHGRP will be used preferentially before any SLT-reported values to the EIS.
4.4 Source characterization of fugitive sources
The following clarifications on how we characterize fugitive emission release point angles and dimensions are
offered. This set of instructions are used to improve air dispersion modeling in support of the National Air Toxics
Assessment (NATA). The OA check that restricts the fugitive angle measure, EIS variable "Fugitive Angle (DEG)",
is now limited to between zero (0) and 89 degrees of rotation, no longer 180 degrees. The latitude/longitude
coordinates for the fugitive release point should be reported as those of the most western corner, and the angle
is measured clockwise around that point from true (not magnetic) north. The "Fugitive Width (FT)" EIS variable is
the measure along the side that would run in the East-West direction if the angle were 0 degrees and the
"Fugitive Length (FT)" EIS variable is the measure along the side that would run North-South if the angle were 0
degrees. In the example below, the release point coordinates are located at the push pin, the length is 1897
feet, the width is 680 feet, and the angle is 22 degrees.
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Figure 4-1: Example of Fugitive release point parameters
4.5 Point source best practices
The EPA encourages the use of the following best practices when submitting emissions of point sources.
• Collecting data from facilities:
o Request that facilities use stack test data, material balances, or other site-specific and reliable
calculation methods to estimate emissions for their processes. Where such methods are not
available, facilities can use the best available emission factors for similar processes,
o Require that facilities use the latest EIS reporting codes. Download these as described above and
make them available to your facilities,
o For HAPs, encourage facilities to compare their HAP submissions to what has been submitted to
TRI. While the EPA prefers the HAP emissions for the NEI because it is at a more detailed process
level, the facility-level TRI data and State-reported process-level data should sum to the same
values.
• Building your inventory:
o Use consistent identification codes from one year to the next (e.g., facility, unit, release point,
and process identifiers). This prevents the creation of duplicate facilities or sub-facility records,
which reduces the potential for double-counted emissions to be introduced either in State-
reported data or due to the use of TRI augmented values. If needed, work with your information
technology department to identify ID changes that have been made in your data system and
update your agency IDS in EIS.
o Provide control information whenever possible, making sure that it is complete. The control
data are required by the AERR (when controls are present), and the EPA uses the control data to
assess future possible controls as a demonstration of whether and how future NAAQS can be
attained.
o Use the expected pollutants list (see Section 3.3) to help prioritize your efforts and QA.
• Reporting best practices:
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o Plan to start your submission process at least 4-8 weeks prior to the deadline, accounting for
time away from the office for holidays,
o If possible, submit the facility inventory data for only those facilities or parts of facilities that
have changed since the previous time the facility inventory data were provided,
o Make sure to also submit updates to the "Operating Status Code" for facilities that are no longer
operating or no longer required to report as point sources. This will impact your completeness
report since facilities which have a Facility Site Status Code of OP (Operating) that have not
submitted emissions will be counted as incomplete,
o Submit data to the EIS QA Environment prior to submitting data to the Production Environment.
Make sure your feedback reports are clean prior to submitting to the Production Environment,
o Verify that the emission totals in EIS agree with what you have in your agency's data system
after submission to EIS Production (see Appendix 1)
o Run the completeness report and update your submission to meet or exceed all completeness
criteria.
4.6 State total fuel consumption throughput needed
The AERR has a requirement for submitting activity data (throughput) information of point sources. This
throughput is necessary to reconcile industrial (I) and commercial/institutional (C/l) fuel combustion in the
nonpoint data category. If SLTs do not provide state-total nonpoint throughput by fuel type (e.g., natural gas,
distillate oil, coal) and sector (I versus C/l), then EPA will seek to obtain state-total point throughput (and a valid
Calculation Parameter Unit of Measure Code) by fuel type, and 2-digit aggregated NAICS code which will be used
to assign the I vs C/l sector. More information on this request is in Section 5.4.3. There will be ICI Nonpoint
Method Advisory (NOMAD) team calls to help form the new ICI tool methodology and submittal options; contact
Rich Mason for more information.
4.7 Mercury and Air Toxics Standard (MATS) Data
For the 2014 NEI the EPA made available via the 2014 NEI Documentation website the average emission factors
developed from the MATs testing done for several HAPs at electric generating units (EGUs). We made available
our assignment of those bin-average emission factors to each of the EGUs covered by the MATs rule for
consideration by the SLTs in their review for the best estimation method available for their facilities. The MATS
testing was performed in 2010 and covered mercury, lead, several other metals, and HCI and HF acid gases. The
assignments of the averaged emission factors to individual units was reviewed and revised by the EPA for the
2011 NEI, based on controls believed to be in place at that time.
The EPA encourages SLTs to review whether the MATs-based emission factors are still applicable to the units in
their jurisdiction, and to use those emission factors unless they have more recent site-specific data on which to
base an emission estimate. The EPA believes the MATs-based emission factors are more representative of
emissions from these units than the published AP-42 emission factors or metal content equations. SLTs should
also be aware that CEMs for many coal-fired units have been installed and are reporting hourly emission rates to
EPA's Clean Air Market Division beginning in 2015. The EPA will use the CEM values or the MATs emissions
factors and reported heat inputs for 2017 to make estimates of the emissions for these units. These estimates
will be compared to the SLT-reported values to identify any large discrepancies which may need resolution.
Please indicate your review and evaluation of the most current emission factor materials for these units by using
the emissions calculation method code "9" or "10" if you are using one of these bin-average emission factors.
The EPA will interpret emission calculation method code "8" (USEPA Emission Factor) to mean that you are using
the outdated published AP-42 emission factor for these units. Whether you use the MATS emission factor or
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your own site-specific assessment, please also fill in the emission factor field and its associated numerator and
denominator fields.
ointsources
5.1 Overview
Air agency nonpoint source data is an important source of data in the NEl, particularly for those nonpoint
categories that have overlap with point sources. Nonpoint sources include (but are not limited to) fuel
combustion categories; oil and gas production; industrial, commercial and consumer solvents; residential wood
combustion; road and construction dust; and agricultural emissions sources. Though the use of the EPA tools is
not a requirement, EPA provides tools intended to be used by SLT agencies to aid in the calculation of their
nonpoint emissions. New for 2017 is the introduction of the Wagon Wheel tool, which is one central MS Access
tool which calculates most nonpoint categories that EPA estimates (with a few exceptions, like ag fertilizer and
oil and gas). The following subsections provide a road map to the requirements from the AERR and the best
practices for submitted data. Additional subsections provide specific information on an updated nonpoint
source-specific process using a category survey for the 2017 NEI.
As in past NEI cycles, the EPA intends to augment state nonpoint source emissions when needed. The nonpoint
tools that EPA develop also serve a secondary purpose: to provide fallback data for the EPA to use where SLTs
do not submit adequate data to the inventory. Further, augmentation of SLT data also includes PM
augmentation, HAP augmentation (factors to ratio HAPs from CAPs), and chromium speciation.
5.2 AERR requirements
Please refer to 40 CFR Part 51, Subpart A for the nonpoint source submission requirements. Key requirements
for your attention include:
• The data fields required by the AERR are provided in Table 2b to Appendix A. While EIS does not enforce
the reporting of all required data fields, air agencies are legally obligated to report the required fields.
The field definitions are provided in Section 51.50 of the AERR.
• Obtain the latest reporting codes from EIS prior to compiling nonpoint source data. For the 2017 NEI
cycle, some codes have changes (see Section 3.2).
For the 2017 NEI, as detailed in Section 2, we are extending the SLT submittal deadline for all nonpoint sources,
to March 31, 2019 for all emissions and any SLT activity inputs for non- "Category 3" nonpoint sources, and to
May 31, 2019 if submitting activity inputs for Category 3 sources. These deadlines are well beyond the January
15, 2019 extended-AERR deadline for all other NEI sources and data categories. We believe the extended
deadline for the nonpoint data category, particularly for Category 3 SLT inputs, will allow for improved estimates
via more updated activity data and more accurate point source subtraction.
5.3 Nonpoint source best practices
The EPA encourages the use of the following best practices when submitting emissions of nonpoint sources.
• EPA's nonpoint emissions tools:
o EPA encourages SLT agency staff to participate in the review and development of the nonpoint
emissions tools, datasets, and Nonpoint Emissions Methodology and Operator Instructions
(NEMO). The EPA will be continuing Nonpoint Method Advisory (NOMAD) workgroups focused
on method improvements and documentation in the tools, including the request for SLT-
submitted activity data where available.
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o After the tools or datasets are released, the EPA encourages states to review the available
documentation and use the tools to estimate their emissions. Alternatively, if no changes are
needed to these EPA defaults, SLT air agencies can indicate to EPA (through their nonpoint
survey response) their interest in accepting the EPA defaults as their NEI emissions estimate.
• Provide an accurate and timely nonpoint survey response.
• Building your inventory:
o Provide control information whenever possible, making sure that it is complete. The control
program data are required by the AERR (when control programs are present), and EPA uses the
control data to assess future possible controls as a demonstration of whether and how future
NAAQS can be attained.
o Use the expected pollutants list (see Section 3.3) to help ensure complete coverage and reduce
mixing of EPA and SLT-submitted data where possible,
o Use the information provided to EPA in the 2017 nonpoint survey (see Section 5.4.4) to make
sure to report those categories that you indicated you have in your state,
o Focus on categories that require point/nonpoint reconciliation since the EPA cannot do this
reconciliation without state input and will be using older NEI point throughput data as a starting
point for EPA estimates. These efforts will help prevent missing emissions or double counting of
emissions.
• Reporting best practices:
o Plan to start your submission process at least 4-8 weeks prior to the deadlines for each data
category (see Section 5.4.1), accounting for time away from the office for holidays,
o When submitting emissions, submit data to the EIS QA Environment prior to submitting data to
the Production Environment. Make sure your feedback reports are clean prior to submitting to
the Production Environment,
o QA your data after submission to Production (Appendix 1).
o Run the completeness report and update your submission to meet or exceed all completeness
criteria.
5.4 Nonpoint process changes for 2017
The 2017 nonpoint data category will be complied in a much different manner than the 2014 NEI. We are
developing a central database to house all inputs and calculate emissions for most nonpoint source categories,
called the Wagon Wheel Tool. We are staggering the schedule for EPA estimates development and review. We
are also going to utilize an EIS feature called Option Group/Option Set (Appendix 6) and utilizing new business
rules for cross-dataset pollutant selection (Appendix 5). The purpose of these enhancements is to minimize the
need for "tagging" out data that would otherwise lead to double-counting, and automating the process of
selecting data based on overlapping SCCs. By using these processes, EPA has greatly simplified the nonpoint
survey, both in the number of questions an SLT needs to answer as well as EPA's interpretation of the results.
5.4.1 Wagon Wheel Tool
In past inventory cycles, EPA has offered emission estimation tools in the form of many Excel spreadsheets and
Access databases, often with overlapping input and activity data, emission factors, and EIS codes. When any
data point needs to be updated, it often needs to be updated in many different spreadsheets and tools in a
consistent manner. Having multiple places to update the same data point creates more opportunities for human
error. Many tools use the same data, but having to update the same data consistently over several tools was
overall, not an efficient process.
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An improvement in the process for 2017 was the creation of a Wagon Wheel Tool. This tool was developed in
Microsoft Access, and was created so that updated data can easily be input and used without needing to modify
multiple tools. EPA has created the ability to link tables between databases, so that updated data only needs to
be inputted once. The Wagon Wheel tool, shown in Figure 5-1, is intended to increase efficiency and decrease
human error.
Figure 5-1: EPA Wagon Wheel and associated modules used to generate nonpoint estimates for 2017 NEI
Ag
Tilling
Ag
Pesticides
AvGas
Compost
Construction
Dust and
Open
Burning
Master Database
Activity data (e.g.
SEDS, County
Business Patterns,
Population)
Emission factors
General tables
(FIPS codes, pollutant
codes, SCCs)
Point source data
• Crosswalks
Interface
Mining and
Quarrying
Residential
Grilling
Residential
Heating
Bridge
Tool
EPA is encouraging states to only provide inputs to the Wagon Wheel Tool (also see section below). Oftentimes,
late in the inventory cycle, EPA finds errors in the tools, and then must republish tools for states to go back and
download and use again. SLTs lack the resources to rerun tools for resubmission, and so sometimes SLT-
submitted data hasn't taken advantage of the latest updated version of the tool. By having one tool that EPA
uses, we hope to eliminate errors in a cohesive way, and ensure that the data is consistently calculated by all
data submitters.
5.4.2 New staggered schedule and submittal option requirements
One of the biggest challenges with the nonpoint data category has been managing the release of the "final" EPA
estimates (and tools). For the 2017 NEI, EPA has decided to divide most nonpoint tools into three primary
categories on differing schedules. This will allow for EPA and the NOMAD Committee to spend the greatest
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resources and most time on the most important and complicated tools, which individually are referred to as
NEMOs (Nonpoint Emissions Methodology and Operating instructions). This staggered NEMO schedule will allow
more focus on specific nonpoint tools in discrete timeframes during the 2017 NEI development cycle, and will
avoid dumping an overwhelming number of new and revised EPA estimates at once on the SLT inventory
developers. The three NEMO categories are defined as:
Category 1. Sources that do not require point inventory reconciliation (subtraction) and where the
existing methodology is expected to have minimal changes, and thus, extensive additional resource
investment is less important than other sources. In general, any updated activity data between a draft
and final NEI would have minimal effect on the resulting emissions, and therefore, these tools can be
finalized earlier in the NEI process. EPA will release these tools for comment and finalize them first in the
succession of the 3 categories.
Category 2. Sources that do not require point inventory reconciliation, but where the existing
methodology needs updates, and thus, more extensive collaboration with SLTs on methodology and
tools are needed than Category 1 tools. Many of these tools have undergone recent significant
methodology changes in the 2014 NEI cycle, or are expected to undergo significant revisions for the
2017 NEI via coordination with targeted NOMAD subcommittees. EPA will release these tools for
comment after Category 1 tools, but prior to Category 3 tool development. For the revised NEI Plan, we
have further split these tools into earlier "2a" release and later "2b" release to SLTs.
Category 3. Sources that require point inventory reconciliation. These tools are last in the staggered
schedule because, while methodology can be locked in prior to NEI development, properly subtracting
point data generally must wait until the 2017 point data (activity or emissions depending on the tool)
are available. These tools will be pre-populated with latest available activity/emissions data to facilitate
methodology and draft estimate review prior to the 2017 point NEI being made available. The tools will
then be finalized after the 2017 point NEI data are successfully loaded.
Note: not every nonpoint source that EPA estimates falls into one of the 3 NEMO categories above. EPA provides
estimates for commercial marine vessels, locomotives, agricultural field burning and biogenics that do not fit in
this schedule. For these sources, EPA will generate estimates in the fall of 2018 and SLTs will need to submit
emissions by the usual extended AERR deadline of January 15, 2019. Also, draft EPA agricultural (including
rangeland) fire estimates will be provided on July 31, 2018, with SLT comments due September 30, 2018.
Nonpoint Inputs vs emissions submittal options for NEMO tools
It is important to note that EPA will accept SLT inputs for the NEMO tools on this staggered schedule, similar in
time deadlines to emissions submittals for all nonpoint non-Category 3 tools: March 31, 2019. Category 3 tool
inputs are due by May 31, 2019; however, if SLTs do not wish to have EPA process Category 3 tools, they can
submit emissions for Category 3 tools, but by the earlier deadline: March 31, 2019.
SLTs are also able to run the final version 1 tools and/or submit their own estimates by March 31, 2019, a full 2
months beyond the extended AERR-based deadline, January 15, 2019 that is in place for all other NEI data
categories. EPA will provide the templates for activity input submissions. EPA is using a SharePoint directory "SLT
Inputs for Wagon Wheel" on the NEI/NOMAD SharePoint site, shared w/ SLT submitters, to store nonpoint input
submittals. EPA will create a spreadsheet in this directory to summarize the SLTs that submit and the types of
inputs submitted. The exact format will be determined via NOMAD calls in the coming months, but we ask that
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May 18, 2018
SLTs follow the examples already in the directory, with State or local abbreviation prefix (e.g., "KS" for Kansas),
followed by the name of the input template and a date stamp.
The schedule for all NEMOs, including interim milestones of draft tool/estimates release, SLT comment period
deadline, Version 1 tool tool/estimate release, and final NEI estimates are provided in Table 5-1.
Table 5-1: EPA Tools/estimate development schedule for the 2017 Nonpoint NEI
Category 1 NEMO
Tools/Estimates
EPA Tool or
Stand-alone
Database?
EPA posts
draft tool/
estimates
SLT
comments
due
EPA VI
NEMOS
posted
VI tools
Finalized
Milestone Goals
DONE
DONE
4/30/2017
1/31/2019
Ag Pesticides
Tool
Y
Y
Ag Tilling
Tool
Y
Y
Asphalt Paving
Tool
Y
Y
Aviation Gas Distribution Stage
1
Tool
Y
Y
Aviation Gas Distribution Stage
2
Tool
Y
Y
Composting
Tool
Y
Y
Construction Dust: Residential
Tool
Y
Y
Construction Dust: Non-
Residential
Tool
Y
Y
Construction Dust: Road
Tool
Y
Y
Mining & Quarrying
Tool
Y
Y
Open Burning: Municipal Solid
Waste
Tool
Y
Y
Open Burning: Yard Waste
Tool
Y
Y
Residential Charcoal Grilling
Tool
Y
Y
Residential Heating -Non-wood
Tool
Y
Y
Category 2a NEMO
Tools/Estimates
EPA Tool or
Stand-alone
Database?
EPA posts
draft tool/
estimates
SLT
comments
due
EPA VI
NEMOS
posted
VI tools
Finalized
Milestone Goals
6/15/2018
7/15/2018
9/15/2018
1/31/2019
Ag Dust (from hooves)
Tool
Commercial Cooking
Tool
Human Cremation (non-Hg)
Tool
Nonpoint Mercury (including
human cremation)
Tool
Portable Fuel Containers
database
Publicly-Owned Treatment
Works (POTWs)
Tool
Category 2b NEMO
Tools/Estimates
EPA Tool or
Stand-alone
Database?
EPA posts
draft tool/
estimates
SLT
comments
due
EPA VI
NEMOS
posted
VI tools
Finalized
Milestone Goals
11/15/2018
12/15/2018
2/15/2019
3/31/2019
Ag Fertilizer
database
Ag Livestock
database
Biogenics
database
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Open Burning: Land Clearing
Tool
Y
Y
Debris
Residential Wood Combustion
Tool
Road Dust: Paved and Unpaved
Tool
Category 3 NEMO
EPA Tool or
EPA posts
SLT
EPA VI
VI tools
Tools/Estimates
Stand-alone
draft tool/
comments
NEMOS
Finalized
Database?
estimates
due
posted
Milestone Goals
2/28/2019
4/30/2019
8/31/2019
8/31/2019
ICI Fuel Combustion
Tool
Oil and Gas Production &
Tool
Exploration
Solvents
Tool
Stage 1 Gasoline Distribution
Tool
5.4.3 ICI Tool Requirement: State total fuel consumption throughput needed
As mentioned in Section 4.6, the AERR has a requirement for submitting activity data (throughput) information
of point sources. This throughput is necessary to reconcile industrial (I) and commercial/institutional (C/l) fuel
combustion in the nonpoint data category. If SLTs do not provide state-total nonpoint throughput by fuel type
(e.g., natural gas, distillate oil, coal) and sector (I versus C/l), then EPA requests SLTs submit state-total point
throughput (and a valid Calculation Parameter Unit of Measure Code) by fuel type, and 2-digit aggregated NAICS
code which will be used to assign the I vs C/l sector.
EPA, in collaboration with the ICI NOMAD team (contact Rich Mason for more information) will develop the
input templates that will be used as inputs to a new version of the ICI Tool for computing nonpoint ICI emissions.
The Energy Information Agency (EIA) State Energy Data System (SEDS) state-level fuel consumption data will be
the starting point for computing nonpoint throughput if SLTs do not provide state-total nonpoint fuel
consumption by I vs C/l. EPA will subtract fuel-specific SLT-submitted state-level I vs C/l throughput from the EIA
consumption data to estimate the nonpoint I vs C/l throughput by fuel type. SLTs are encouraged to engage in
this process as a lack of submitted nonpoint or point throughput data will require EPA to craft a "default"
method for estimating nonpoint throughput by analyzing only the largest point inventory facilities in each state
to estimate throughput for only these largest ICI facilities. By definition, this will lead to a larger than expected
nonpoint ICI throughput computation than would be expected from a complete point inventory (or direct
nonpoint activity estimate) throughput estimate.
The ICI tool will also be modified to no longer compute nonpoint emissions from point inventory emission
subtraction because of the gross over-estimation of the resulting nonpoint emissions with point source controls
not being reflected in the subtraction. The ICI tool will also not allow county-level throughput subtraction as we
believe the input data (EIA SEDs) does not reconcile well with the point inventory at the county-level. Instead,
the ICI tool will retain (only) the state-level activity (throughput) subtraction by sector (I vs C/l) and fuel type,
and then allocation from resulting nonpoint throughput to county throughput via sector employment data
already built into the ICI tool.
These NP ICI inputs will not be required if SLTs submit NP ICI emissions; however, EPA will no longer support the
point inventory emissions subtraction to compute nonpoint ICI emissions in the ICI tool and we request the SLTs
not use the existing versions of the ICI tool if they plan to submit their emissions rather than submitting inputs
for use in the new version of the ICI tool. There will be ICI NOMAD calls to help form the new ICI tool
methodology and submittal options.
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5.4.4 New SCCs, proposed retirements, and proposed un-retirements
Analysis of the 2014 NEl, EPA and SLT-submitted data and all active and retired nonpoint SCCs identified several
issues with the list of active SCCs. Appendix 2 contains a complete list of all SCCs that have been retired, new
SCCs needed, and SCCs that are currently retired but will be made active again prior to the July 2018 submittal
window opening.
Reasons for retiring SCCs vary but include, but are not restricted to:
• Consistency where similar SCCs have already been retired. For example, Industrial Fuel Combustion,
Natural Gas "All IC Engine Types" is already retired, but "All Boiler Types" is currently active, along with
the general "Total: Boilers and IC Engines". We propose retiring "All Boiler Types". Other examples are
various solvent types in lieu of "Total: All Solvent Types"; no SLT submitted emissions for most of these
SCCs in 2014.
• Remove possibility for double-counting. Too many overly-specific options for some source categories, or
conversely, overly-broad "catch-all" SCC descriptions can make automated reconciliation of EPA and SLT
data difficult to QA. Examples of overly-broad SCCs abound, including Oil and Gas "All Processes: Total:
All Processes" -in this case, should all SLT and EPA data for all other oil and gas SCCs be considered a
double-count?
• If there are instances where we have an SCC that neither EPA uses nor any SLTs.
New SCCs are needed for several reasons:
• For sectors like agricultural livestock and fertilizer application, where EPA utilizes offline models to
create aggregate emissions -by animal type for livestock and a "bidirectional flux" model for fertilizer
application. For example, EPA estimates for livestock waste, beef (and all other model-based animals)
are currently assigned to a "Not Elsewhere Classified" SCC because a beef "Total" All Processes" does
not exist.
• Similarly, where we do not have a "Total", SLTs appear to be assigning emissions to a specific SCC and
EPA emissions for other specific SCCs are used. We suspect this is happening in sectors like Commercial
Cooking.
• Where new sources are being estimated or we are allowing SLTs to submit emissions. Examples include
dust kicked up by hooves and feet for various animal types and agricultural silage. One of the new SCCs
that will be adding under Ag livestock is silage emissions. These emissions (primarily VOCs, and for the
2017 NEI, EPA is unlikely to generate estimates, though SLTs will be able to submit emissions to the new
SCC) occur mostly at dairy farms, where silos are used to store grain used as feed for livestock. While
there are some methods in the literature (for California) that we can consider, how to apply it to the
entire US will be challenging, considering the activity data available for the entire nation. We have been
made aware of a USDA National Agricultural Statistics Service (NASS) "corn silage" database that
includes silage production for every state and will look into this source. We will continue to work with
SLTs to better understand and potentially inventory this source in the 2020 nonpoint NEI if EPA and SLTs
cannot craft a method to be used in the 2017 NEI.
• For the agricultural burning sector (which includes grassland burning), we will introduce a new SCC for
the 2017 NEI which will represent agricultural pile burns. EPA will not provide estimates for this new
SCC, rather we will allow SLTs that have that source to report into it, pollutant coverage will be the same
as that for the SCCs in this sector. HAP augmentation will be done using HAP ratios used for other SCCs
in this sector according to the nonpoint business rules discussed earlier.
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May 18, 2018
We plan to un-retire a few SCCs because we've identified new methods for estimating emissions at these
specific SCC descriptions, or, SLTs have requested the ability to use these SCCs.
5.4.5 Utilization of EIS Option Group/Option Set evaluation to compile NEI
The EIS has an Option Group/Option Set (OG/OS) feature that we will implement for the 2017 nonpoint NEI. In
the Source Classification Code table, we can define SCCs that have a hierarchical nature. That is, there may be a
"general" group, as well as more specific SCCs within the same group. These relationships are defined by the
"Option Group / Option Set" (OGOS) fields in the SCC table. When EPA and SLT datasets are placed in an NEI
selection, there is the potential for double-counting of data sources (emissions) across these data sources. For
example, the EPA may report emissions to a "general" SCC while SLTs report data to detailed SCCs. Without
OGOS evaluation, both sets of data would be included in the NEI selection.
The current OGOS rules employed in the Selection assumes that if a SLT submits data, they are summitting data
for the entire group and no additional data sets are to be used to "back-fill" any SCCs within the same option
set. The desired function is for the selection to back-fill any SCCs within the same option set. Refer to "Appendix
6 - Option Group Option Set Enhancement EIS Requirements.pdf" on the 2017 National Emissions Inventory
Documentation website for a comprehensive discussion on the OGOS business rules being implemented in EIS
for the 2017 nonpoint NEI.
A draft list of OGOS assignments for all nonpoint data category SCCs is provided in the "Appendix 4 - 2017
Nonpoint Proposed OptionGroup-OptionSet" workbook on the 2017 National Emissions Inventory
Documentation website.
5.4.6 Revised nonpoint survey
Because each agency has their own universe of sources and inventory development approaches, each agency
reports nonpoint estimates a little differently. The nonpoint survey will gather information specifically for each
SLT regarding which source categories are covered by point, nonpoint, or both, and about where point source
reconciliation needs to be done to nonpoint activity.
The nonpoint survey was first implemented in 2014, but will be greatly simplified for the 2017 submittal process.
Implementing the previously discussed Option Group/Option Set feature will automate how EPA data are used
to gap fill SLT submittals. One of the primary purposes of the nonpoint survey in 2014 was to prevent EPA
double-counting emissions in sectors where SLTs and EPA report emissions for different SCCs but for similar
processes. EPA anticipates releasing the new nonpoint survey by the end of August 2018.
The nonpoint survey will default to "yes" for all SCCs (sources) that EPA estimates. This has the following
consequences:
• If SLTs do nothing in the nonpoint survey, EPA estimates will be used where computed and where SLTs
do not submit emissions in that Option Group. For example, if you submit some type of woodstoves
with inserts (EPA SCC or not), your SLT emissions will be used and EPA emissions will not; however, if
you neglect to submit any emissions for this Option Group, EPA estimates will be used (gap fill). This is
an important distinction: if you submit emissions for an Option group, they will be in the NEI unless you
actively remove them from your data, or contact EPA prior to the submittal deadline to request EPA
remove ("tag-out") your data. For QA reasons, EPA prefers less tagging than necessary.
• If you indicate "no" in the nonpoint survey, EPA emissions will not appear in the NEI for the Option
Group. You must select one of the 4 reasons for not accepting EPA estimates:
1. I do not have this source.
2. This source is included in my Point Source Contributions.
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May 18, 2018
3. My agency uses different SCCs.
4. My inventory is complete. It does not need to be supplemented.
There is also an option to "Supplement reported location SCCs" only. You would choose this to allow EPA
pollutants to fill in expected pollutants if your submittal does not include all expected HAPs and CAPs. This
option also prevents EPA data from making it into the NEI where SLTs purposely do not report emissions for
some counties. For example, your inventory for some CAPs a small number of HAPs may be survey-based and
not generate estimates for outdoor hydronic heaters in a very urban county; meanwhile, the EPA residential
wood combustion tool, with more simplified spatial allocation has these devices in that county and for all
pollutants. By choosing this "Supplement reported location - SCCs" option, EPA data will only gap-fill outdoor
hydronic heater emissions for pollutants that SLTs did not report, but did report something. Meanwhile, if SLTs
reported no pollutants, then no EPA data will be chosen in the selection.
A very important note on using the Nonpoint Survey:
If you submit activity inputs to the EPA Tool category, you need to accept EPA estimates (do nothing for that
tool) to ensure that your inputs will be processed by the EPA tool and generate an inventory. You only edit an
SCC (to choose one of the 4 "No" options or to restrict EPA supplementing data to reported locations only) if you
are submitting emissions and not activity inputs. Please contact Rich Mason if you have any questions on how
to fill out the Revised Nonpoint Survey.
Revised Nonpoint Survey Examples
Some screenshots on how the revised nonpoint survey will function are provided here. As seen in Figure 5-2,
when you first enter the Nonpoint Survey, you will be greeted with a Survey Status:
• Complete (green): There is an answer for every SCC that EPA estimates.
• In progress (yellow): There is at least 1 SCC in the survey that has an answer, but also has at least SCC
without an answer
• Not started (red): No SCCs in the survey have an answer
Once you edit and save and category in the following screens, the survey will be yellow until all categories are
complete. If you select the "Accept All EPA Estimates" button then this will set the answer for every SCC in the
survey to "Yes - Supplement My Data With EPA Estimates", and this will "Submit" the survey and once pressed,
no further action is required by your agency. These, and more to follow detailed business rules will populate the
text in this opening page as well.
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Figure 5-2: Example of the Noripoirit Survey opening page
Agency Organization Detail
Current Agency
Agency Description: North Carolina Department of Environment and Natural Resources
Agency Type: State
FT! P|-nrp<;gfirniip' O
LP[DO
(jur,
Survey Status: ( )Survey Complete
Shows Current Status of the Agency Survey
1
Agency Responsibilities | Agency Members | Program System Codes I Allow Access FeedoacK Reports Nonpoint Survey
2017 NONPOINT SURVEY
Business Rules
Text in this Area Will Describe the Different
Answers, and How Those Answers will be
Interpreted by EPA.
Main Page Easy Button. If you press
this button, all SCCs in the Survey
will be Answered as "Yes". This will
Give You a "Survey Complete"
Status.
Opens Agency
Survey Summary
Accept all EPA Estimates
Go To Survey
Page
Once you "Go the Survey" on the opening page, you will be directed to the Nonpoint Survey summary page,
shown in Figure 5-3. Each EPA Tool Estimate Category will be listed on the left. These categories (not necessarily
EIS sectors), not to be confused with the NEMO bins 1, 2a, 2b and 3 from Section 5.4.2, represent each nonpoint
"tool" EPA such as "Residential Wood Combustion", "ICI Fuel Combustion", "Solvents", "Ag Pesticides", "Oil and
Gas" and so on.
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Figure 5-3: Example Nonpoint Survey category summary page
Agency Organization Detail
Current Agency
Agency Description: North Carolina Department of Environment and Natural Resources
Agency Type: State
ETL Process Group: 2
Survey Status: ( ,'Survey Complete ; Survey In Progress A Survey Incomplete
Agency Responsibilities Agency Members Program System Codes Allow Access Feedback Reports Nonpoint Survey
A "Category Complete?" is marked as "Yes" when every SCC within the category has been answered and
"submitted", and is marked "No" if at least SCC within the category has not been submitted in the survey. If you
select "Accept All EPA Emissions Estimates" then:
• Each SCC within the category will be given an answer of "Yes - Supplement My Data With EPA
Estimates".
• This implies a "Submit" action
• You can also go back and edit individual SCCs later
The overall survey status changes when the category complete status changes from "Yes" to "No".
If you decide to not accept EPA estimates for every SCC in the category, then you must click on the "Edit SCCs"
button, which will then navigate you to the example detailed SCCs screen shown in Figure 5-4. This is where you
can select specific SCCs that you do not want EPA to supplement, or, where you can have EPA supplement only
at locations (counties) where you reported at least one pollutant. These options were laid out in the beginning
of this section, and once you drag the SCC from the Yes (default) column on the left into the No column on
upper right, you choose one of the 4 "No - Do Not Supplement My Data" via the drop-down dialogue box.
Pressing the "X" from either the "No..." or "Supplement..." boxes will move the given SCC back to the default
"Yes..." box. The "Reset" button will move all SCCs (for this category) back to "yes", regardless of what the
answers were when came in to this page. The "Save" button saves the answers for every SCC as it currently
stands; this does NOT submit your answers; it only saves your current progress. You are encouraged to save
often; this should remove a problem that was common with the 2014 Nonpoint Survey. If you click "Submit"
then you are officially committing to your answers and data is saved and you are sent to the previous Summary
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page, You must submit to complete the survey. If you click "Cancel", then any changes you made since you last
saved will be ignored and you will be returned to the previous Summary page after you select "yes" to the
confirmation message "Are you sure you want to exit this page? Any changes to the SCCs in this Category will
NOT be saved." If you click cancel, you will stay on the SCC detail page
Figure 5-4: Example Nonpoint survey SCC detail page
Agency Organization Detail
Current agency
Agency Description: North Carolina Department of Environment and Natural Resources
Agency Type: State
ETL Process Group; 2
Survey Status: 0 Survey In Progress
Agency Responsibilities Agency Members Program System Codes Allow Access FeedDac* Reports Nonpoint Survey
EPA Tool Estimate Category 1
Should EPA Supplement your agency data?
If the answer for an SCC is not "Yes". Drag ft to the appropriate answer box on
right
YES-SUPPLEMENT MY
DATA WITH EPA ESTIMATES
Click Comment icon
SCC 1/Short name
SCC 2/Short name
SCC 3/Short name
SCC 41 Short name
SCC 5/Short name
SCC 6/Short name
SCC 7/Short name
SCC 8/Short name
SCC 9/Short name
SCC 10/Short name
NO - DO NOT SUPPLEMENT MY DATA
to open dialog box.
IS
SCC 1 /Short name
SCC 2 /Short name
1 see 8
SCC Short
Name
Should EPA Supplement your
agency data ? 4
SCC 1
Short Name 1
No -1 do not have this type of so ~ Saw
SUPPLEMENT REPORTED LOCATION - SCCs
Pressing "X" will move,
the SCC back to "Yes"
answer box
£
SCC 3 /Short name
Select a "NO" answer from
the dropdown in dialog
SCC 4 /Short name
Reset button will "undo" all
changes to SCCs. All SCCs will
move back to "Yea" box.
Reset
Save
Submtt
Cancel
6 Mobile sources
6.1 Overview
Mobile sources are sources of pollution caused by vehicles transporting goods or people (e.g., highway vehicles,
aircraft, rail, and marine vessels) and other nonroad engines and equipment, such as lawn and garden
equipment, construction equipment, engines used in recreational activities, and portable industrial, commercial,
and agricultural engines
The EPA creates a comprehensive set of mobile source emissions data for criteria, hazardous air pollutants, and
greenhouse gasses for all states, Puerto Rico, and U.S. Virgin Islands as a starting point of the NEI. The EPA uses
models to estimate emissions for most of the mobile source categories. With the exception of California, the
EPA requires SLT agencies to submit MOVES model inputs where applicable, rather than emissions, so that the
EPA can use those inputs if MOVES is updated and for consistent future year mobile source projections.
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6.2 AERR requirements
For onroad and nonroad, state and local agencies are required to submit MOVES model county data bases (CDB)
inputs. They may choose to submit emissions in addition. The exceptions are tribes and California, who may
submit emissions only.
6.3 Mobile source best practices
The EPA encourages the following best practices when submitting onroad/nonroad mobile data:
• Look for and follow posted directions on how to submit mobile inputs. Inputs are required for all sources
in MOVES: all onroad vehicles and nonroad equipment.
• Submit both the required input data, and any supplemental documentation, to help support and explain
your input information. The EPA will provide instructions regarding how to provide any supplemental
documentation prior to the June 2018 opening of the EIS submission window.
6.4 Onroad process changes for 2017
The EPA will continue to use MOVES for the 2017 NEI for both onroad and nonroad emissions, the exact version
will be determined prior to the submittal window opening in June 2018.
Collection of inputs, rather than emissions, is required to provide EPA the ability to run varying model scenarios
and future projections from the same input basis. Model input data collection will be like the process used for
the 2014 NEI. The EPA is interested in comments on the current MOVES input process in planning improvements
for the 2017 NEI cycle.
6.5 Nonroad process changes.
For the 2017 inventory cycle and beyond, only MOVES input format (CDB) will be accepted. Although the input
collection will be unchanged, EPA is evaluating a simplification/aggregation of nonroad SCCs stored in EIS. This
change will make the nonroad sector have fewer records and be more easily queried. Detailed SCC estimates
will be available via modeling files.
6.6 Commercial marine vessels changes
As with the 2014 NEI, the EPA will post shape-fraction files to aid agencies that have CMV emissions at the
county-level and wish to allocate them to shapes based on EPA's values. If SLTs have more detail than EPA's
shapes, they may contact us to update the shape files to include new ones. EPA will be developing bottom up
CMV emissions for 2017 and SLTs may choose to accept those in lieu of submissions.
6.7 Rails changes
For the 2017 inventory cycle, we will return to county-based processes for in-line rail emissions, dropping the
use of shape IDs. Rail yards will still be at the facility-level. EPA will be using rail estimates developed via the
Eastern Research Technical Advisory Committee (ERTAC) for 2017. SLTs may choose to accept this data in lieu of
submitting.
6.8 Aircraft changes
For the 2017 inventory cycle, we are using the same methodology as used for the 2014 NEI. We will collect
landing and take-off inputs, which SLTs will be asked to review/update. Then EPA will run the Federal Aviation
Administration's model to estimate emissions. For 2017NEI, we will use the newer Aviation Environmental
Design Tool (AEDT) for EPA estimates.
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:s
7.1 Overview
As proposed, the revised AERR does not require SLT agencies to report emissions from wildfire or prescribed
burning (wildland fires) sources. These sources are reported as events to EIS. Thus, for the purposes of this plan,
the approaches described here assume use of the event format and voluntary participation from SLT agencies to
help EPA to create the most accurate inventory of these sources. We actually encourage states to submit inputs
and not emissions for Events.
Air agency EVENT (day-specific emissions from wildfire and prescribed burning sources) data is an important
source of data in the NEI, as many pollutants such as PM, VOCs and numerous HAPs are emitted in significant
amounts by the large fires. For EVENTS, the EPA provides a default dataset that covers the entire U.S (including
AK, HI, PR, and the Virgin Islands). States should carefully check these emissions and strongly consider accepting
them before making a decision to submit emissions on their own. The EPA prefers to use consistent methods
and pollutants where possible, so working with EPA to have the best estimates possible and then accepting
EPA's estimates are an ideal approach. After review of EPA's final EVENT emissions (after provision of activity
data), if an Agency deems it absolutely necessary to submit emissions, then care must be exercised to keep the
pollutant coverage the same as what EPA estimates using its methods. More details on the inventory
development for wildland fires is provided here.
1. Reassembly of the Fires Workgroup
We will hold calls on a periodic basis to understand EPA methods, get work group comments and
suggestions, and incorporate comments to the best of our ability into our estimation process. We will also
include agricultural fires (which is currently in nonpoint and is discussed in the NOMAD WG) in these
discussions. We may build of the WG that has been set up to handle fire emissions for 2016 modeling
platform use.
2. Solicitation of 2017 Activity Data
EPA will send a request by email to all SLTs to collect activity data for wildland fires. These activity data
include, but are not limited to inputs such as: acres burned, fuel moisture, fuel consumption and type of
fires. EPA will provide an Excel-based template for SLTs to populate and return to EPA.
3. Memo to SLTs on EVENTS process for 2017
EPA will send a memo briefly explaining EPA methods and why EPA would prefer SLTs and others to only
submit activity data for wildland fires, and not emissions. In addition, if an SLT will submit emissions, we will
explain what needs to be submitted (including CAPs, HAPs, and GHGs) including parameters needed for
emissions modeling such as the heat released by each fire and its unit of measure and how one can estimate
that value.
4. Questionnaire to SLTs
Concurrent with the memo to SLTs on EVENTS process, a questionnaire will be sent to SLTs to help EPA
assess how complete their activity data is. This will help EPA appropriate use other datasets in conjunction
with what the SLTs submit.
5. EPA Communication back to SLTs
EPA will provide feedback to SLTs that submitted activity data as to the quality of the submitted activity data
and if/how those data can use in emissions processing. EPA will further use questionnaire results to ensure
SLTs are agreeable to bringing in new activity datasets that are available as default for their domains.
6. Create SMARTFIRE2-based draft emission estimates and SLT review
Activity data agreed upon to for use by SLTs for their areas will be used with or without other activity
datasets to estimate emissions via the SMARTFIRE2 (Satellite Mapping Automated Reanalvsis Tool for Fire
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Incident Reconciliation) (SF2) approach that has been used for previous inventories. For those SLTs that did
not submit activity data, default activity data will be used. Draft methodology will also be provided and
request SLTs provide comments for corrections, including revised activity data they may possess. For the
initial draft 2017 WLF emissions for events, EPA may run the SF2 model without any state-submitted activity
information (even if we receive it prior to that run). Once these draft estimates are posted, EPA will use the
resulting comments and any activity data provided to EPA by SLTs to rerun the SF2 model. The reason for
this is due to the uncertain nature of resource allocation for developing WLF emissions estimates in the
2017 NEI.
7. Rerun SMARTFIRE2 with revisions
A regeneration of emissions based on suggested revisions from the review process as well as inclusion of SLT
submitted activity data will be performed as resources allow. Accompanying documentation outlining
differences between the draft estimates and this rerun will be provided. SLTs that do not comment should
see no changes in emissions.
8. Finalizing Wildland fires inventory
SLTs will be able to review the SMARTFIRE2 rerun emissions and minor comments or edits will be addressed
and reflected in the Final NEI. Any SLTs that do approve of the EPA estimates need to have submitted their
emissions prior to the extended-AERR deadline -though we strongly discourage this for wildland fires. For
those SLTs that submit emissions, EPA will provide HAP and PM2.5 composition emission factors for SLTs to
use. Also, if SLTs submit emissions, they must also have submitted other parameters required for emissions
modeling, such as hear released by each fire (which can be estimated from CONSUME). All required
parameters will have been provided by EPA prior to the AERR submittal deadline.
7.2 Event process changes
For the 2017 NEI process, we expect the following items to be new/changed from the 2014 NEI process:
• Similar to the 2014 NEI, we continue to strongly-encourage SLTs to submit activity data and NOT
emissions for this data category. While we do encourage all SLTs to submit only activity data, a couple
of states do continue to submit emissions for this category.
• In the 2017 NEI, more parameters will be required if SLTs submit data (emissions) to this category,
including heat content ("Heat Release" and "Heat Release UOM"—see step 3 in the previous section for
further details) for each fire as well as other parameters needed for emissions modeling of these fires;
without heat release and heat release unit of measure, it is not possible to compute plume rise for fires.
It's also possible that we update PAH and EC and OC EFs for these fires in the 2017 NEI.
• Those Agencies that decide to submit emissions data must submit smoldering and flaming emissions
where the sum represents what has been required in the past (see Section 3.4). The smoldering and
flaming components individually are important for many activities including use of data for climate
assessments, because the PM2.5 chemical composition is different for the smoldering vs. the flaming
component. Note that if an SLT does submit emissions, they will be prohibited from submitting a total,
they will only be able to submit smoldering and flaming emissions. If SLTs only have total emissions and
they need to re-apportion to the flaming and smoldering components, then they can use EPA estimates
to develop those needed ratios or consult with EPA about the best way to solve the problem.
• We will review the possibility of including lead (Pb) as a pollutant from these large fires in the 2017 NEI.
If we adopt an EPA method for Pb in the 2017 NEI, agencies that decide to submit actual emissions data
should also plan on submitting Pb emissions. An emissions factor and procedure for estimating Pb
emissions from PM2.5 fractions will be provided by the EPA as needed.
• SLTs that submit emissions must also submit HAPs, GHGs, and PM species as reported in EPA data for
EVENTS. EPA will provide the requisite EFs.
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• Agencies should make it clear to the EPA that the activity data they are submitting is a complete set for
both prescribed and wild fires. In that way, the EPA will ensure no other default data is brought into the
process of estimating emissions for the SLTs in question if such a note is included as part of the activity
data submission. EPA will add more details on this to the plan at a later time, but it's expected we will do
it via a survey administered by USFS that was sent to all SLTs that submitted activity data for the draft
wildland fires inventory for the 2014 NEI.
• As discussed earlier in this plan, we likely will introduce a new SCC for pile burns in the 2017 NEI for
EVENTS (for prescribed fires). If we do that, SLTs that submit emissions must submit to that SCC to fires
they consider to be pile burns. It's expected the list of pollutants will be the same for piles as for wild
and prescribed fires. Please note that EPA methods will not cover pile burn emissions, it's be entirely
populated by SLT emissions for those few states that have such burns occurring in their domain.
• We encourage agencies to send in activity data as soon as possible after EPA's "request for 2017 WLF
activity data" note goes out. Due to resource constraints this year and the fact that EPA's draft estimates
will be based on only national default activity data, EPA will likely provide more time for SLTs to submit
activity data. We strongly encourage all agencies to review and comment on the draft EVENTS NEI that
we expect to post in the summer of 2018. This includes submitting additional activity data, commenting
on the draft emission estimates, and other items that will facilitate getting us to a final WLF inventory.
• We will add an SCC for Prescribed fires that are pile burns. EPA will not provide estimates for this SCC;
rather, any state that has that activity on their lands will report actual emissions. Pollutant coverage and
requirements for submission must comply with Event-based requirements.
7.3 Event source best practices
• Submit activity data so that the EPA does not have to use default data to identify and estimate emissions
from fires occurring in your domain. Important parameters include acres burned, fire perimeters, fuel
loading, and fuel consumption; however, acres burned is the most important activity data to submit. The
EPA relies on the default methods from satellite detections without more specific data. The importance
of submitting activity data is especially true for prescribed fires, because the EPA methods have a more
difficult problem in identifying which fires are prescribed fires for appropriately estimating the
emissions. At this time, we expect that activity data for the 2017 NEI fires will simply be submitted via
email to Tesh Rao, and the EPA will provide directions if those plans change.
• Review draft NEI for EVENTS soon after it is available. Ensure that submitted activity data were used
appropriately. Provide comments in the comment time period specified by the EPA.
• If an Agency decides to submit actual emissions (EPA discourages this process for EVENTS), provide
documentation on the methods as much as possible either via comment fields in EIS or via an email to
Tesh Rao. Also, if an Agency submits emissions, ensure that the pollutant coverage is the same as what
the EPA estimates using its methods. If Emission Factors are needed, please contact the EPA. If you do
decide to submit emissions,
o Submit data to the EIS QA Environment prior to submitting data to the Production Environment.
Make sure your feedback reports are clean prior to submitting to the Production Environment,
o Use the new (expected) comparison report as an additional QA step (see Section 8.3).
• Please plan on reviewing the draft estimates that will be provided by EPA and submitting appropriate
comments. In addition, please work with EPA to submit and review your activity data as EPA processes
them into emissions.
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nv -u>wayf Reports, and Tools
8.1 Staging Tables
To assist in resolving Bridge Tool errors, we built queries into the staging tables that identify widows and
orphans, which can prevent your data from converting to the required XML format. We updated the Bridge Tool
in October of 2017 to provide error messages to be more informative.
For users of Windsor Solutions' inventory management product "SLEIS", the Bridge Tool has been adapted to
convert the XML export files from SLEIS into the staging tables without prior manual manipulation. Past versions
of the Bridge Tool could not convert the XML to the staging table format.
8.2 Submissions - EIS Multi-thread Approach
To prevent a backlog of submissions during peak periods, the EPA plans to create a "multi-thread" approach to
the submission process within the EIS. This multithread approach will establish two submission threads, with
each thread being a separate data processing pathway. With the new approach, the EIS will automatically move
files larger than a pre-assigned file size limit to another thread, allowing smaller files to be processed
simultaneously. Currently, larger files must be completely processed before the smaller files will be processed.
This change will be in the EIS software, so the only differences users will notice is faster response times.
8.3 Reports
All reports, except Snapshots and the Smoke Flat Files, now have the ability to be customized though the
"Column" filter.
A new report is now available in EIS. The new report is a comparison report that will allow you to compare any
number of datasets against a single, user-specific base dataset. This could be used, for example, to compare
point emissions in the NEI 2014 v2 against your agency submitted data for 2017. An additional example would
be to compare your submitted data against TRI data so that you can see what facilities have reported to TRI and
what is being reported by your agency. The comparison reports will provide an absolute difference, percent
difference and ratio between the baseline data value and the comparison value for each dataset being
compared. We encourage SLT air agencies to take advantage of this report after having made your submission as
an additional QAtool.
In addition, another report will be available for assessing whether your submissions have met the 2017 NEI
completeness criteria. The use of this completeness report is described in Section 3.5.
9 Conclusion and Points of Contact
The EPA has created this plan to assist SLT agencies with their own planning needs for the 2017 NEI cycle. Please
direct comments on this plan to Rich Mason. The EPA recognizes that SLT air agency staff will have many
questions, ideas, and improvements that we have not addressed here, and your comments will help us improve
this plan and the 2017 NEI process. Points of contact for various NEI data source categories and functions are
provided on the Air Emissions Inventories Points of Contact website.
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