Appendix B 

Documentation of Missouri’s 

2011 National Emissions Inventory Data 

Missouri Department of Natural Resources 

Division of Environmental Quality 

Air Pollution Control Program 

Jefferson City, Missouri 

Public Hearing 

May 29, 2014 
i 

Table of Contents 

1.0 Introduction......................................................................................................................................1

2.0 Pollutants..........................................................................................................................................1

3.0 Geographic Coverage ....................................................................................................................... 2

4.0 Temporal Coverage .......................................................................................................................... 2

5.0 Staff Resources.................................................................................................................................3

6.0 Data Collection and Handling .......................................................................................................... 4

6.1. Point Sources.................................................................................................................................4

6.2 Nonpoint Sources.......................................................................................................................... 7

6.3 Onroad Mobile .............................................................................................................................. 7

6.4 Nonroad Mobile ............................................................................................................................ 8

7.0 Point Source Inventory..................................................................................................................... 9

7.1 Quality Assurance Prioritization.................................................................................................... 9

7.2 Quality Assurance Methods.......................................................................................................... 9

7.3 Data Checks Used........................................................................................................................ 12

7.4 Quality Assurance of Hazardous Air Pollutant emissions ........................................................... 18

8.0 Nonpoint Source Inventory............................................................................................................ 54

8.1 Agricultural Pesticide .................................................................................................................. 54

8.2 Agricultural Tilling....................................................................................................................... 55

8.3 Agriculture Fertilizer Application ................................................................................................ 62

8.4 Industrial and Commercial/Institutional (ICI) and Residential Fuel Combustion ........................65

8.5 Agriculture Livestock Waste........................................................................................................ 66

8.6 Aviation Gasoline Distribution:  Stage I ...................................................................................... 76

8.7 Aviation Gasoline Distribution:  Stage II ..................................................................................... 84

8.8 Commercial Cooking ................................................................................................................... 90

8.9 Fugitive Dust:  Construction Activities Roads............................................................................ 100

8.10 Fugitive Dust:  Construction Activities Non‐residential............................................................. 105

8.11 Fugitive Dust:  Construction Activities Residential.................................................................... 109

8.12 Fugitive Dust:  Mining and Quarrying....................................................................................... 115

8.13 Fugitive Dust:  Mining and Quarrying Lead Ore........................................................................ 124
ii 

8.14 Fugitive Dust Paved Roads........................................................................................................ 128

8.15 Fugitive Dust:  Unpaved Roads ................................................................................................. 137

8.16 Asphalt Plants ........................................................................................................................... 138

8.17 Gas Stations:  Stage II ............................................................................................................... 146

8.18 Gasoline Distribution:  Stage I................................................................................................... 147

8.19 Open Burning:  Household Waste and Municipal Solid Waste .................................................171

8.20 Open Burning:  Land Clearing Debris ........................................................................................ 178

8.21 Open Burning: Yard Waste........................................................................................................ 184

8.22 Portable Fuel Containers, Residential and Commercial ............................................................ 191

8.23 Residential wood combustion ................................................................................................... 201

8.24 Solvent:  Architectural Coatings................................................................................................ 211

8.25 Solvent:  Auto Refinishing/Auto Aftermarket ........................................................................... 211

8.26 Solvent:  Consumer and Commercial Household Products ....................................................... 211

8.27 Solvent:  Consumer and Commercial Personal Care, Cosmetic, and Toiletries.........................211

8.28 Solvent:  Consumer and Commercial Miscellaneous Products..................................................211

8.29 Solvent:  Consumer and Commercial Adhesives and Sealants..................................................211

8.30 Solvent:  Consumer and Commercial Auto Aftermarket........................................................... 211

8.31 Solvent:  Consumer and Commercial Coatings and Related Products......................................212

8.32 Solvent:  Consumer and Commercial FIFRA Regulated Products..............................................212

8.33 Solvent:  Degreasing ................................................................................................................. 212

8.34 Solvent:  Dry Cleaning ............................................................................................................... 212

8.35 Solvent:  Graphic Arts................................................................................................................ 212

8.36 Solvent:  Industrial Maintenance Coatings............................................................................... 212

8.37 Solvent:  Other Special Purpose Coatings ................................................................................. 212

8.38 Surface Coating:  Aircraft.......................................................................................................... 213

8.39 Surface Coating:  Electronic and other Electric Coatings.......................................................... 213

8.40 Surface Coating:  Factory Finished Wood ................................................................................. 213

8.41 Surface Coating:  Large Appliances........................................................................................... 214

8.42 Surface Coating:  Machinery and Equipment............................................................................ 215

8.43 Surface Coating:  Marine .......................................................................................................... 216

8.44 Surface Coating – Metal Can Coating ....................................................................................... 218

8.45 Surface Coating:  Metal Furniture............................................................................................. 223
iii 

8.46 Surface Coating:  Miscellaneous Manufacturing ...................................................................... 224

8.47 Surface Coating:  Motor Vehicle ............................................................................................... 227

8.48 Surface Coating:  Paper, foil, and film....................................................................................... 228

8.49 Surface Coating:  Railroad......................................................................................................... 232

8.50 Surface Coating:  Traffic Markings............................................................................................ 234

8.51 Surface Coating:  Wood Furniture............................................................................................. 234

8.52 Landfills.....................................................................................................................................235

8.53 Publically Owned Treatment Works.......................................................................................... 238

8.54 Cremation:  Human and Animal................................................................................................ 243

8.55 Asphalt Paving:  Cutback........................................................................................................... 253

8.56 Asphalt Paving: Emulsified........................................................................................................ 257

8.57 Miscellaneous Mercury:  Lamp Breakage, Health, Dental........................................................ 261

8.58 Oil and Gas Production.............................................................................................................. 262

9.0 Mobile Source Inventory.............................................................................................................. 288

9.1 Onroad Inventory ...................................................................................................................... 288

9.2 Nonroad Inventory .................................................................................................................... 293

9.2.1 Nonroad Model ........................................................................................................................ 293

9.2.2 Commercial Marine.................................................................................................................. 294

9.2.3 Aircraft .....................................................................................................................................294

9.2.4 Locomotive............................................................................................................................... 294

10.0 Biogenic Inventory ....................................................................................................................... 296

11.0 Event Inventory ............................................................................................................................ 298

12.0 EIS Data Submission ..................................................................................................................... 299

   
iv 

List of Sub‐Appendices

Appendix B‐1 – EIQ Forms

Appendix B‐2 – CenSARA Agricultural Pesticide Tool

Appendix B‐3 – CenSARA Fuel Combustion Tool

Appendix B‐4 – 2011 Oil and Gas Inventory Enhancement Project for CenSARA States

Appendix B‐5 – 2011 Aircraft LTO Data Processing for the National Emission Inventory

Appendix B‐6 ‐ Development of 2011 Railroad Component for National Emissions Inventory

Appendix B‐7 – Technical Memorandum:  Preparation of Wildland Fire Emissions Inventory for 2011
1 

1.0 Introduction

The Missouri Department of Natural Resources’ Air Pollution Control Program developed a

comprehensive statewide emissions inventory for 2011, as required by the EPA’s Air Emissions

Reporting Requirements (AERR) rule published December 17, 2008. The inventory includes point,

nonpoint, onroad mobile, and nonroad mobile source emissions. This document describes how the 2011

inventory is compiled and submitted to the National Emissions Inventory (NEI) through the EPA’s

Emission Inventory System (EIS).  This report documents the 2011 inventory in detail, from its creation,

quality assurance, and final summaries.  It also details the qualifications and limitations of the inventory.   

Various tables are included showing summarized, facility‐specific, and source category‐specific data.  All

emission amounts are given in tons per year unless otherwise noted.  Blank fields and those with dashes

indicate a value of zero.  Fields with 0, 0.0, or 0.00 contain small values that round to zero.   

2.0 Pollutants

The 2011 inventory includes emissions of the traditional criteria air pollutants (CAPs) sulfur oxides (SOx),

nitrogen oxides (NOx), carbon monoxide (CO), volatile organic compounds (VOC), coarse particulate

matter (PM10 Primary), fine particulate matter (PM2.5 Primary), ammonia (NH3), and lead (Pb).  Missouri

also inventories speciated Hazardous Air Pollutant (HAP) emissions for certain data categories.  For

some data categories, particulate matter (PM) is further disaggregated to its component parts: PM10

Primary is the sum of PM condensable (PM CON) and PM10 Filterable (PM10 FIL), and PM2.5 Primary is the

sum of PM condensable (PM CON) and PM2.5 Filterable (PM2.5 FIL).  Missouri’s inventory does not include

greenhouse gas (GHG) emissions and none of the tables in this document will summarize GHGs. Only the

nonpoint fuel combustion category contains GHG emission estimates where those pollutants were

already part of the tool provided by a third‐party contractor.

Table 1: Statewide 2011 Emissions 

   Lead NH3 CO NOX PM10‐PRI

PM2.5‐

PRI SO2 VOC

Point

Total 42.20 1,642 113,272 92,721 16,727 9,834 255,217 14,503

Nonpoint

Total 1.63 115,151 124,464 14,403 831,546 124,664 995 105,932

Onroad

Total 2,588 599,054 180,579 1,208 61,785 8,416 6,760

Nonroad

Total 3.27 5,382 362,916 79,213 9,734 7,971 1,631 48,250

Biogenic

Total     138,954 28,311 1,168,254

Missouri

Total

   

47.10  

   

124,764  

  

1,338,659

  

395,228

  

859,215

  

204,254  

   

266,258  

  

1,343,699
2 

3.0 Geographic Coverage

The 2011 emissions inventory covers the entire state of Missouri. Point source emissions are prepared

at the facility level with a geographic coordinate. Nonpoint, onroad, nonroad mobile, and biogenic

emissions are submitted at the county level. There are no tribal areas in Missouri, and all 115 counties

and municipalities are included.

4.0 Temporal Coverage

Annual emissions are developed for point, nonpoint, onroad mobile and nonroad mobile sources. The

emissions cover a continuous 12 month period from January 1 to December 31 of the reporting year.  

Ozone season day emissions are submitted only for point sources in the 5‐county St. Louis Ozone

Nonattainment area (Franklin, Jefferson, St. Charles, and St. Louis Counties and the City of St. Louis).

These emission estimates detail the amount of emissions on a typical summer day during the peak

ozone season from June 1 through August 31. Only the ozone precursor pollutants of NOx, VOC and CO

are reported at this temporal scale.
3 

5.0 Staff Resources

The department’s Air Pollution Control Program (APCP) Air Quality Analysis (AQA) Section, Data

Management Unit, prepared the 2011 emissions inventory with assistance from other APCP units. Local

agencies in the Kansas City, St. Louis County, St. Louis City, and Springfield areas did not participate in

inventory collection or quality assurance, but they do assist with identification of point source facilities.  

The individuals making up the 2011 NEI preparation team and their responsibilities are listed below:

• Stacy Allen, Data Management Unit Chief:  Oversight of point, and nonpoint source development,

quality assurance, and data submission  

• Jeanne Brown, Data Management Unit:  Point source data entry, quality assurance, and data

submission

• Josh Martin, Data Management Unit:  Point source quality assurance; HAP quality assurance

• Nathan O’Neil, Data Management Unit:  Point source quality assurance; nonpoint source

development and data submission; mobile source development and data submission

• Mary Powell, Data Management Unit:  Point source data entry and quality assurance

• Terry Stock, Data Management Unit:  Point source quality assurance and nonpoint source

development

• Brenda Wansing, Data Management Unit:  Point source data entry, quality assurance, and data

submission

• Dan Williams, Data Management Unit:  Point source quality assurance and nonpoint source

development

• Aaron Basham, Rules Unit:  Nonpoint source quality assurance

• Mark Leath, SIP Unit:  Nonpoint source quality assurance

• Paul Myers, Rules Unit:  Nonpoint source quality assurance

• Stan Payne, Rules Unit:  Nonpoint source quality assurance

• Shelly Reimer, Rules Unit:  Nonpoint source quality assurance

• Seanmichael Stanley, Rules Unit Planning Section:  Nonpoint source quality assurance
4 

6.0 Data Collection and Handling

6.1. Point Sources

Point source data is collected from permitted facilities in the form of a report called the Emissions

Inventory Questionnaire (EIQ). The EIQ is a report detailing facility operational data and estimating the

amount of air pollution emitted, and its collection is governed by Missouri Statute 10 CSR 10‐6.110.  The

facility will either submit a detailed annual “full” report, with updated calendar year operations and

emissions, or a “reduced” report, which represents that their last full report emissions are a reasonable

estimate for the current year, within emission change and permit tolerances. These reports are certified

by the facility, but are subject to review and revision based on quality assurance performed by the state,

or notification by the facility of errors in the original submission.  The point data presented in this report

reflects all updates made to emission reports through February 1, 2014.

The AERR definition of Type A and B point source facilities depends on the pollutant‐specific PTE and

location within a designated nonattainment area. Since Missouri does not maintain records of facility

total potential to emit, the permit type is used to determine Type A and Type B status.  Missouri has one

area designated as both a moderate ozone nonattainment area and moderate PM nonattainment area,

so the Type B thresholds for SOx, VOC, NOx, CO, Pb, PM10 and NH3 are compared to permit thresholds.  

Per Missouri operating permit rule 10 CSR 10‐6.065, Part 70 sources and Intermediate sources have

uncontrolled PTE of at least one pollutant in excess of the AERR Type B thresholds.  All Missouri sources

with Part 70 or Intermediate operating permits are submitted as Type B sources, and they are required

to complete the “full” emissions report, detailing their actual operations and emissions during the 2011

year. Emission units permitted at the facility via their construction or operating permit are included in

the report, including both stack and fugitive emission releases.

A fully detailed emission report contains several elements, most of which originated and continue to

exist on paper EIQ forms.  The following list provides brief description of the forms available for use in

completing an EIQ, and the forms themselves appear in Appendix B‐1.  In general, forms beginning with

number one (1) provide general facility information, and forms beginning with a two (2) provide detailed

annual emission calculations.  More information on EIQ forms is available at

http://www.dnr.mo.gov/env/apcp/moeis/emissionsreporting.htm

Form Name Form Description Form

Number

Form 1.0 General Plant

Information

General plant information, plant‐wide emissions totals,

signature section certifying submitted information is

accurate and complete.

780‐1431
5 

Form Name Form Description Form

Number

Form 1.1 Process Flow

Diagram

Diagram identifying and linking all emission units, processes,

air pollution control devices, and emission release points for

a facility.

780‐1619

Form 1.2 Summary of

Emission Units and Related

Processes

List of all emission units, associated processes, and unit

operating status.

780‐1620

Form 2.0 Emission Unit

Information

Main emissions reporting form; separate Form 2.0 required

for each significant process for which emissions are being

reported.

780‐1621

Form 2.0C Control Device

Information

Control device information when there is a control device

operative at an emission unit; separate Form 2.0C required

for each control device.

780‐1434

Form 2.0K Charcoal Kiln

Information

Details the operations and characteristics of charcoal kilns. 780‐1530

Form 2.0L Landfill

Information

Form for reporting emissions from landfills. 780‐1583

Form 2.0P Portable

Equipment Information

Details the locations and operations for portable equipment

operations including quarries, asphalt plants, and concrete

batch plants.

780‐1433

Form 2.0S Stack/Vent

Information

Stack information for emission units where emissions from a

process enter the ambient air through one or more

stacks/vents.

780‐1435

Form 2.0Z Ozone Season

Information Form

Calculation of ozone season day emissions of VOC, NOx, or

CO; required from facilities located in the St. Louis ozone

nonattainment counties of St. Louis, St. Charles, Franklin

and Jefferson Counties and St. Louis City.

780‐1452

Form 2.1 Fuel Combustion

Worksheet

Combustion equipment itemization including equipment

design rate and fuel type.

780‐1436

Form 2.2 Incinerator

Worksheet

Information related to the incinerator, waste material(s)

incinerated, and the annual waste material throughput.

780‐1438

Form 2.3 VOC Process Mass‐

Balance Worksheet

Calculates a VOC mass balance emission factor from one or

more VOC‐containing materials.

780‐1440
6 

Form Name Form Description Form

Number

Form 2.4 Volatile Organic

Liquid Loading Worksheet

Calculates an emission factor for petroleum liquid loading

into tank trucks, rail cars, and barges based on AP‐42.

780‐1625

Form 2.5L General Liquid

Storage Tank Information

Information about storage tanks. 780‐1444

Form 2.7 Haul Road Fugitive

Emissions Worksheet

Calculates an emission factor for unpaved haul roads based

on AP‐42 formula.

780‐1445

Form 2.8 Storage Pile

Worksheet

Calculates emission factors for activity and wind erosion

from storage piles based on AP‐42 formulas.

780‐1446

Form 2.9 Stack

Test/Continuous Emission

Monitoring Worksheet

Documentation for emission factors derived from stack tests

or CEM devices.

780‐1447

Form 2.T Hazardous Air

Pollutant Worksheet

Speciates HAP chemicals emitted at the process level;

separates individual HAPs from those included in VOC/PM

emissions.

780‐1448

Form 3.0 Emission Fee

Calculation

Summary table showing emissions from all processes. 780‐1509

Form 3.0CK Emission Fee

Calculation for Charcoal Kilns

Summary table showing emissions from charcoal kiln

operations.

780‐1508

Dry Cleaner – Non‐

chlorinated and Petroleum

Based Solvents

Emissions calculations for dry cleaners using non‐

chlorinated solvent and with combined dryer capacity of 84

pounds or more.

780‐1954

Form 4.0 Financial Cost

Estimate

Estimate the cost of complying with air pollution regulation. 780‐1622

Though paper forms were the origination of emission reporting, Missouri now has an online emission

reporting system called the Missouri Emission Inventory System, or MoEIS.  The data elements on the

hardcopy forms have an electronic counterpart in MoEIS, though several data elements which were

calculated by the user and written on the form are now automatically populated by MoEIS.  For the full

emission reports submitted by an AERR Type A or B facility, the report can be submitted either on paper

forms or via MoEIS.  Both submittals require a signature page to certify that representative emissions

have been reported, to the best knowledge of the facility representative.   

All data elements for full emission reports are stored in the underlying MoEIS database.  For reports that

are submitted on paper forms, the data is entered to the MoEIS database by the APCP staff members
7 

within a few weeks of receipt.  Both the number and type of reports submitted annually are monitored

to ensure proper coverage of AERR‐reportable point source facilities. Paper forms were due by April 1,

2012, and MoEIS submissions were due by May 1, 2012.  Late reports from AERR point source facilities

were collected through reminders, enforcement actions, or site visits.   

EIQ solicitations for calendar year 2011 were mailed to facilities in January 2012.  A total of 2,237 EIQs

were mailed statewide, of which 676 were full EIQs and 1,561 were reduced reporting forms.  Of those

676 full reports, 505 facility reports are for AERR Type A or B facilities, and are included as point sources

in Missouri’s submittal to the NEI.   

6.2 Nonpoint Sources

Nonpoint emission estimates come from a variety of input data sources, including but not limited to:

 US Census population, employment, and industrial datasets

 US Census of Agriculture activity data

 Satellite derived fire burn areas

 Energy Information Administration (EIA) annual fuel usage statistics

 EPA’s Emission Inventory Improvement Program (EIIP)

 Missouri air‐permitted sources  

The activity data, emission factors, and control assumptions for each specific data category are outlined

in Section 8.  Many of the nonpoint emission categories are developed by EPA using nationally available

datasets to ensure complete and consistent estimates.  Those estimates are reviewed by states for

accuracy of appropriateness of calculation methods, verification of input data, state‐specific data input,

and full geographic, temporal, and pollutant coverage.  While most data is handled in Microsoft Excel or

Access databases, some categories require the use of proprietary tools such as the SMARTFIRE program

or Fredonia market research for solvent usage statistics. All data and documentation provided by EPA is

stored electronically by Missouri.  For nonpoint data categories where Missouri provides no state‐

specific data updates or corrections, EPA is notified that their estimate is accepted by Missouri.   

6.3 Onroad Mobile

Onroad mobile data inputs include vehicle mile travelled estimates from travel planning organizations at

the state and regional level.  Vehicle registration data from the Missouri Department of Revenue include

Vehicle Identification Numbers (VINs) that are decoded by a third‐party vendor to determine the

number, age, and engine types of vehicles on Missouri roads.  Data from the Gateway Vehicle Inspection

program is used to verify the number of inspection waivers given, retesting rate, and the pass/fail rate of

inspections to ensure the amount of pollutant reduction attributed to vehicle maintenance is accounted

for.  All these datasets are formatted for use in EPA’s approved mobile source model, the Motor Vehicle

Emission Simulator (MOVES). The datasets are collected in electronic formats, manipulated
8 

electronically, and stored in MOVES table structures that allow for appropriate model runs and data

submittal to EPA.

6.4 Nonroad Mobile

EPA’s NONROAD model, version 2008, is used to estimate emissions from engines that are not operated

on roadways.  Missouri does not collect state‐specific engine or vehicle population or activity data for

this category of model inputs.  EPA’s default NONROAD emissions are accepted by Missouri after a

review of their results.    

Nonroad emissions from aircraft, railroads, and commercial marine vehicles are not included in the

NONROAD model.   

 Aircraft emission data is estimated by EPA based on Federal Aviation Administration (FAA)

airport‐specific activity data that is input to the Emissions Dispersion Modeling System (EDMS)

to provide emission calculations.  EPA provides the input activity data to states for review and

comment electronically, and provides the output emissions for review by states.  Missouri had

no comments on the estimates, and EPA’s estimate for this category was accepted.

 Railroad emission data is estimated by EPA by scaling the 2008 emission estimates to 2011

based on the ratio of 2008 to 2011 freight hauled and revenue for large, Class I railroads, and by

employee hours for smaller railroads.  EPA only provided documentation of how the emissions

were grown, and no review of the underlying electronic datasets was done by Missouri.  EPA’s

estimate was for this category was accepted.

 Commercial marine operations were estimated by EPA using emissions developed in 2002 and

grown to 2011, accounting for industry growth and updated engine standards.  Missouri did not

provide state‐specific estimates, and reviewed EPA’s estimates as they were provided in

spreadsheet form.  Missouri noted the large decrease in emissions due to an updated EPA

procedure to allocate more emissions to underway activities compared to port activities.  

Missouri accepted this new estimation technique and emissions.
9 

7.0 Point Source Inventory

7.1 Quality Assurance Prioritization

The Data Management Unit prioritizes review of facilities that produce the most emissions, specifically

facilities with a Part 70 or Intermediate operating permit.  While every data element collected helps to

characterize the emission estimate, the fields most directly tied to the emissions calculation are given

the highest priority.   

7.2 Quality Assurance Methods

The Data Management Unit’s general quality assurance (QA) procedures utilize many of the techniques

outlined in the EPA’s Emission Inventory Improvement Program (EIIP) Technical Report Series Volume 6:

Quality Assurance Procedures.  The unit groups these techniques into two basic categories:  Bottom‐Up

QA procedures and Top‐Down QA procedures.  Top‐Down Procedures analyze groups of emissions data

that share a common trait and look for outliers, in keeping with the ‘Reality Check’ technique.  Bottom‐

Up procedures evaluate individual EIQs that are believed to be erroneous due to data entry errors or

inconsistencies brought up by a third party.  The Air Quality Analysis unit’s quality assurance efforts are

driven by top‐down techniques, with individual EIQ improvements due to referrals from other air

program staff.  This allows prioritization of potential errors found and maximizes the results achievable

with the available staff resources.  Correction of individual reports is done based on the results of the

top‐down and referral reviews.

Top‐down quality assurance activities begin by determining what information to pull from the MoEIS

database.  The lists below give the Microsoft Access queries written to identify errors, prioritize facilities,

and show totals for the year. The following section describes the results of data checks that resulted in

changes to facility information or emissions.

EIQ Submission (queries named "Sub") EIQ sources covered

Sub01 EIQ submittal no production and insignificant plant‐wide All ‐ full and reduced

Sub02 Stats on number of Reduced doing Full All ‐ full and reduced

Sub03 Identify reduced sites to contact to verify 5 ton trigger Reduced

Sub04 List of permits issued versus reduced doing full All ‐ full and reduced

Sub05 Stats on dates EIQs received   All ‐ full and reduced

Sub06 Comments submitted   All ‐ full and reduced

Sub07 MoEIS usage statistics Full

Sub08 Identify confidential EIQs Full

Sub09 Habitual late EIQs by permit and industry type All ‐ full and reduced

Sub10 Number of late EIQs All ‐ full and reduced

Sub11 Number of EIQs not sending signed 1.0 on time All ‐ full and reduced

Sub12 Pull 82 hardcopy full reports to get consultant name and Full
10 

excel vs PDF

EIQ Data Format for EIS Submittal (queries named "EIS") EIQ sources covered

EIS01 Check MoEIS vs EIS code tables for active codes N/A

EIS02 Submitting new data elements NEI P70 and INT list

EIS03 Add unit type codes for new units NEI P70 and INT list

EIS04 Existing processes to new release point NEI P70 and INT list

EIS05 Fill in TRI‐IDs All ‐ full and reduced

Common Data Errors in MoEIS (queries named "Err") EIQ sources covered

Err01 Check PM10 always greater than PM2.5 NEI P70 and INT list

Err02 

Insignificant units with throughput  greater than

zero Full

Err03 Ash/sulfur content not in the emission factor   NEI P70 and INT list

Err04 Check the MoEIS emission calculation is correct All ‐ full and reduced

Err05 

If reduced doing full, make sure throughputs were

updated Full

Err06 Check that HAP worksheets were updated Full

Err07 

Clean up fuel combustion worksheet heat content

and MHDR outliers All ‐ full and reduced

Err08 

If only PM10 (no PM2.5), list sources with over 10

tons NEI P70 and INT list

Err09 

Check that combustion SCCs are reporting all

combustion CAPs Full

Err10 Missing ozone worksheets need to be added All ‐ full and reduced

HAP Process to 

Worksheet 

HAP amounts that differ between worksheets and

emission calculations NEI P70 and INT list

HAPs Without 

Worksheets HAPs reported with no worksheet NEI P70 and INT list

Financial (queries named "Fin") EIQ sources covered

Fin01 Total Emission fees received All ‐ full and reduced

Fin02 Compare 2010 and 2011 fees received All ‐ full and reduced
11 

Fin03 Compare local agency fees All ‐ full and reduced

Total Statewide Emissions (queries named "Tot") EIQ sources covered

Tot01 Graph P70 emissions by pollutant over last 5 years P70

Tot02 Graph INT emissions by pollutant over last 5 years INT

Tot03 

Graph all other permit types by pollutant over last

five years Basic, Dempal & PORT

Tot04 Graph total Missouri emissions over last 5 years All

Compare to other data sets (queries named "Ext") EIQ sources covered

Ext01 

Retrieve CAMD data and compare to MoEIS

for utilities

Electric Generating

Units (EGUs)

Ext02 

Retrieve EIA data and compare facility layout

and ash/sulf and heat cont EGUs

Ext03 

Retrieve TRI air emissions and compare to

MoEIS Full

Ext04 

Compare HAP contact list from Feb 2012 to

see if problems were corrected Previous list

Ext05 Compare to emission projection spreadsheet   Large Source List

Ext06 

EPA 2008 NEI Priority and pollutant addition

list NEI P70 and INT list

Emission Checks by Industry (queries named "Ind") EIQ sources covered

Ind01 

For common NAICS groups, find outliers in

emissions Full

Ind02 

For common NAICS groups, run emission

trends last 5 years NEI P70 and INT list

Ind03 

For elec utilities, check that PM CON is

reported separately EGUs

Ind04 

Other facilities where PM CON is

speciated/should be NEI P70 and INT list
12 

7.3 Data Checks Used

Submission Checks

These queries provide statistics for the 2011 EIQ submissions, and they do not result in changes in

reported emissions.  

EIS Checks

These checks ensure that Missouri’s emission inventory data can be properly mapped over to EPA’s EIS

data formats.  These checks do not result in changes to reported emissions.

Emission Checks by facility (queries named "Fac") EIQ sources covered

Fac01 

Total facility chargeable emission change

>20% and >5 tons Full

Fac02 

Total facility pollutant change >20% and >5

tons Full

Fac03 

By pollutant and process, emission changes

>20% and >5 tons Full

Fac04 

High priority pollutant and process changes

of >10% and >3 tons NEI P70 and INT list

            

Emission Factor Checks (queries named "Ef") EIQ sources covered

Ef01 

Source of factor AP‐42, compare to webfire

for same SCC NEI P70 and INT list

Ef02 

Stack test or eng calc factor changes 2010 to

2011 NEI P70 and INT list

Ef03 Review stack test letters from APCP Enf staff All ‐ full and reduced

Ef04 EPA revised PM Efs for gas combustion All ‐ full and reduced

Pollutant Checks (queries named "Pol") EIQ sources covered

Pol01 

Review Lead emissions over 0.25 ton in 2011

compared to 2010 All ‐ full and reduced

Pol02 

Identify the largest facilities for NH3, see if

any major sources are missing All ‐ full and reduced

Pol03 

Check for total HAPs reported over the

VOC/PM10 total Fulls
13 

Err01

This data check was performed to identify facilities reporting PM2.5 in excess of PM10 and those reporting

PM10 with no PM2.5.  Since PM2.5 is a component of PM10, emissions of PM2.5 must be less than or equal

to emissions of PM10.  Only one facility reported less PM10 than PM2.5, and the issue was corrected after

a review of the facility’s data.   

Err02

This check identified units marked “insignificant”, but where throughput was reported along with

emissions.  These units were simply changed from “insignificant” to “active” status, with no change in

emissions.

Err03

This check identified the AP‐42 emission factors that are the result of an equation involving either an ash

or sulfur term.  The SCCs associated with these factors were identified. It appears all facilities were

correctly including the ash or sulfur term in the emission factor, and no changes were necessary.

Err04

Manual recalculation of the emission totals for all pollutants and emission processes verified that the

MoEIS‐generated emissions are correct.

Err05

For any facility choosing to do a full EIQ instead of a reduced EIQ, this check verifies that they updated

one or more of their emission unit totals.  No facilities were updated due to this check as they all

updated their data to the current year.

Err06

HAP worksheet data tends to be overlooked during facility submittals, so this check ensures that the

worksheet has been updated from the previous submittal. See Section 7.4 for more details.

Err07

Fuel combustion worksheets were examined to ensure that the heat content of the fuel was correct,

given the unit of measure reported.  Many worksheets were updated to ensure the proper heat content

was reported, which in turn updated the maximum hourly design rate of the equipment.  These changes

did not result in changes to emission totals.

Err08

This data check was done to identify facilities reporting PM10 without reporting any PM2.5.  Nine facilities

reported over ten tons PM10 emissions with no corresponding PM2.5 emissions. These facilities were

contacted, and PM2.5 emissions were added to their updated report.
14 

Err09

This data check ensured that all combustion pollutants were reported for an emission unit.  The data

showed that nine facilities were missing at least one expected combustion pollutant for at least one

unit, and the resulting new pollutants and emissions were saved via revised emission reports.

Err10

Facilities in the five‐county St. Louis Ozone Nonattainment area were identified if they were missing the

Ozone Season Worksheet that estimates emissions of CO, NOx, and VOC on a typical summer day.  

Several facilities had this worksheet added to their report since it is estimated based on data elements

found elsewhere in their report, and this additional worksheet did not change any reported annual

emission totals.

HAP Process to Worksheet

This check determines which facilities have a discrepancy between the amount of HAPs reported as

HAPs on worksheets and the total chargeable HAPs for 2011. See Section 7.4 for more details.

HAPs Without Worksheets

For a facility that reported over 5 tons of total HAPs, emissions were reviewed if they did not itemize

emissions on the HAP worksheet.  See Section 7.4 for more details.

Financial Checks

These checks tabulate emission fees that are based on reported emissions.  These checks do not result

in changes to reported emissions.

Total Checks

The emission total checks create graphical displays of aggregate emission trends, and do not result in

reported emission changes.

Ext01

EPA’s Clean Air Markets Division (CAMD) emissions data for electric generating units was compared to

emissions reported to Missouri.  Since these emissions are measured by continuous emissions monitors

(CEMs) at the facility, and results transmitted directly to EPA, the same emissions should be reported to

Missouri.  Any facility with over a 20% and 5 tons difference in either NOx or SOx emissions was flagged

for review.  The four facilities that showed at least one unit meeting the review threshold reported their

facility total emissions in agreement between the two systems, but the grouping of emission units

differed between CAMD and MoEIS.  No changes were made to emission reports since there was no net

difference in emission totals.

Ext02
15 

The Energy Information Administration (EIA) Form 860 and Form 923 data was compared to emission

reports from electric generating units to ensure consistency between control devices and ash and sulfur

content of fuels.  Due to time constraints, this comparison was not completed.

Ext03

The 2011 Toxics Release Inventory (TRI) dataset for Missouri was compared to EIQ data. See Section 7.4

for more details.

Ext04

Facilities that had problem HAP reporting for 2010 were reviewed to ensure that problems weren’t

repeated in 2011. See Section 7.4 for more details.  

Ext05

Missouri maintains an emission projection spreadsheet that gives estimates for facilities expected to

shut down, add controls, or otherwise reduce emissions, in future years.  The spreadsheet was reviewed

to ensure expected emission changes were seen in reported data.  Two facilities that significantly

reduced emissions due to shutdowns during 2011 were verified by the comparison, and one facility that

stopped using coal for a combustion process was also verified.

Ext06

Based on the 2008 NEI facility priority list shared by EPA with the states, Missouri pulled their 2011 data

to see if there were significant changes, additions, or deletions that would be noted by EPA.  While some

of these facilities showed large changes in both CAP and HAP emissions, the changing nature of EPA’s

priorities from 2008 to 2011 made detailed analysis of these facilities unnecessary. Changes in facility

emissions over time were examined in further quality assurance checks.

Ind01

Emission outliers were to be examined by industry types. Due to time constrains, this check was not

completed.

Ind02

These checks create emission trend graphics for common industry types.  These graphics do not cause

changes to reported emissions.

Ind03

For electric utilities, Missouri had worked with them to adjust previous year emission reports to include

condensable PM for coal combustion units.  A check of their 2011 data showed those units were still

reporting PM CON.

Ind04
16 

For non‐EGU facilities that EPA created PM CON emissions in the 2008 NEI, their 2011 emission reports

to Missouri were reviewed to see if they should be itemizing PM CON.  No facility reports were amended

as a result of this comparison, as most large combustion units had begun itemizing PM CON in their

reports.

Fac01

The initial goal of examining facilities with changes of 20% or 5 tons produced over 100 facilities of

interest.  Instead, 51 facilities with total chargeable emissions change of 30% and 15 tons from 2010 to

2011 were examined.  Several changes are attributed to facility shutdowns or equipment changes, and

most other changes are legitimately due to changes in activity levels at the facility.  No erroneous facility

total emission changes were identified.

Fac02

Facility‐total pollutants PM10, NOX, SOx, and VOC were examined for single‐pollutant changes that drove

emission changes from 2010 to 2011.  To reduce the list from over 100 facilities to 39, only changes of

30% and 15 tons were examined.  Many facilities on this list overlapped the Fac01 results, meaning

facility process and production changes created the emission changes.  No erroneous facility pollutant

total changes were identified.

Fac03

For specific pollutants and processes, changes of 20% and 5 tons were initially reviewed to try and

identify erroneous changes in throughput, emission factors, or control efficiencies.  Due to the large

number of records and processes involved, plus the overlap of facilities from checks Fac01 and Fac02, no

emission changes at the process level were identified for detailed investigation or modification.

Fac04

For a select group of sources, the check was to identify process‐specific pollutant changes of 10% or

more than 3 tons.  Due to the overlap of checks from the previous series of checks, and the number of

processes involved, this check was not completed.

EF01

For emission factors where the source is cited as AP‐42, this check attempts to verify that the emission

factor is accurate.  Since the webFIRE database should contain SCC‐specific emission factor from AP‐42,

the database was compared to MoEIS emission factors for the same SCC, pollutant, and control status.  

One common problem with this approach is that the SCC chosen by a facility to describe an emission

process should match closely to what is actually occurring, and the emission factor may not be

associated with that same SCC.  For cases where a facility has chosen an emission factor from a similar

process, but not the exact process SCC, it becomes difficult to separate these legitimate emission factors

from poorly chosen or misrepresented emission factors.  No updates were made to emission factors

based on this comparison.  Future work with AP‐42 emission factor verification will be industry and

process specific to ensure groups of similar equipment are estimating emissions consistently, regardless

of the source of emission factor.
17 

EF02

For stack test factors that have changed between the 2010 and 2011 reports, the air program

enforcement approved stack tests done during 2010 and 2011 were reviewed to ensure the facility used

the most current test, and applied the factor correctly.  The review found no concerns with the modified

stack tested emission factors, and no updated emission reports were needed.

EF03

Similar to the previous check, all program reviewed and approved stack tests were examined to ensure

the facility used the most recent tested emission factors, regardless of how their previous emission

reports may have appeared.  No updated emission reports were needed based on this check.

EF04

EPA proposed that updated emission factors for PM from natural gas combustion be considered by

states prior to inventory submittal.  EPA based these new factors on more recent stack tests done with

an updated stack test method.  Missouri data indicates that the majority of PM emission factors EPA

proposes to update will result in less than a ton of emission change, and many of Missouri’s large PM

natural gas sources are already using site‐specific emission factors.  Though EPA claims these factors are

higher quality than what exists in AP‐42, there has not been an open opportunity for states and local

agencies to review the proposed new factors.  Despite the small change in PM that could result from

Missouri using EPA’s proposed factors, Missouri will wait for EPA to fully incorporate these updated

factors to the AP‐42 documents, including offering the results for state and local agency review.

Pol01

The lead monitoring network in Missouri covers all sources estimating over 0.5 tons of emissions

annually, except for sources with model‐demonstrated ambient impacts below the level of the standard.  

For Missouri, an annual review of all sources emitting over 0.5 tons of lead is completed, and 0.25 ton

sources are also reviewed to ensure complete coverage of the network.  All sources previously identified

in 2008 through 2010 data continued reporting emissions at or above the 0.25 ton level, including

power plants, lead smelters, ammunition plants, and large coal‐fired boilers.  This review did not result

in any revised emission reports.

Pol02

The largest sources of ammonia were identified in the inventory, and all facilities in those industries

were reviewed to ensure the pollutant is being included where necessary.  The largest emitters are

power plants with urea injection as part of a NOx control strategy, and wastewater treatment plants.  A

review of facilities in these industries shows all are reporting ammonia emissions as expected, and no

revised emission reports were required.

Pol03
18 

For facilities reporting aggregate and itemized HAP pollutants, this check ensures that the HAPs are a

subset of their total PM10 or VOC emissions, and HAPs are not greater than the PM10 and VOC totals.  

See section 7.4 for further details.

7.4 Quality Assurance of Hazardous Air Pollutant emissions

Various quality assurance checks were performed on Hazardous Air Pollutant (HAP) data reported by

facilities with a Part 70 or Intermediate operating permit.   The data was investigated in a different

manner than the previous year.  For the 2010 reporting year, facilities were marked high priority

primarily because of large differences in amounts reported from 2009 to 2010.  That approach yielded

some positive results, but proved to be very time intensive.   Additionally, sites reporting large year to

year changes were often correct.  A modified approach was developed, and HAP data checks performed

for the 2011 reporting year fall under these general categories:

 Searches for data that cannot be correct, such as grouped HAPs reported in the fee calculations

with no speciated HAP worksheets present

 Searches for data that is unlikely to be correct, such as identical HAP emissions from 2010 to

2011

 Cross‐checks with other data sources, primarily the Toxic Release Inventory (TRI)

More specifically, the following checks were done to identify HAP areas of concern.   

Err06

Data check Err06 compared hazardous air pollutant (HAP) worksheets to find those that were not

updated between reporting years 2011 and 2012.  Two Access queries were used to extract the

necessary information, one for 2010 data and one for 2011 data.  Facilities with identical information on

both year’s worksheets were identified, and any site with five or more tons of HAPs was marked high

priority.

Ext01

Data check Ext01 compared SOx and NOx data submitted through MoEIS to data submitted directly to

EPA.  Some electricity generating facilities are required to use continuous emission monitoring to

demonstrate compliance with the Acid Rain Program.  This information is available online from EPA.  

Discrepancies exceeding five tons and twenty percent of total emissions were identified and marked

high priority.

Ext03

Data check Ext03 compared HAP data submitted to the emissions inventory to submissions made to the

Toxic Release Inventory (TRI).  Since there is a significant amount of overlap between the two, most

comparisons can be made on a chemical by chemical basis.  EPA typically releases preliminary TRI data

within a month of the July 1 due date.  MoEIS stores TRI identification numbers for point sources,
19 

allowing a facility‐total match between the two data sets.  This comparison used releases reported to

the TRI as Fugitive Air and Stack Air.  No other TRI data was used.   

Two facilities reported hazardous air pollutants to the TRI but not to the EIQ.  Both were marked high

priority and investigated.  One facility appeared to have TRI emissions below the EIQ reporting

threshold.  Hazardous air pollutants were added to the other facility’s report.   

Ext04

Facilities that reported identical HAP worksheets for years 2009 and 2010, had HAP worksheets that

didn’t match the total chargeable HAP tons, or had significant differences between TRI and EIQ data

were identified in early 2012.  These facilities received an email explaining the potential errors and

advising them that particular attention should be paid to these areas of the inventory for the 2011

reporting year.  Data check Ext04 rechecked the facilities with HAPs reported on worksheets that did not

match chargeable HAPs and determine if the same mistake was made again for 2011.  The purpose for

this step was not to identify facilities to contact, but to determine the effectiveness of using mass email

as a means to improve the inventory.  The QA plan already included checks for identical HAP worksheets

and concurrent with TRI data.  

Ext06

In May, 2012, EPA sent a spreadsheet containing 2008 NEI data to the department with pollutants that

EPA considers particularly significant.  Some of the emission quantities that were ultimately used by EPA

in the NEI were different than what was reported by the department.  Four Access queries were written

to compare the data used by EPA to the data that was submitted by the department to the 2008 NEI.  

The first query, Ext06a, extracted the amount of each of the ten HAPs on EPA’s list that the department

reported as VOC or PM10 in 2008 for each facility on the 2011 NEI submission list.  The second query,

Ext06b, contained the HAPs reported in 2008 as HAPs.  The third query, Ext06c, combined HAPs

reported by the department as VOC or PM10 and HAPs reported as HAPs into one table.  As part of data

check Ext06, the HAPs for each facility on EPA’s list were converted into an Access table.  The last query,

Ext06final, combined HAPs reported by the department for the 2008 NEI and the HAPs from EPA’s list

into one table.    

A comparison of the two data sets revealed widespread and significant differences.  Since addressing

the discrepancies would have taken a vast amount of time, and since the data is several years old, it was

decided not to pursue corrections except in the very worst case.  The pollutants on the EPA list will be

given special attention in another QA step, Ext03.     

Pol03

Data check Pol03 compares the amount of HAPs reported as VOC or PM10 to the total amount of VOC

and PM10 reported for the.  An Access query, Pol03a, reports the total amounts of VOC and PM10

claimed at each site.  A second query, Pol03b reports the total amount of HAPs reported as VOC and

PM10 on the site’s HAP worksheets.  Pol3final matches the HAPs VOC and PM10 and total VOC and PM10
20 

by facility for comparison.  Any site reporting HAPs as VOC or PM10 in excess of the total VOC and PM10

reported was noted as an error.  Facilities with an excess of five tons or more were added to the high

priority list.

HAP Process to Worksheet Check

Although not included in the original list of QA steps, this check was done to determine which facilities

have a discrepancy between the amount of HAPs reported as HAPs on worksheets and the total

chargeable HAPs for 2011.  A single query, titled HAP Process to Worksheet Check, compared the two

amounts.  Nine facilities with a difference of five or more tons were added to the high priority list.

HAPs Without Worksheets Check

This step was also a later addition to the original QA plan.  It determined which facilities reported HAPs

as chargeable tons but did not have any HAP worksheets.  An Access query extracted the sum of HAPs

from the HAP worksheets and the sum of chargeable HAPs.  The join properties were set in such a way

that any facility with chargeable HAPs would be included, even if no worksheets exist.  When including

summations from multiple tables, Access often reports erroneous information.  In this case, chargeable

tons, when present, were frequently inaccurate.  For any site with chargeable HAPs and no blank

worksheet values, DNR staff verified the actual chargeable tons through the MoEIS website.  Any facility

with no HAP worksheets and five or more tons of chargeable HAPs was added to the high priority list.

After the high priority list was compiled, a detailed review was done to remove facilities that were likely

correct or would not significantly impact the inventory if corrected.  A total of five facilities were

removed for the following reasons.

 Data for 2011 had not been submitted, and APCP staff was working with the site to get updated

information.  

 HAP emissions for 2010 and 2011 were identical, but other emissions were nearly identical.  One

site had a year to year difference of 2.6%, and another had a difference of less than 1%.

 There was no production in 2011, and the site had no operating permit.   

 The company’s consultant verified that 2011 data was accurate, and said that the mistake was in

the 2010 data that was used for comparison.

After the preliminary review, the high priority list contained 22 facilities.  Contact was made with each

facility, and any reporting errors were resolved.  Changes made to the inventory were documented in

the facility’s 2011 EIQ file.   
21 

Table 2: Point Source Emissions by Facility (tons per year) 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

001 0006 AMEREN MISSOURI 0.15 0.59 0.03 0.00 003 P011

KELLER CONSTRUCTION

COMPANY 6.63 0.00 0.41 2.04 0.23 

007 0001 MID AMERICA BRICK 8.81 2.57 3.85 0.09 007 0002

ARCHER DANIELS MIDLAND

CO 15.13 18.01 45.04 18.79 

007 0003

HARBISON‐WALKERREFRACTORIES 16.77 6.55 16.94 11.84 

007 0012 AMEREN MISSOURI 0.01 0.00 2.36 0.03 0.03 007 0040

TEVA PHARMACEUTICALSUSA INC 0.39 0.00 0.46 3.06 0.24 0.24 

007 0041 VANDALIA POWER PLANT 0.20 0.95 0.02 0.00 007 0047

CERRO FLOW PRODUCTSLLC 117.43 0.02 0.00 2.50 17.12 15.11 

007 0051 MEXICO PLASTIC COMPANY 0.05 0.26 0.01 0.00 007 0053 AMEREN MISSOURI 32.93 56.02 6.21 0.00 007 0054 POET BIOREFINING 54.66 45.86 26.56 0.00 009 0003 EFCO 5.49 1.18 6.53 0.93 0.50 009 0005

SAPA EXTRUSIONS NORTH

AMERICA 18.02 0.00 0.69 22.59 11.53 11.27 

009 0021 SCHREIBER FOODS INC 6.73 0.00 0.26 8.01 0.61 0.61 009 0052 JUSTIN BOOT COMPANY 0.00 0.00 0.00 0.00 009 0062

ARCHITECTURAL SYSTEMS

INC 4.57 
22 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

009 0066 GEORGE'S INC 2.47 0.09 2.93 17.18 2.73 011 0031

LAMAR CITY ELECTRICAL

GENERATION 118.81 39.11 5.10 5.10 

011 0039

PRAIRIE VIEW REGIONAL

WASTE FACILITY 43.85 2.34 11.03 2.00 

013 0029

BUTLER MUNICIPAL POWER

PLANT 0.23 2.23 0.19 0.19 

017 0019

NATURAL GAS PIPELINE

COMPANY 185.46 0.00 2,924.24 31.83 31.83 

019 0002

COLUMBIA MUNICIPAL

POWER PLANT 129.33 0.00 10.91 266.32 23.31 21.58 

019 0004

UNIVERSITY OF MISSOURI

(MU) 70.05 0.00 0.06 500.43 60.52 56.07 

019 0005

MAGELLAN PIPELINE

COMPANY LP 8.45 3.38 

019 0039

HUBBELL POWER SYSTEMS,

INC 4.75 0.01 0.00 6.79 4.93 0.24 

019 0045

CHRISTIAN HEALTH

SYSTEMS 2.78 0.00 0.02 5.03 0.37 0.36 

019 0047 UNIVERSITY OF MISSOURI 0.30 0.00 0.01 1.38 0.03 0.03 019 0066

DANA LIGHT VEHICLE

DRIVELINE 0.33 0.01 0.40 0.03 0.03 

019 0069

QUAKER MANUFACTURINGLLC 0.92 1.09 13.33 13.33 

019 0077

PANHANDLE EASTERNPIPELINE 151.43 641.84 12.34 12.34 

019 0091

COLUMBIA SANITARY

LANDFILL 96.78 0.00 12.67 5.35 0.70 

019 0105 COLUMBIA ENERGY CENTER 2.31 0.00 3.20 0.68 0.12 021 0004

KANSAS CITY POWER AND

LIGHT CO 117.70 0.08 2.33 2,335.74 357.12 110.48 

021 0009

JOHNSON CONTROLSBATTERY GROUP INC 5.65 0.19 6.73 7.37 4.02 
23 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

021 0016 LIFE LINE FOODS LLC 37.85 36.81 12.01 3.12 021 0037 ALBAUGH INC 0.00 0.00 021 0045 OMNIUM LLC 0.00 0.00 4.67 0.00 021 0046 INTERNATIONAL PAPER 4.03 0.15 4.80 0.37 0.27 021 0056

BARTLETT GRAIN COMPANY

LP 1.31 0.00 1.56 12.89 1.30 

021 0060 AG PROCESSING INC 1.44 1.71 35.43 10.41 021 0063

HEARTLAND REGIONAL

MEDICAL CENTER EAST 5.25 0.00 0.03 6.27 0.48 0.48 

021 0064 SILGAN CONTAINERS CORP 5.80 0.00 6.90 0.52 0.52 021 0078 ALTEC INDUSTRIES INC 1.98 0.01 0.08 2.37 0.85 0.44 021 0095 BLUESCOPE BUILDINGS 0.00 0.00 0.00 0.00 021 0105 ST. JOSEPH LANDFILL 29.89 1.59 12.88 1.22 021 0118 AG PROCESSING 0.49 0.00 021 0129

KANSAS CITY POWER AND

LIGHT CO 20.08 1.07 0.46 0.46 

023 0003 WILLIAMSVILLE MATERIALS 5.69 0.01 023 0027

JOHN J. PERSHING VA

MEDICAL CENTER 1.28 0.07 4.33 0.15 0.12 

023 0032 GATES CORPORATION 4.38 0.00 5.22 0.40 0.00 023 0038

BRIGGS AND STRATTON

CORP 29.05 0.00 0.04 7.89 8.20 0.41 

023 0042 CENTERPOINT ENERGY 111.49 108.08 1.51 1.51 023 0050

POPLAR BLUFF MUNICIPAL

UTILITIES 2.71 0.09 9.94 0.15 0.14 
24 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

023 0058 BUTLER COUNTY LANDFILL 47.25 2.52 1.07 1.07 023 0062 NORDYNE LLC 0.01 0.02 0.00 0.00 027 0001

HARBISON‐WALKERREFRACTORIES 0.08 0.09 0.86 0.03 

027 0007 FULTON POWER PLANT 0.32 0.10 1.38 0.05 0.04 027 0010

A. P. GREEN INDUSTRIES

INC 25.22 7.39 25.71 14.21 

027 0019 ABB INC 4.02 5.98 2.13 0.00 027 0026 AMEREN MISSOURI 4.12 20.59 0.59 0.00 031 0002 DELTA ASPHALT INC 37.45 0.00 0.69 2.33 5.29 0.20 031 0010

SOUTHEAST MISSOURISTATE UNIVERSITY 33.00 0.00 0.00 41.25 9.02 6.05 

031 0021 BUZZI UNICEM USA 7,113.12 0.00 12.69 1,129.35 393.86 218.29 031 0053

PROCTER AND GAMBLE

PAPER PRODUCTS CO 185.84 0.00 1.55 101.53 49.72 0.51 

031 0058

ST. FRANCIS MEDICALCENTER 5.01 0.04 6.89 0.46 0.46 

031 0061

JACKSON MUNICIPAL

UTILITIES 0.36 1.35 0.02 0.02 

031 0064 BIOKYOWA INC 18.89 0.00 4.81 8.39 2.57 1.71 031 0072 MONDI JACKSON 0.66 1.15 2.10 2.10 031 0081

CONSOLIDATED GRAIN AND

BARGE CO 0.58 0.00

031 0126 MID‐SOUTH PRODUCTS INC 0.23 0.02 033 0001 SINCLAIR 3.25 1.30 033 0013

AGRISERVICES OFBRUNSWICK LLC WEST 0.02 0.02 0.10 15.15 1.12 
25 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

033 0022

CARROLLTON MUNICIPALUTILITIES 2.00 0.06 10.88 0.18 0.18 

033 0023

RAY‐CARROLL COUNTY

GRAIN GROWERS INC 0.00 0.00 4.21 0.00 

033 0036 SHOW ME ETHANOL LLC 29.26 48.74 12.76 0.00 033 0037 RAY‐CARROLL FUELS 035 0004 ROYAL OAK ENTERPRISES 29.19 70.20 16.01 5.15 037 0001

MARTIN MARIETTA

MATERIALS 55.41 4.45

037 0002

MARTIN MARIETTA

MATERIALS LLC 1.87 0.00

037 0003

KANSAS CITY POWER AND

LIGHT CO 0.31 3.02 0.07 0.07 

037 0048

PECULIAR SOUTHERN STAR

CENTRAL 4.87 0.00 36.22 0.73 0.58 

037 0056

DOGWOOD ENERGY

FACILITY 6.08 13.89 43.24 19.82 19.82 

037 0063

KANSAS CITY POWER AND

LIGHT CO 39.38 24.31 3.17 3.17 

039 0003 DAIRICONCEPTS 9.12 0.00 0.35 7.92 38.17 38.04 039 0012 FOAM FABRICATORS INC 1.55 0.06 1.84 0.14 0.10 045 0026

KAHOKA ELECTRICGENERATING PLANT 0.05 0.21 0.00 0.00 

045 0028 KPF STEEL FOUNDRY 0.37 0.00 0.50 1.71 0.03 047 0002 INGREDION, INC 26.86 31.98 108.85 0.34 047 0009

ARCHER DANIELS MIDLAND

CO 0.51 0.00 0.02 0.61 11.15 0.90 

047 0012 CCP COMPOSITES US LLC 2.41 0.00 0.09 3.09 0.53 0.22 
26 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

047 0019 FORD MOTOR CO 68.56 0.00 2.61 81.79 78.67 74.56 047 0025 BARTLETT GRAIN COMPANY 2.64 0.13047 0027 CARGILL INC 0.04 0.38 0.00 047 0032 HENRY WURST INC 0.06 1.53 0.01 0.00 047 0040 DAVIS PAINT CO 0.03 0.08 5.63 0.00 047 0052 AXEL AMERICAS, LLC 0.10 0.41 0.01 0.00 047 0059 HALLMARK CARDS INC 1.52 0.00 1.81 0.14 0.00 047 0075 TNEMEC COMPANY INC 0.00 0.00 0.00 0.22 0.00 047 0096

INDEPENDENCE POWER

AND LIGHT 9.73 0.01 0.05 588.33 130.19 123.37 

047 0122 RR DONNELLEY 1.29 0.00 1.54 0.18 0.00 047 0141

FUJIFILM MANUFACTURING

USA INC 0.07 0.32 0.02 0.00 

047 0175 VERTEX PLASTICS INC 047 0189 ARKEMA INC 0.51 0.85 1.51 0.05 047 2227 WATER SUPPLY DIVISION 6.97 0.00 0.23 15.72 9.01 0.60 051 0008 AMEREN MISSOURI 0.08 0.00 1.15 0.06 0.00 051 0009

UNILEVER SUPPLY CHAIN

INC. 3.92 4.66 0.35 0.35 

051 0028

RR DONNELLEY‐JEFFERSON

CITY 

051 0032

MODINE MANUFACTURINGCOMPANY 2.51 0.08 0.10 3.03 4.47 3.17 

051 0042

PHILLIPS 66 PIPELINECOMPANY 44.19 25.31 
27 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

051 0043

COMMAND WEB OFFSET

MISSOURI INC 0.55 0.65 0.05 0.05 

051 0049 AMEREN MISSOURI 0.07 0.00 1.07 0.06 0.00 051 0058

JEFFERSON CITY LANDFILL

LLC 11.24 0.60 1.59 0.39 

051 0075

AMERESCO JEFFERSON CITYLLC 94.42 21.42 5.52 0.00 

053 0003 HUEBERT FIBERBOARD INC 61.86 22.84 17.26 0.00 053 0019 CATERPILLAR INC 1.23 0.02 1.47 1.71 0.12 053 0021 NORDYNE INC 0.18 0.22 0.03 0.00 053 0027

OFFICE OFADMINISTRATION FMDC 2.53 0.10 0.97 0.23 0.23 

055 0043 SLP LIGHTING CENTER 061 0010 LANDMARK MFG CORP 0.00 0.00 0.00 0.02 0.02 063 0009

MAGELLAN PIPELINE

COMPANY LP 2.92 7.00 0.27 0.00 

065 0038

ROYAL OAK ENTERPRISES

INC 56.84 0.01 0.00 46.55 84.54 30.95 

069 0010

WHITE OAK GIN COMPANY

INC 0.63 0.75 8.39 0.25 

069 0014

GRAVES KENNETT GIN

COTTON CO INC 0.13 0.16 9.27 0.27 

069 0018 FARMERS UNION GIN 31.08 0.91069 0027 FOUR WAY GIN COMPANY 17.71 0.38069 0029

CARDWELL COOPERATIVEINC 6.20 0.00 

069 0034

MALDEN MUNICIPAL

POWER & LIGHT 0.42 0.00 1.98 0.05 0.05 
28 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

069 0063

KENNETT GENERATING

PLANT 1.74 0.00 13.42 0.21 0.21 

069 0066 ST FRANCIS POWER PLANT 32.04 26.25 46.75 11.87 0.26 071 0003 AMEREN MISSOURI 2,694.05 0.00 3.04 9,891.45 2,660.87 1,712.12 071 0014 CANAM STEEL CORP 0.01 1.45 0.44 0.00 071 0020

STEELWELD EQUIPMENT CO

INC 0.10 0.00 0.12 0.01 0.00 

071 0031

GRAPHIC PACKAGING

INTERNATIONAL 0.04 0.03 0.18 0.02 0.02 

071 0068 MERAMEC INDUSTRIES INC 0.06 0.27 1.11 0.00 071 0080 SPARTAN SHOWCASE INC 0.35 0.42 0.06 0.00 071 0087

BULL MOOSE TUBECOMPANY 0.28 0.48 0.65 0.09 

071 0131

SULLIVAN PRECISION

METAL FINISHING INC 0.00 0.00 0.00 0.00 

071 0132 SPORLAN VALVE DIVSION 071 0151 AEROFIL TECHNOLOGY INC 0.26 1.28 5.77 2.31 071 0153 MAGNET LLC 071 0157 PLAZE INCORPORATED 0.25 1.20 0.04 0.00 071 0173

HENNIGES AUTOMOTIVE

SEALING SYSTEMS NA 0.53 

071 0230 PLAZE, INC 0.62 0.73 0.06 0.00 073 0008

RR DONNELLEY ‐ OWENSVILLE 1.55 0.06 1.85 0.14 0.14 

077 0004

CARLISLE POWER

TRANSMISSION PRODUCTS

INC 7.90 0.00 0.30 9.51 3.39 0.84 
29 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

077 0005

CITY UTILITIES OF

SPRINGFIELD MISSOURI 697.57 0.03 0.58 1,434.54 398.21 238.54 

077 0008

BRISTOL MANUFACTURING

CORP 0.27 0.00 0.01 2.15 0.16 0.02 

077 0017 EUTICALS INC 1.55 0.00 0.14 6.20 1.78 0.70 077 0026 KRAFT FOODS GROUP INC 9.62 0.00 0.37 11.45 2.37 0.87 077 0028

MERCY HOSPITAL ‐

SPRINGFIELD 12.37 0.00 0.46 11.32 1.14 1.14 

077 0036

DAIRY FARMERS OF

AMERICA INC 5.62 0.00 0.21 6.69 0.53 0.51 

077 0039

CITY UTILITIES OF

SPRINGFIELD MISSOURI 835.87 0.03 34.21 1,367.11 385.60 172.51 

077 0047

MISSOURI STATEUNIVERSITY 6.19 0.00 0.04 7.37 0.56 0.56 

077 0051 3M COMPANY 5.01 0.00 0.19 5.97 1.54 0.45 077 0116

MAGELLAN PIPELINE

COMPANY LLC 16.72 6.69 

077 0161

SPRINGFIELD SANITARYLANDFILL 176.32 9.40 25.00 1.47 

077 0163

CITY UTILITIES OF

SPRINGFIELD 0.08 0.25 0.02 0.01 

077 0164

CITY UTILITIES OF

SPRINGFIELD 14.59 0.00 15.11 0.57 0.57 

077 0170

CITY UTILITIES OF

SPRINGFIELD MISSOURI 95.42 20.74 5.39 5.39 

077 0228

SUPERIOR SOLVENTS &

CHEMICALS 

079 0004

MODINE MANUFACTURINGCOMPANY 3.09 0.12 3.87 2.81 0.28 

079 0027

TRENTON MUNICIPAL

UTILITIES 0.51 0.00 1.92 0.03 0.03 

081 0010

MAGELLAN PIPELINE

COMPANY LP 14.75 35.41 1.38 0.00 
30 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

081 0015

BETHANY MUNICIPALPOWER PLANT 0.53 2.47 0.05 0.05 

083 0001

KANSAS CITY POWER AND

LIGHT CO 409.27 0.09 0.86 4,701.55 367.39 199.92 

083 0011 APAC MO, INC 0.64 0.68 13.16 0.02 083 0031 TRACKER MARINE 1.12 1.33 0.49 0.00 083 0033 SCHREIBER FOODS INC 0.35 0.01 0.41 0.03 0.03 083 0046 SCHREIBER FOODS INC 0.68 0.03 0.81 0.06 0.06 087 0001 EXIDE TECHNOLOGIES 3.10 0.01 0.12 7.01 20.24 20.24 087 0016 GOLDEN TRIANGLE ENERGY 0.36 1.07 10.11 43.95 4.16 091 0005

SMITH FLOORINGCOMPANY 31.87 26.03 9.93 3.19 

091 0011

DRS SUSTAINMENTSYSTEMS INC. 0.15 0.10 0.75 0.41 0.02 

091 0037

ROYAL OAK ENTERPRISES

INC 25.70 0.00 0.00 20.99 51.57 11.44 

091 0038

GARNETT WOODPRODUCTS 2,413.94 142.85 106.77 68.32 

091 0046

ARMSTRONG HARDWOODFLOORING COMPANY 12.06 2.13 6.42 0.00 

091 0068

CITY OF WEST PLAINS‐

POWER STATION 0.21 0.01 0.85 0.07 0.00 

093 0005 DOE RUN COMPANY 0.00 1.07 0.00 51.47 7.71 093 0009 DOE RUN COMPANY 25,641.21 16.88 82.49 30.73 22.43 095 0002

BUCKEYE TANK TERMINALS,

LLC 4.75 1.90 

095 0005 U. S. DEPT OF ENERGY 0.85 0.00 0.88 13.98 0.55 0.53 
31 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

095 0011 BAYER CROPSCIENCE 23.01 0.00 0.80 48.09 4.23 4.23 095 0012 CLAY AND BAILEY MFG CO 0.01 0.00 0.09 5.08 0.00 095 0017 FOLGERS COFFEE CO 140.02 20.95 10.79 0.00 095 0021

VEOLIA ENERGY KANSAS

CITY INC 39.50 0.02 5.21 1,216.88 358.40 354.05 

095 0022

KANSAS CITY POWER AND

LIGHT CO 2,007.09 0.04 8.43 1,424.74 189.87 167.39 

095 0023

KANSAS CITY POWER AND

LIGHT CO 0.04 0.00 13.00 0.12 0.12 

095 0026

HANSEN MUELLER KANSAS

CITY ELEVATOR 0.11 0.02

095 0030 AUDUBON MATERIALS, LLC 542.09 0.00 17.93 646.83 183.89 84.26 095 0031

KCP AND L ‐ GREATER MOOPERATIONS 350.66 0.03 0.39 2,461.30 338.23 292.11 

095 0037 VANCE BROTHERS INC 15.63 0.00 0.14 9.24 1.46 0.78 095 0039

BLUE RIVER TREATMENTPLANT 66.22 0.06 0.02 13.37 2.41 1.94 

095 0046 ALLIANT TECHSYSTEMS INC 18.05 0.42 0.86 46.92 10.64 2.09 095 0050

INDEPENDENCE POWER

AND LIGHT 24.31 0.02 0.14 525.04 305.45 271.00 

095 0064 VANCE BROTHERS INC 0.40 0.00 0.14 4.46 0.69 0.37 095 0075 PETERSON MFG CO 0.41 0.00 0.48 0.08 0.03 095 0076

BARBER AND SONSAGGREGATES 3.38 10.39 4.96 0.82 

095 0114 HALLMARK CARDS 2.08 0.00 0.06 4.35 0.19 0.19 095 0139

KANSAS CITY POWER AND

LIGHT CO 11.89 0.00 24.50 0.97 0.97 
32 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

095 0178 UNILEVER 6.98 0.23 8.31 5.13 0.63 095 0191

AERO TRANSPORTATIONPRODUCTS INC 

095 0222

INDEPENDENCE POWER

AND LIGHT 0.10 1.88 0.13 0.00 

095 0223

INDEPENDENCE POWER

AND LIGHT 0.88 4.00 0.49 0.00 

095 0224

INDEPENDENCE POWER

AND LIGHT 0.06 1.12 0.08 0.00 

095 0244 TIFFANY MARBLE INC 0.00 0.00 0.00 0.00 0.00 095 0267

COURTNEY RIDGELANDFILL, LLC 45.08 2.40 9.20 1.84 

095 0272

LEE'S SUMMIT SANITARYLANDFILL 20.48 1.09 3.13 0.73 

095 0273

RUMBLE RECYCLING AND

DISPOSAL SERVICES 52.68 2.85 1.20 1.20 

095 0321

KANSAS CITY AGGREGATE

LLC 0.03 0.03

095 2001 CARGILL INC 0.00 0.00 0.00 13.57 12.04 095 2007

CROWN CENTER

REDEVELOPMENT

CORPORATION 7.57 0.00 0.27 9.30 0.69 0.69 

095 2054

RESEARCH MEDICAL

CENTER 2.38 0.00 0.33 9.54 0.22 0.13 

095 2058

COOK BROTHERSINSULATION INC 0.00 

095 2087

RESEARCH MEDICAL

CENTER 0.66 0.01 2.64 0.14 0.14 

095 2101 SOUTHEAST LANDFILL, LLC 59.19 3.16 1.34 1.34 095 2177

INTERNATIONAL PAPER

COMPANY 2.38 0.00 0.01 2.84 0.81 0.22 
33 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

095 2431 SUN CHEMICAL 0.02 0.01 097 0001

EMPIRE DISTRICT ELECTRICCO 177.89 0.09 4.19 1,229.00 373.75 348.13 

097 0007 DYNO NOBEL INC 1.94 0.00 2.12 7.92 3.91 0.37 097 0011 ADM MILLING COMPANY 0.10 0.00 0.00 0.12 1.90 0.68 097 0013

TAMKO BUILDINGPRODUCTS INC 7.51 0.00 0.00 4.83 4.08 1.96 

097 0021

ST. JOHN'S REGIONAL

MEDICAL CENTER 2.02 0.00 2.41 0.18 0.18 

097 0058 JUSTIN BOOT COMPANY 0.00 0.00 097 0062

EMPIRE DISTRICT ELECTRICCO 5.40 35.00 2.99 2.98 

097 0065

MODINE MANUFACTURINGCOMPANY 0.44 0.75 4.01 0.00 

097 0089

ABLE MANUFACTURING &

ASSEMBLY L.L.C. 

097 0094

TAMKO BUILDINGPRODUCTS INC 73.86 0.00 31.69 20.51 0.00 

097 0095

ABLE MANUFACTURING

CORPORATION 

097 0104

EMPIRE DISTRICT ELECTRICCO 575.86 0.00 62.02 107.60 46.35 46.35 

097 0110

CARTHAGE WATER &

ELECTRIC 6.28 0.42 70.67 4.42 0.76 

097 0117

EAGLEPICHERTECHNOLOGIES LLC 0.21 1.00 0.05 0.00 

097 0132 BEMIS PACKAGING LLC 2.48 0.00 2.95 0.22 0.22 097 0138

EBV EXPLOSIVES

ENVIRONMENTAL CO 9.45 0.00 0.00 24.54 0.54 0.00 

099 0002

RIVER CEMENT CO. DBA

BUZZI UNICEM USA 1,168.99 0.04 5.85 1,756.58 322.25 168.46 
34 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

099 0003 DOE RUN COMPANY 18.01 21.11 0.29 9.60 7.47 4.34 099 0011

UNION PACIFIC RAILROAD

CO 1.10 1.55 3.05 2.68 

099 0012 TRAUTMAN QUARRY 3.28 0.26 099 0014

DOW CHEMICAL COMPANY,

THE 0.00 0.00 0.00 0.00 0.00 0.00 

099 0016 AMEREN MISSOURI 1,242.97 0.00 1.40 3,441.72 686.65 246.31 099 0044

METAL CONTAINER

CORPORATION 9.09 10.85 2.50 2.50 

099 0052

ENGINEERED COILCOMPANY 0.00 0.00 0.00 0.00 

099 0068

SAINT‐GOBAIN

CONTAINERS INC 9.24 0.20 107.22 90.86 87.03 

099 0103 BUSSEN QUARRIES INC 11.42 0.22 099 0111

CARONDELETCORPORATION 4.18 0.00 0.07 6.46 16.53 0.14 

099 0114 AERO METAL FINISHING 1.53 0.34 0.00 101 0002

UNIVERSITY OF CENTRAL

MISSOURI 4.39 5.22 0.40 0.00 

101 0009

WHITEMAN AIR FORCE

BASE 19.35 0.08 26.99 2.51 0.32 

101 0023

ENERSYS ENERGYPRODUCTS INC 3.50 0.02 4.21 0.94 0.08 

101 0046

SHOW‐ME REGIONAL

LANDFILL 52.61 0.00 2.81 4.23 1.50 

101 0051 HOLDEN POWER PLANT 0.64 0.00 6.78 0.84 0.84 101 0054 MASTER MARBLE INC 0.00 0.00 0.00 0.00 105 0001

INDEPENDENT STAVE CO

INC 57.82 0.00 2.01 47.37 15.57 8.74 
35 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

105 0006

BRUNSWICK FRESHWATER

GROUP 0.67 0.81 0.32 0.00 

105 0013

DETROIT TOOL AND

ENGINEERING 0.00 0.08 0.00 

105 0033

RBC MANUFACTURINGCORPORATION 0.27 0.00 0.00 0.32 0.22 0.02 

105 0038 G3 BOATS 0.00 0.00 105 0046 TRACKER MARINE 0.00 0.00 4.13 0.00 107 0004 REMINGTON ARMS 1.80 0.00 0.20 1.12 0.41 107 0010 WINCUP 5.16 0.00 0.03 6.15 0.47 0.00 107 0038

HIGGINSVILLE MUNICIPALPOWER FACILITY 0.48 0.04 1.73 0.04 0.04 

107 0050

BARTLETT GRAIN COMPANY

LP 0.00 0.00 2.21 0.56 

109 0002

TRANSMONTAIGNEOPERATING COMPANY L.P. 0.59 0.24 

109 0004 BCP INGREDIENTS 4.07 4.87 5.90 0.75 109 0008

MO REHABILITATION

CENTER 0.26 0.00 0.01 1.22 0.03 0.03 

109 0036 PHILLIPS 66 COMPANY 11.12 5.56 0.00 0.00 111 0019 AYERS OIL CO 111 0025 BFI BACKRIDGE LANDFILL 43.46 2.32 5.76 0.00 113 0003

OLD MONROE ELEVATOR &

SUPPLY 0.01 0.02 0.98 0.20 

113 0029 BODINE ALUMINUM INC 3.27 29.53 18.27 0.00 113 0042

FARMERS ELEVATOR &

SUPPLY CO 0.00 0.01 0.97 0.14 
36 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

115 0001

WALSWORTH PUBLISHINGCOMPANY 0.08 0.03 0.38 0.03 0.03 

115 0021

MARCELINE MUNICIPAL

UTILITY 0.04 0.00 0.00 0.17 0.00 0.00 

117 0002

CHILLICOTHE MUNICIPAL

UTILITIES 0.48 0.00 3.85 0.06 0.06 

117 0012 DONALDSON CO INC 0.05 0.00 0.00 0.06 1.46 0.00 119 0017 SIMMONS FOODS INC 54.05 10.30 40.07 8.11 6.54 119 0030

WAL‐MART NORTH DATACENTER 0.41 13.30 0.09 0.00 

121 0004

MACON MUNICIPALUTILITIES 0.37 1.73 0.04 0.04 

121 0027

VEOLIA ES MAPLE HILL

LANDFILL, INC 44.93 2.40 3.37 1.25 

121 0028 POET BIOREFINING 46.61 36.32 26.12 0.02 121 0033

MACON MUNICIPALUTILITIES 12.06 17.69 3.26 3.26 

121 0035

MACON MUNICIPALUTILITIES 0.19 0.89 0.02 0.02 

121 0036

MACON MUNICIPALUTILITIES 0.12 0.57 0.01 0.01 

123 0018 CENTERPOINT ENERGY 153.64 249.85 0.59 0.59 123 0022 VERSA‐TECH INC 0.00 0.00 0.00 0.00 0.00 125 0001

KINGSFORDMANUFACTURING CO 44.57 0.02 169.64 101.73 98.71 

127 0001 BASF CORPORATION 114.45 0.17 0.35 380.41 159.96 141.09 127 0002

MAGELLAN PIPELINE

COMPANY LLC 4.28 1.71 

133 0014 GATES CORPORATION 0.88 1.05 0.08 0.00 
37 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

133 0016

CONSOLIDATED GRAIN AND

BARGE CO 0.00 0.00 1.79 0.11 

137 0028

MONROE CITY POWERPLANT 0.27 1.23 0.08 0.00 

139 0008 CHRISTY MINERALS, LLC 71.70 0.00 0.00 147.67 15.33 0.04 143 0004

NEW MADRID POWER

PLANT 6,311.54 0.00 19.45 8,637.73 400.31 292.54 

143 0008 NORANDA ALUMINUM INC 24,562.97 0.96 30.53 488.33 220.86 143 0012 MAHAN GIN CO 0.04 0.31 6.03 0.00 143 0013

PORTAGEVILLE FARMERS

GIN INC 6.73 0.16

143 0015

SIEGEL‐ROBERTAUTOMOTIVE 0.70 0.08 7.74 0.17 0.06 

143 0023 MCCORD GIN ‐ NORTH 0.00 0.00 15.68 0.46 143 0027

CARGILL INC ‐ NEW MADRID

ELEVATOR 1.10 0.19

143 0046

A. C. RILEY COTTONCOMPANY 0.00 0.00 6.44 0.00 

143 0062

BUNGE NORTH AMERICA

INC 0.04 0.01 0.15 6.91 1.10 

145 0005 LA‐Z‐BOY, INCORPORATED 0.68 0.02 0.84 1.76 1.76 145 0007

FAG BEARINGSCORPORATION 5.79 0.01 0.18 0.01 0.01 

145 0044 PREMIER TURBINES 11.49 13.44 0.85 0.10 145 0049

SAGINAW SOUTHERN STAR

CENTRAL 4.78 34.27 0.65 0.53 

147 0005

NORTHWEST MISSOURISTATE UNIVERSITY 54.52 0.00 0.00 23.16 2.84 2.07 

147 0008

ENERGIZER BATTERY

MANUFACTURING INC 1.87 0.07 2.23 0.29 0.17 
38 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

147 0023

KAWASAKI MOTORS MFG

CORP 111.83 0.00 8.15 22.80 11.74 

147 0024

ANR PIPELINE COMPANY ‐TRANSCANADA CORP 223.21 931.71 18.03 18.03 

147 0027 CONSUMERS OIL CO INC 0.53 0.00 147 0032 NODAWAY POWER PLANT 0.54 1.93 0.19 0.19 151 0002

CENTRAL ELECTRIC POWER

COOPERATIVE 71.73 0.01 0.09 2,205.78 164.87 151.39 

151 0050

QUAKER WINDOWPRODUCTS COMPANY 0.00 0.00 0.48 0.00 

155 0024 STILL GIN AND GRAIN INC 0.00 0.00 3.21 0.14 155 0030

TRINITY MARINE PRODUCTS

INC 0.35 1.76 12.43 0.05 

155 0045 M‐D PRODUCTS INC 2.33 0.00 2.77 0.33 0.21 155 0049

TRINITY MARINE PRODUCTS

INC 0.08 0.41 0.02 0.00 

155 0063

BUNGE NORTH AMERICA

INC 0.00 0.00 0.00 1.71 0.17 

157 0019 TG MISSOURI 0.80 0.01 4.92 3.94 0.24 157 0020 ATLAS EPS 2.32 2.58 5.76 0.00 157 0027 TNT PLASTICS INC 0.00 0.00 0.00 0.00 159 0009

PITTSBURGH‐CORNINGCORP 24.57 199.77 40.30 3.03 

159 0012 WATERLOO INDUSTRIES INC 5.31 6.32 0.49 0.00 159 0022 ALCAN CABLE 2.73 0.00 0.10 3.25 0.25 0.25 159 0027

HAYES LEMMERZ

INTERNATIONAL INC 3.82 0.00 4.55 0.50 0.00 
39 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

159 0037 TYSON FOODS INC 31.04 9.04 36.96 19.06 1.84 159 0041

MISSOURI PRESSED METALS

INC 0.05 0.01 0.35 0.15 0.00 

159 0047

PANHANDLE EASTERN PIPE

LINE CO 362.30 1,844.10 38.17 38.17 

159 0055

CENTRAL MISSOURI

SANITARY LANDFILL 2.40 13.54 1.35 

159 0056 EDWARDS FIBERGLASS INC 161 0006

MISSOURI UNIV. OFSCIENCE AND TECHNOLOGY 48.99 0.00 5.27 51.20 11.13 4.62 

161 0039

MANCHESTER PACKAGINGCOMPANY 0.01 0.04 0.00 0.00 

161 0054 ROLLA MUNICIPAL UTILITIES 0.05 1.97 0.06 0.06 163 0002 ASHLAND INC 19.93 0.01 2.67 295.33 43.86 7.69 163 0008 WAYNE B SMITH INC 0.00 0.02 9.37 0.63 163 0025

BUNGE NORTH AMERICA

INC 0.02 0.00 0.02 3.72 0.56 

163 0031 DYNO NOBEL INC 1.51 20.56 462.41 110.41 53.00 163 0040 EAGLE RIDGE LANDFILL 1.12 3.55 0.36 163 0047 AMEREN MISSOURI 3.05 49.65 5.64 0.00 165 0007

KANSAS CITY POWER AND

LIGHT CO 1,126.77 0.11 2.13 2,480.04 504.89 407.79 

165 0021

MULTI‐COLOR

CORPORATION 0.00 0.00 0.00 0.00 0.00 

165 0028

WOODBRIDGECORPORATION 1.39 0.01 1.65 0.13 0.13 

165 2404

KCI AIRPORT ‐ KCMO

AVIATION DEPT 2.81 0.00 0.03 5.43 0.40 0.40 
40 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

165 2415

HARLEY DAVIDSON MOTOR

COMPANY 4.09 0.83 6.05 0.47 0.47 

165 2424

FACILITY OPERATIONSERVICES LLC 5.50 0.00 18.34 0.50 0.50 

169 0004

INSTALN MGMNT CMND

AND FT LEONARD WOOD 15.31 0.00 9.37 46.23 3.41 0.53 

171 0015 UNIONVILLE POWER PLANT 0.01 0.00 0.05 2.20 0.03 0.03 173 0001

CONTINENTAL CEMENTCOMPANY LLC 467.94 0.00 788.33 81.75 0.28 

173 0021 ENNIS PAINT INC 0.47 0.00 173 0037

BUCKHORN RUBBER

PRODUCTS INC 0.00 0.04 0.00 0.00 11.44 11.36 

175 0001

THOMAS HILL ENERGY

CENTER POWER DIVISION 5,444.35 0.00 72.50 8,484.24 544.00 469.97 

175 0010 AMEREN MISSOURI 0.05 0.00 0.71 0.04 0.00 175 0061 WILSON TRAILER SALES INC 0.00 0.00 0.00 0.24 0.24 179 0006 DOE RUN COMPANY 0.00 0.73 0.00 20.43 3.08 183 0001 AMEREN MISSOURI 710.19 0.00 0.80 7,073.99 445.74 413.52 183 0004 FRED WEBER INC 21.92 0.00 1.37 1.40 0.05 183 0010 BOEING COMPANY 1.70 0.00 0.06 2.03 0.36 0.15 183 0019 ST. JOSEPH HEALTH CENTER 3.36 0.02 4.85 2.95 0.36 183 0027

MEMC ELECTRONICMATERIALS INC 9.49 2.62 11.83 7.82 4.41 

183 0076 GENERAL MOTORS LLC 100.28 0.27 0.31 270.49 35.91 26.16 183 0077 O'FALLON CASTING LLC 1.55 0.96 1.85 0.14 0.14 183 0129

WOODBRIDGECORPORATION 0.00 0.00 0.00 0.01 0.00 
41 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

183 0131

SUPERIOR HOMEPRODUCTS INC 0.00 0.01 0.14 0.00 

183 0184 TRUE MANUFACTURING CO 1.14 0.00 3.43 0.29 0.29 183 6003 LAMI WOOD PRODUCTS 0.00 0.00 186 0001 MISSISSIPPI LIME COMPANY 12,394.15 0.01 3,630.41 1,251.25 576.74 186 0022 TOWER ROCK STONE CO 14.39 0.04 186 0024 CENTERPOINT ENERGY 5.62 0.00 49.16 0.36 0.36 186 0035

LHOIST NORTH AMERICA OF

MISSOURI 25.74 0.01 1,262.89 125.10 36.65 

186 0044 HOLCIM (US) INC 943.31 0.01 54.27 1,975.58 429.35 194.89 187 0001

LEAD BELT MATERIALS CO

INC 15.55 0.00 0.00 4.81 8.19 0.39 

187 0002 VALLEY MINERALS, LLC 28.02 57.91 47.01 10.03 187 0006

IRON MOUNTAIN TRAP

ROCK CO 17.17 0.00

187 0017 PIRAMAL GLASS USA INC 4.65 3.31 363.24 93.08 45.72 187 0048

SIEGEL‐ROBERTAUTOMOTIVE 0.25 7.73 4.10 0.10 0.00 

187 0054

LEAD BELT MATERIALS CO

INC 6.59 0.00 0.00 5.47 3.88 0.36 

187 0072 BASE ROCK MINERALS INC 0.99 0.00 2.98 12.54 2.21 187 0075

FARMINGTON LIGHT &

POWER 0.51 0.01 1.20 0.04 0.03 

189 0010 AMEREN MISSOURI 3,843.21 1.13 4,789.24 458.51 171.92 189 0017

FRED WEBER, INC ‐ NORTH

STONE 25.91 1.84

189 0020 MONSANTO WORLD 13.41 0.00 0.50 22.23 1.23 0.34 
42 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

HEADQUARTERS

189 0023 AMEREN MISSOURI 0.07 0.00 1.00 0.05 0.00 189 0032 MONSANTO 15.41 0.44 18.89 1.20 1.20 189 0035

ROCKWOOD PIGMENTS NA

INC 7.89 0.00 0.35 11.26 3.34 0.23 

189 0042 WASHINGTON UNIVERSITY 16.59 0.00 0.10 20.43 14.34 1.54 189 0057 ST. LOUIS POST‐DISPATCH 0.23 0.00 0.27 0.02 0.01 189 0064

SUNNEN PRODUCTSCOMPANY 1.09 0.04 1.30 0.10 0.02 

189 0065

ST. LOUIS AIRPORT

AUTHORITY 8.46 0.00 0.31 13.22 12.00 0.29 

189 0069

THE QUIKRETE COMPANIES,

INC. 0.99 0.00 0.04 1.18 10.66 0.00 

189 0111

MISSOURI ASPHALTPRODUCTS, LLC 10.29 0.00 3.09 1.99 0.06 

189 0141

ENERGY PETROLEUM

COMPANY 

189 0208 PRINTPACK INC 3.48 0.13 4.15 0.32 0.08 189 0217

METROPOLITAN ST. LOUIS

SEWER DISTRICT 275.24 0.02 467.90 44.39 3.76 1.60 

189 0226 GREIF‐FENTON 1.45 0.00 1.72 0.13 0.00 189 0230 THE BOEING COMPANY 20.00 0.00 0.70 24.08 4.55 2.15 189 0238

ST. LOUIS LITHOGRAPHING

COMPANY 

189 0275 BUSSEN QUARRIES INC 9.27 0.38189 0276 RUPRECHT QUARRY 0.05 0.00189 0281 BFI MISSOURI PASS 65.11 3.47 1.48 1.48 
43 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

LANDFILL

189 0282 CENVEO ST. LOUIS 0.15 0.01 0.18 0.01 0.00 189 0308 IESI MO CHAMP LANDFILL 199.09 10.62 9.84 4.94 189 0310

ADVANCED DISPOSALSERVICES 121.20 6.46 3.57 2.83 

189 0312 BRIDGETON LANDFILL, LLC 216.66 11.56 4.91 4.91 189 0315 FOL TAPE LLC 0.00 0.00 0.00 0.00 189 0317 PRO‐TECT MFG INC 189 0318 ST. MARYS HEALTH CENTER 5.34 0.03 6.44 0.48 0.12 189 0327 CAMIE‐CAMPBELL INC 189 1012 BELT SERVICE CORP 0.00 0.00 0.00 0.97 0.00 189 1029

SSM DEPAUL HEALTHCENTER 5.48 0.00 0.03 5.54 0.52 0.51 

189 1097 REICHHOLD, INC 3.85 0.15 4.58 1.14 0.17 189 1101 ST. LUKE'S HOSPITAL 5.32 0.04 6.43 0.13 0.13 189 1205

MSD, MISSOURI RIVERWWTP 7.83 103.16 89.31 0.27 0.27 

189 1210

MSD, COLDWATER CREEK

WWTP 0.00 90.61 0.00 0.00 0.00 

189 1226

SIMPSON CONSTRUCTION

MATERIALS LLC 19.17 0.00 5.68 22.85 0.70 

189 1248

FRED WEBER INC. ‐ SOUTH

ASPHALT (BATCH) 20.56 1.40 1.59 0.01 

189 1249

FRED WEBER INC ‐ NORTH

ASPHALT H AND B 33.57 4.64 2.01 0.00 

189 1250

FRED WEBER INC. ‐ NORTH

ASPHALT B‐G 15.01 1.18 0.64 0.00 
44 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

189 1489

GKN AEROSPACE NORTH

AMERICA, INC. 15.46 0.59 8.10 14.23 12.26 

189 1516

J.D. STREETT AND

COMPANY INC 

189 1520 F AND S PRINTING 195 0004 CONAGRA FOODS 5.22 0.00 0.20 7.29 6.32 0.47 195 0010

MARSHALL MUNICIPALUTILITIES 13.02 0.01 0.06 151.36 38.47 36.76 

195 0046 MID‐MISSOURI ENERGY LLC 62.43 58.98 43.55 10.09 201 0003 TETRA PAK MATERIALS 0.25 0.00 0.30 0.02 0.02 201 0017 SIKESTON POWER STATION 3,253.34 0.01 2,181.60 566.45 467.53 201 0018

ENTERPRISE REFINED

PRODUCTS COMPANY LLC 

201 0021

HAVCO WOOD PRODUCTS

INC 72.63 0.00 0.00 26.63 34.73 7.02 

201 0073

CROWDER GIN COMPANYINC 0.03 0.22 8.32 0.24 

201 0099

TEXAS EASTERNTRANSMISSION LP 17.14 391.43 1.84 1.84 

201 0102 MANAC TRAILERS USA INC 0.00 0.00 1.18 0.00 201 0110

CONSTRUCTION TRAILER

SPECIALISTS INC 0.00 0.00 

201 8001

CONSOLIDATED GRAIN AND

BARGE CO 0.32 1.50 1.59 0.12 

203 0005

HARDWOODS OF MISSOURI

LLC 7.79 0.00 6.36 1.84 0.23 

205 0010

CERRO FLOW PRODUCTSLLC 97.15 4.29 0.21 0.00 

205 0011 SHELBINA POWER PLANT 0.65 3.76 0.10 0.10 
45 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

207 0007 AMES TRUE TEMPER INC 11.89 1.31 6.90 3.45 207 0008 J. P. ROSS COTTON CO INC 0.07 0.50 23.80 0.45 207 0014

NESTLE PURINA PETCARE

COMPANY 38.26 0.00 59.20 25.64 13.73 

207 0018

STODDARD COUNTYCOTTON CO 0.21 0.24 24.45 0.72 

207 0019 W. W. WOOD PRODUCTS 0.39 0.00 2.28 8.86 0.07 207 0062

LEMONS SANITARY

LANDFILL 75.23 0.00 4.01 14.91 3.03 

207 0064 ESSEX POWER PLANT 0.06 2.87 0.60 0.60 209 0007

TABLE ROCK ASPHALTCONSTR CO INC 5.99 0.00

213 0003

TABLE ROCK ASPHALTCONSTR CO INC 0.57 1.03 5.36 0.00 

213 0007 ROYAL OAK ENTERPRISES 20.48 0.00 7.51 19.64 6.98 213 0048 COLLEGE OF THE OZARKS 4.35 0.00 0.12 5.54 1.90 0.04 215 0026

DAIRY FARMERS OF

AMERICA INC 6.55 0.00 0.00 7.79 0.60 0.59 

215 0060 WOODPRO CABINETRY INC 1.55 0.17 0.32 0.00 217 0004 3M COMPANY 23.43 27.91 2.12 0.00 217 0034

KANSAS CITY POWER AND

LIGHT CO 0.00 0.00 0.66 0.01 0.01 

217 0043 ADM 8.59 0.00 8.55 13.09 7.49 219 0013 SAF‐HOLLAND USA 0.00 1.15 0.00 219 0036 GREIF PACKAGING LLC 0.09 0.00 0.11 0.01 0.00 219 0038 CASCADES PLASTICS INC 0.00 0.00 
46 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

221 0008

RED WING SHOE COMPANY

INC 

221 0018

BUCKMAN LABORATORIESINC 2.05 0.08 2.44 0.19 0.19 

221 0022

PURCELL TIRE & RUBBERCOMPANY 1.18 1.40 1.06 0.44 

221 0031 IESI CORPORATION 11.19 0.60 2.01 0.25 225 0026 HUTCHENS INDUSTRIES 0.16 0.04 0.48 0.59 0.01 225 0040

OZARK HARDWOODPRODUCTS LLC 18.06 1.99 6.15 0.00

225 0045 UNDERCOVER INC 0.38 0.45 0.03 0.03 229 0001 HUTCHENS INDUSTRIES 0.51 0.10 1.32 2.39 0.04 229 0022

BLACK OAK RECYCLING &

DISPOSAL FACILITY 4.30 13.03 1.30 

510 0003 ANHEUSER‐BUSCH INC 76.68 31.81 467.42 181.06 158.07 510 0017 MALLINCKRODT LLC 35.03 0.00 1.45 42.88 12.29 11.40 510 0027 PRECOAT METALS 8.06 9.60 0.73 0.00 510 0031 ADM GRAIN COMPANY 0.38 0.46 3.66 0.61 510 0038

TRIGEN‐ST. LOUIS ENERGY

CORP 36.17 0.00 1.73 54.87 4.73 4.73 

510 0040

WASHINGTON UNIV

MEDICAL SCHOOL 27.03 0.00 0.16 37.80 31.96 2.82 

510 0047 FRED WEBER INC 5.29 0.52 0.05 0.00 510 0053

METROPOLITAN ST. LOUIS

SEWER DISTRICT 558.38 0.18 476.95 80.58 23.77 3.45 

510 0057 PROCTER AND GAMBLE 10.72 0.41 12.79 30.42 30.38 510 0063 THE DIAL CORPORATION 1.41 0.00 0.05 1.68 0.13 0.13 
47 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

510 0066 ELEMENTIS SPECIALTIES INC 4.06 0.15 4.84 13.74 0.32 510 0070

ICL PERFORMANCEPRODUCTS LP 23.24 0.48 7.05 12.56 1.14 

510 0096 ELANTAS PDG, INC. 3.96 0.15 5.39 0.40 0.40 510 0097 U S PAINT CORPORATION 3.07 0.00 510 0118 JW ALUMINUM 12.93 0.00 0.00 21.65 38.23 36.64 510 0161 POLY ONE CORPORATION 0.00 0.00 510 0162 MARQUETTE TOOL AND DIE 510 0175

ST. LOUIS METALLIZING

COMPANY 0.08 0.29 0.33 0.00 

510 0179 ITALGRANI ELEVATOR USA 0.31 0.01 0.37 28.42 0.78 510 0204 BARNES JEWISH HOSPITAL 2.67 0.00 11.66 0.61 0.00 510 0269 SENSIENT COLORS LLC 2.18 0.08 2.62 0.38 0.20 510 0391

HERMANN OAK LEATHER

CO 0.00 0.00 0.00 0.00 

510 0468

LANGE‐STEGMANNCOMPANY 1.64 0.06 1.95 11.69 0.04 

510 0697 SIGMA ‐ ALDRICH MFG LLC 8.85 0.17 9.95 0.76 0.35 510 0808

CHEMISPHERECORPORATION 

510 0809 PQ CORPORATION (THE) 9.47 0.00 0.51 92.55 32.96 32.56 510 0938 INTERSTATE BRANDS CORP 2.56 0.05 3.56 0.23 0.23 510 1055 GOODWIN PRINTING CO. 510 1077

MID‐WEST INDUSTRIALCHEMICAL 0.00 0.00 0.00 2.14 0.00 
48 

County

Number

Plant

Number Plant Name CO Lead NH3 NOx PM10‐PRI PM2.5‐PRI 

510 1093 BRENNTAG MID‐SOUTH INC 0.00 0.00 0.00 0.00 510 1123 U. S. RINGBINDER LP 0.00 0.00 510 1280 ST. LOUIS POST DISPATCH 0.44 0.00 0.52 0.04 0.01 510 1370

NATIONAL GEOSPATIAL‐INTELLIGENCE AGENCY 1.31 0.00 0.04 1.63 0.15 0.13 

510 1407

SOUTHERN METALPROCESSING 1.68 4.19 0.26 0.26 

510 1460

ALLIED HEALTH CARE

PRODUCTS 0.00 0.00 0.00 0.00 

510 1505 ENERGY CENTER (THE) 9.77 0.00 0.37 11.77 0.89 0.89 510 1556 CONNECTOR CASTINGS 0.00 0.00 0.01 0.11 4.65 0.53 510 1642

J S ALBERICICONSTRUCTION 0.00 0.00 1.61 0.00 

510 2300

SUPERIOR SOLVENT AND

CHEMICAL 

510 2378 HERTZ ST. LOUIS ONE, LLC 304.66 0.00 0.00 197.04 3.98 1.69 510 2433 NEW WORLD PASTA 3.30 0.00 0.13 3.93 0.80 0.80 510 2711 ST. LOUIS UNIVERSITY 6.02 0.04 7.17 0.54 0.54 

Statewide Total 113,272 42 1,642 92,721 16,727 9,834 
49 

Table 3 Point Source Ozone Season Day Emissions (pounds per day) 

County

Number

Plant

Number Plant Name CO NOx VOC

071 0003 AMEREN MISSOURI                           15,093.09 55,437.04 1,810.64

071 0014 CANAM STEEL CORP                          0.00 12.01 361.18

071 0020 STEELWELD EQUIPMENT CO INC       0.84 1.00 42.02

071 0031

GRAPHIC PACKAGING

INTERNATIONAL           0.00 0.00 206.04

071 0068 MERAMEC INDUSTRIES INC                0.21 1.00 410.79

071 0080 SPARTAN SHOWCASE INC                   0.00 0.00 77.43

071 0087 BULL MOOSE TUBE COMPANY           1.65 2.86 200.43

071 0131

SULLIVAN PRECISION METAL

FINISHING INC    0.00 0.00 27.38

071 0132 SPORLAN VALVE DIVSION                   184.35

071 0151 AEROFIL TECHNOLOGY INC                 0.20 1.00 240.82

071 0153 MAGNET LLC                                61.31

071 0157 PLAZE INCORPORATED                       2.52 12.00 496.22

071 0173

HENNIGES AUTOMOTIVE SEALING

SYSTEMS NA    2.80 41.83

071 0230 PLAZE, INC                                3.36 4.00 112.78

099 0002

RIVER CEMENT CO. DBA BUZZI

UNICEM USA     6,422.65 9,649.45 968.79

099 0003 DOE RUN COMPANY                          98.81 52.90 9.35

099 0011 UNION PACIFIC RAILROAD CO            9.60 12.82 243.36

099 0012 TRAUTMAN QUARRY                          0.00

099 0014 DOW CHEMICAL COMPANY, THE       0.00 0.00 6.69

099 0016 AMEREN MISSOURI                           7,348.02 20,366.24 881.15

099 0044

METAL CONTAINER

CORPORATION               99.17 118.06 542.64

099 0052 ENGINEERED COIL COMPANY             0.00 0.00 36.73

099 0068 SAINT‐GOBAIN CONTAINERS INC       50.17 588.43 145.12

099 0103 BUSSEN QUARRIES INC                      0.00

099 0111 CARONDELET CORPORATION             14.93 28.50 200.12

099 0114 AERO METAL FINISHING                     11.83 11.91
50 

County

Number

Plant

Number Plant Name CO NOx VOC

183 0001 AMEREN MISSOURI                           4,858.89 48,695.56 1,070.67

183 0004 FRED WEBER INC                            229.28 14.33 4.70

183 0010 BOEING COMPANY                            4.20 5.00 44.40

183 0019 ST. JOSEPH HEALTH CENTER               20.48 60.32 4.58

183 0027

MEMC ELECTRONIC MATERIALS

INC             51.34 64.28 28.05

183 0076 GENERAL MOTORS LLC                       439.66 1,153.77 4,216.30

183 0077 O'FALLON CASTING LLC                     6.72 8.00 132.00

183 0129 WOODBRIDGE CORPORATION           0.00 0.00 692.21

183 0131 SUPERIOR HOME PRODUCTS INC      0.00 0.00 55.78

183 0184 TRUE MANUFACTURING CO               4.20 5.00 204.65

183 6003 LAMI WOOD PRODUCTS                      30.28

189 0010 AMEREN MISSOURI                           24,250.76 29,073.78 644.43

189 0020

MONSANTO WORLD

HEADQUARTERS               33.74 72.70 2.52

189 0023 AMEREN MISSOURI                           1.51 21.99 0.53

189 0032 MONSANTO                                  131.95 459.02 12.56

189 0035 ROCKWOOD PIGMENTS NA INC         42.21 60.00 3.62

189 0042 WASHINGTON UNIVERSITY                 270.19 959.88 69.88

189 0057 ST. LOUIS POST‐DISPATCH                  1.68 2.00 70.12

189 0064 SUNNEN PRODUCTS COMPANY         3.36 4.00 45.19

189 0065 ST. LOUIS AIRPORT AUTHORITY         34.83 99.43 88.54

189 0069 THE QUIKRETE COMPANIES, INC.      8.40 10.00 0.55

189 0111

MISSOURI ASPHALT PRODUCTS,

LLC            152.70 45.81 3.13

189 0141 ENERGY PETROLEUM COMPANY       43.10

189 0208 PRINTPACK INC                             21.84 26.00 572.25

189 0217

METROPOLITAN ST. LOUIS SEWER

DISTRICT     1,693.84 273.20 99.55

189 0226 GREIF‐FENTON                              12.60 15.00 341.57

189 0230 THE BOEING COMPANY                       74.72 155.56 274.17
51 

County

Number

Plant

Number Plant Name CO NOx VOC

189 0238

ST. LOUIS LITHOGRAPHING

COMPANY           139.01

189 0281 BFI MISSOURI PASS LANDFILL             360.00 19.20 12.45

189 0282 CENVEO ST. LOUIS                          0.00 0.00 0.00

189 0308 IESI MO CHAMP LANDFILL                  1,095.00 58.40 52.49

189 0310 ADVANCED DISPOSAL SERVICES        667.50 35.60 23.50

189 0312 BRIDGETON LANDFILL, LLC                  1,192.50 63.60 40.26

189 0315 FOL TAPE LLC                              0.00 0.00 197.24

189 0317 PRO‐TECT MFG INC                          180.00

189 0318 ST. MARYS HEALTH CENTER                21.84 26.00 1.43

189 0327 CAMIE‐CAMPBELL INC                       27.40

189 1012 BELT SERVICE CORP                         0.00 0.00 320.10

189 1029 SSM DEPAUL HEALTH CENTER            36.96 36.70 2.42

189 1097 REICHHOLD, INC                            21.00 25.00 180.01

189 1101 ST. LUKE'S HOSPITAL                       29.40 35.00 1.92

189 1205 MSD, MISSOURI RIVER WWTP           45.17 487.11 61.58

189 1210 MSD, COLDWATER CREEK WWTP      0.00 0.00 0.88

189 1226

SIMPSON CONSTRUCTION

MATERIALS LLC        278.91 82.69 26.41

189 1248

FRED WEBER INC. ‐ SOUTH

ASPHALT (BATCH)   316.13 21.10 6.48

189 1249

FRED WEBER INC ‐ NORTH

ASPHALT H AND B    474.69 65.20 20.96

189 1250

FRED WEBER INC. ‐ NORTH

ASPHALT B‐G       166.24 13.19 0.05

189 1489

GKN AEROSPACE NORTH

AMERICA, INC.         40.32 23.25 366.71

189 1516 J.D. STREETT AND COMPANY INC      84.67

189 1520 F AND S PRINTING                          381.50

510 0003 ANHEUSER‐BUSCH INC                       468.57 2,857.63 1,313.26

510 0017 MALLINCKRODT LLC                          239.92 443.05 364.28

510 0027 PRECOAT METALS                            63.00 75.00 395.69
52 

County

Number

Plant

Number Plant Name CO NOx VOC

510 0031 ADM GRAIN COMPANY                       2.52 3.00 0.16

510 0038 TRIGEN‐ST. LOUIS ENERGY CORP       136.92 181.60 10.01

510 0040

WASHINGTON UNIV MEDICAL

SCHOOL            53.63 234.42 16.35

510 0047 FRED WEBER INC                            51.93 4.62 1.07

510 0053

METROPOLITAN ST. LOUIS SEWER

DISTRICT     10,833.63 1,849.17 526.63

510 0057 PROCTER AND GAMBLE                       184.01 219.20 24.35

510 0063 THE DIAL CORPORATION                     6.72 8.00 0.44

510 0066 ELEMENTIS SPECIALTIES INC               22.68 27.00 402.73

510 0070 ICL PERFORMANCE PRODUCTS LP     131.32 48.28 6.63

510 0096 ELANTAS PDG, INC.                         21.32 28.22 41.18

510 0097 U S PAINT CORPORATION                   169.05

510 0118 JW ALUMINUM                               71.65 120.00 1,546.71

510 0161 POLY ONE CORPORATION                   2.12

510 0162 MARQUETTE TOOL AND DIE               40.00

510 0175

ST. LOUIS METALLIZING

COMPANY             0.00 0.00 20.00

510 0179 ITALGRANI ELEVATOR USA                  2.52 3.00 0.16

510 0204 BARNES JEWISH HOSPITAL                  43.54 196.73 12.30

510 0269 SENSIENT COLORS LLC                       8.40 10.14 0.58

510 0391 HERMANN OAK LEATHER CO              0.00 0.00 57.26

510 0468 LANGE‐STEGMANN COMPANY          9.24 11.00 0.62

510 0697 SIGMA ‐ ALDRICH MFG LLC                 45.36 49.50 52.73

510 0808 CHEMISPHERE CORPORATION           75.16

510 0809 PQ CORPORATION (THE)                     52.65 509.24 23.60

510 0938 INTERSTATE BRANDS CORP                15.96 22.60 381.82

510 1055 GOODWIN PRINTING CO.                    65.64

510 1077

MID‐WEST INDUSTRIAL

CHEMICAL              0.00 0.00 39.60

510 1093 BRENNTAG MID‐SOUTH INC               0.00 0.00 30.41
53 

County

Number

Plant

Number Plant Name CO NOx VOC

510 1123 U. S. RINGBINDER LP                       38.17

510 1280 ST. LOUIS POST DISPATCH                  0.84 1.00 0.05

510 1370

NATIONAL GEOSPATIAL‐

INTELLIGENCE AGENCY   4.66 10.04 0.71

510 1407 SOUTHERN METAL PROCESSING        12.19 30.49 6.47

510 1460 ALLIED HEALTH CARE PRODUCTS      0.00 0.00 19.70

510 1505 ENERGY CENTER (THE)                       26.51 36.08 2.13

510 1556 CONNECTOR CASTINGS                       0.00 0.99 6.54

510 1642 J S ALBERICI CONSTRUCTION              0.00 0.00 54.38

510 2300

SUPERIOR SOLVENT AND

CHEMICAL             18.03

510 2378 HERTZ ST. LOUIS ONE, LLC                 1,970.52 1,277.58 16.94

510 2433 NEW WORLD PASTA                           18.48 22.00 1.21

510 2711 ST. LOUIS UNIVERSITY                      32.76 39.00 2.14

Areawide Total 80,771.43 176,897.19 23,988.89
54 

8.0 Nonpoint Source Inventory

Nonpoint emissions estimates were developed by EPA for the 2011 inventory.  Where appropriate,

Missouri accepted these estimates with no modifications and has provided the documentation

generated by EPA.   

When it was determined that emissions from Missouri may be substantially different than EPA

estimates, state specific information was used to produce more accurate data.  For some source

categories, this was done by modifying the numbers produced by EPA.  In other instances, estimates

were developed by DNR.

Additional nonpoint emissions estimates were developed by contractors hired by CenSARA (Central

States Air Resources Agencies).  The following source categories used emissions estimates developed by

CenSARA contractors:  Agricultural Pesticide, Industrial, Commercial, Institutional, and Residential Fuel

Combustion, and Oil and Gas Drilling.

The different documentation sources vary in style and organization.  Each subsection was left in its

original formatting.   

This 2011 inventory does not include biogenic or geogenic emissions.  The inventory does not include

the nonpoint categories for wildfire which are in the event inventory.   

8.1 Agricultural Pesticide

CenSARA hired a contractor to develop Agricultural Pesticide emissions for the region.  Documentation

of the methods used can be found in Appendix B‐2.

   
55 

8.2 Agricultural Tilling

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  The documentation

below was developed by EPA.  Subsection g contains Missouri’s audit of EPA’s estimate.   

a. Source Category Description

Fugitive dust emissions from agricultural tilling include the airborne soil particulate emissions produced during the

preparation of agricultural lands for planting.  Fugitive dust emissions from agricultural tilling were estimated for

PM10‐PRI, PM10‐FIL, PM2.5‐PRI, and PM2.5‐FIL. Since there are no PM‐CON emissions for this category, PM10‐PRI

emissions are equal to PM10‐FIL emissions and PM2.5‐PRI emissions are equal to PM2.5‐FIL.

For this source category, the following SCC was assigned:

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

2801000003

Miscellaneous Area

Sources

Agriculture Production ‐

Crops Agriculture ‐ Crops Tilling

Particulate emissions from agricultural tilling were computed by multiplying a crop specific emissions factor by an

activity factor, as discussed below.

b. Emission Factor Equation

The county‐level emissions factors for agricultural tilling (in lbs per acre) are specific to the crop and tilling type and

were calculated using the following equation:1,2

EF = 4.8 × k × s

0.6 × pcrop,tilling type

where:

k = dimensionless particle size multiplier (PM10 = 0.21; PM2.5 = 0.042),

s = silt content of surface soil (%),

p = number of passes or tillings in a year for a given crop and tillage type.

The silt content of surface soil is defined as the percentage of particles (mass basis) of diameter smaller than 75

micrometers (μm) found in the soil to a depth of 10 centimeters (cm).  Silt contents were assigned by comparing

the United States Department of Agriculture (USDA) surface soil survey map to a USDA county map and assigning a

soil type to each county.  The table below shows silt content assumed for each soil type.
56 

Silt Content for Soil Types in USDA Surface Soil Map

Soil Type Silt Content (%)

Silt Loam 52

Sandy Loam 33

Sand 12

Loamy Sand 12

Clay 29

Clay Loam 29

Organic Material 10‐82

Loam 40

The table below shows the number of passes or tillings in a year for each crop for conservation use and

conventional use.3

   No till, mulch till, and ridge till tillage systems are classified as conservation use, while 0 to 15

percent residue and 15 to 30 percent residue tillage systems are classified as conventional use.  

Number of Passes or Tillings per Year.

Crop Conservation Use Conventional

Use

Barley 3 5

Beans and Peas 3 3

Canola 3 3

Corn 2 6

Cotton 5 8

Cover 1 1

Fallow 1 1

Fall‐seeded Wheat 3 5

Forage 3 3

Hay 3 3

Oats 3 5

Peanuts 3 3

Permanent Pasture 1 1

Potatoes 3 3

Rice 5 5

Rye 3 5

Sorghum 1 6

Soybeans 1 6

Spring Wheat 1 4

Sugarbeets 3 3

Sugarcane 3 3

Sunflowers 3 3

Tobacco 3 3
57 

c. Activity

The basis of agricultural tilling emission estimates was the number of acres of crops tilled in each county by crop

type and tillage type.  These data were obtained from the 2008 National Crop Residue Management Survey,

developed by the Conservation Technology Information Center (CTIC).4

  Data summaries are available on the CTIC

web site at: http://www.ctic.purdue.edu/CRM/. The five types of tilling for which emission estimates were

calculated are:

Conservation Till       Conventional Till

No till/strip till       0 to 15 percent residue till (Intensive Till)

Mulch till       15 to 30 percent residue till (Reduced till)

Ridge till

Note that the 2008 activity data for highly erodible land (HEL) overlap the other crop‐type‐specific data.  

Therefore, the HEL and Treated HEL data are not included in the calculation of emissions estimates. A summary of

national‐level acres planted in 2008 for each tilling type are presented in the table below. Due to data

nondisclosure agreements with CTIC, the EPA cannot release the county‐level tillage data by crop type.

Acres Planted by Tillage Type, Fallow and Pasture in 2008

Tillage System Actual National Number of

Acres Planted in 2008

(million acres)

Conservation

No‐Till/Strip Till 74.86

Ridge‐Till 2.32

Mulch‐Till   49.43

Conventional

Reduced‐Till  (15‐30% cover) 63.31

Intensive‐Till  (<15% cover) 105.13

Total 295.05

The following equation was used to determine the emissions from agricultural tilling for 2008.1,2   The county‐level

activity data are the acres of land tilled for a given crop and tilling type.  The equation is adjusted to estimate PM10

and PM2.5 emissions using the following parameters:  a particle size multiplier, the silt content of the surface soil,
58 

the number of tillings per year for a given crop and tilling type, and the acres of land tilled for a given crop and

tilling type.

E = Σc × k × s

0.6 × pcrop,tilling type × acrop,tilling type

where:    E = PM10‐FIL or PM2.5‐FIL emissions

c = constant 4.8 lbs/acre‐pass

k = dimensionless particle size multiplier (PM10=0.21;  PM2.5=0.042)

s = percent silt content of surface soil, defined as the mass fraction of particles smaller than 75

μm diameter found in soil to a depth of 10 cm  

p = number of passes or tillings in a year

a = acres of land tilled (activity data)

e. Controls

No controls were accounted for in the emission estimations.

f. 2011 Updates

Since the CTIC has not prepared an updated National Crop Residue Management (CRM) Survey for 2011, activity

data for this category were updated using growth factors derived from state‐level USDA statistics on various crop

types.5 These growth factors were then matched by state and crop type and applied to the 2008 activity data at

the county level. See the table below for how USDA and CRM categories were matched.

Crosswalk between Crop Residue Management Category and USDA Data

CRM Category USDA Data Items

Barley BARLEY ‐ ACRES HARVESTED

Beans and Peas SUM OF BEANS AND PEAS HARVESTED

Canola CANOLA ‐ ACRES HARVESTED

Corn CORN, GRAIN ‐ ACRES HARVESTED
59 

CRM Category USDA Data Items

Cotton COTTON ‐ ACRES HARVESTED

Cover TOTAL ACRES HARVESTED

Fallow TOTAL ACRES HARVESTED

Forage FORAGE, ALFALFA, HAY ‐ ACRES HARVESTED

Hay FORAGE (EXCL ALFALFA), HAY ‐ ACRES HARVESTED

Oats OATS ‐ ACRES HARVESTED

Peanuts PEANUTS ‐ ACRES HARVESTED

Permanent Pasture TOTAL ACRES HARVESTED

Potatoes POTATOES ‐ ACRES HARVESTED

Rice RICE ‐ ACRES HARVESTED

Rye RYE ‐ ACRES HARVESTED

Sorghum SORGHUM, GRAIN ‐ ACRES HARVESTED

Soybeans SOYBEANS ‐ ACRES HARVESTED

Sugarbeets SUGARBEETS ‐ ACRES HARVESTED

Sugarcane SUGARCANE, SUGAR & SEED ‐ ACRES HARVESTED

Sunflower SUNFLOWER ‐ ACRES HARVESTED

Tobacco TOBACCO ‐ ACRES HARVESTED

Wheat WHEAT ‐ ACRES HARVESTED

Winter Wheat WHEAT, WINTER ‐ ACRES HARVESTED

In addition, for those categories where a specific state/crop combination match was not made, the number of

acres tilled were grown using a growth factor based on the total number of farm acres in those states.  

g. QA/QC

Missouri audited EPA’s estimate by:
60 

1. Data:  Efforts were made to locate references 1 and 2 below in order to verify the following equations:  

EF = 4.8 × k × s

0.6 × pcrop,tilling type

E = Σ c × k × s

0.6 × pcrop,tilling type × acrop,tilling type and

However, the electronic versions of the references were unable to be located.  In the 4th edition of AP‐42,

the emission factor for PM10 was calculated by taking 1.01*s0.6, which is quite close to the emission factor

from the 1st equation above, when 0.21 is used for the k‐value as is specified in the documentation (1.008 *

s

0.6), therefore the equations seem appropriate.

The Silt Content Table lists the silt content of various soil classifications.  The silt contents for Missouri

counties appear to be one of two different values, either 28.8 or 52.0.  The Silt Content Table indicates,

that 52.0 is the silt content for silt loam soil; however no soil classification in the Silt Content Table has a silt

content of 28.8.  Both clay and clay loam have values of 29% silt content in the Silt Content Table, so it’s

assumed that the counties in Missouri that were assigned 28.8% silt content have soil classification of one

of these two categories.  Missouri would suggest revising the Silt Content Table, if the value of 28.8% is

being used for silt content instead of 29.0%.  Also, the method of picking one soil classification for each

county is acceptable if the majority of the cropland in the county is that particular soil classification, but

this may not always be the case.  Although acceptable, it is also noted that it rarely would be the case that

all cropland in a county is of the same soil classification, and for future NEIs if resources permit, Missouri

suggests using weighted percentages for soil classifications to develop the silt content percentage for

each county, as this would likely yield more accurate values.

USDA quick stats (reference 5) were checked to determine how reasonable the values were for the number

of acres tilled in the entire state.  USDA data indicates that in 2011 a total of 13,338,000 acres of field crops

were harvested.  Adding each individual county in the NEI worksheets gives a total of 10,383,135.  These

values are roughly 25% apart from each other, which raises some concerns, but Missouri is unable to check

the data used in the worksheets for accuracy because the CRM county level data is not publicly available.  

Nonetheless, Missouri accepts EPA’s data and has no changes to the NEI results for this source category.

2. Math:  In the emissions worksheet the math for several counties was manually spot‐checked by multiplying

the emission factor by the number of acres tilled and all numbers that were checked manually agreed with

the numbers in the table.  However, due to the fact that the CRM data is not publicly available, Missouri

was unable to verify the calculations used to develop the lbs./acre emission factors for each county.  If

resources permit for future NEIs, Missouri suggests that EPA release the actual calculations for the

emissions factor for at least one county in each state so that they can be reviewed and verified at the

state level during the QA process.  Nonetheless, Missouri accepts EPA’s calculations and has no changes to

the NEI results for this source category.

3. Method:  Growth of 2008 crop harvest numbers to 2011 seems like a reasonable method in theory.  

However, the method of growing 2008 emissions to 2011 emissions based on comparing the 2008 CRM

data to the 2011 USDA data could be improved upon by comparing data sets from the same source to

ensure consistency in the data sources when developing the growth factors.  A quick comparison of 2008

USDA data to 2011 USDA data shows that total field crop acres harvested in Missouri decreased by roughly

350,000 acres (~2.5%), yet when comparing the 2008 emissions sector Agriculture – Crops and Livestock

Dust to the 2011 NEI for this agriculture‐tilling category you will see that emissions in 2011 are calculated at

about 1.8% higher than the emissions that were calculated in 2008.  Comparing the 2008 and 2011 county

level acres tilled data in EPA’s worksheets for these two NEIs shows an increase in total acres tilled from
61 

2008 to 2011 for Missouri, which corresponds to the slight increase in the emission estimate for 2011.  This

increase in total tilled acres is an artifact of the methodology used to create the growth factors by

comparing data from two different sources.  Nonetheless, Missouri accepts EPA’s methodology and has no

changes to the NEI results for this source category.

h.  References

1. The Role of Agricultural Practices in Fugitive Dust Emissions, T.A. Cuscino, Jr., et al., California Air

Resources Board, Sacramento, CA, June 1981.

2. Memorandum from Chatten Cowherd of Midwest Research Institute, to Bill Kuykendal of the U.S.

Environmental Protection Agency, Emission Factor and Inventory Group, and W.R. Barnard of E.H. Pechan

& Associates, Inc., September 1996.

3. Agricultural Activities Influencing Fine Particulate Matter Emissions, Woodard, Kenneth R., Midwest

Research Institute, March 1996.

4. National Crop Residue Management Survey, Conservation Technology Information Center, 2008

http://www.ctic.purdue.edu/CTIC/CTIC.html .  

5. USDA Quickstats 2.0, http://quickstats.nass.usda.gov/, Accessed April 2012.

   
62 

8.3 Agriculture Fertilizer Application

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  EPA provided no

documentation of the category, so the data was checked for reasonableness.

List of SCCs Included:

SCC Level One Level Two Level Three Level Four

2801700001 Miscellaneous Area

Sources

Agriculture

Production ‐ Crops

Fertilizer

Application

Anhydrous Ammonia

2801700002 Miscellaneous Area

Sources

Agriculture

Production ‐ Crops

Fertilizer

Application

Aqueous Ammonia

2801700003 Miscellaneous Area

Sources

Agriculture

Production ‐ Crops

Fertilizer

Application

Nitrogen Solutions

2801700004 Miscellaneous Area

Sources

Agriculture

Production ‐ Crops

Fertilizer

Application

Urea

2801700005 Miscellaneous Area

Sources

Agriculture

Production ‐ Crops

Fertilizer

Application

Ammonium Nitrate

2801700006 Miscellaneous Area

Sources

Agriculture

Production ‐ Crops

Fertilizer

Application

Ammonium Sulfate

2801700007 Miscellaneous Area

Sources

Agriculture

Production ‐ Crops

Fertilizer

Application

Ammonium

Thiosulfate

2801700010 Miscellaneous Area

Sources

Agriculture

Production ‐ Crops

Fertilizer

Application

N‐P‐K (multi‐grade

nutrient fertilizers)

2801700011 Miscellaneous Area

Sources

Agriculture

Production ‐ Crops

Fertilizer

Application

Calcium Ammonium

Nitrate

2801700012 Miscellaneous Area

Sources

Agriculture

Production ‐ Crops

Fertilizer

Application

Potassium Nitrate

2801700013 Miscellaneous Area

Sources

Agriculture

Production ‐ Crops

Fertilizer

Application

Diammonium

Phosphate

2801700014 Miscellaneous Area

Sources

Agriculture

Production ‐ Crops

Fertilizer

Application

Monoammonium

Phosphate

2801700015 Miscellaneous Area

Sources

Agriculture

Production ‐ Crops

Fertilizer

Application

Liquid Ammonium

Polyphosphate

2801700099 Miscellaneous Area

Sources

Agriculture

Production ‐ Crops

Fertilizer

Application

Miscellaneous

Fertilizers

List of Pollutants:

SourceClassificationCode PollutantCode

2801700001 NH3

2801700002 NH3

2801700003 NH3

2801700004 NH3
63 

SourceClassificationCode PollutantCode

2801700005 NH3

2801700006 NH3

2801700007 NH3

2801700010 NH3

2801700011 NH3

2801700012 NH3

2801700013 NH3

2801700014 NH3

2801700015 NH3

2801700099 NH3

List of Missouri Counties Included

All but one of Missouri’s 115 counties are included in the estimate file.  St. Louis City, an urban

area, is not included as it has no agricultural activity.

List of Emission Factors

The activity for each SCC and county is listed in the “Reporting Period” table.  Combined with

the “Emissions” table total emissions field, the emission factor for each SCC can be calculated (it

is not explicitly given).

SCC SCC Level Four EF EF

Numerator

EF

Denominator

2801700001 Anhydrous Ammonia 0.0486 KG TON

2801700003 Nitrogen Solutions 0.0971 KG TON

2801700004 Urea 0.182 KG TON

2801700005 Ammonium Nitrate 0.0243 KG TON

2801700006 Ammonium Sulfate 0.121 KG TON

2801700007 Ammonium Thiosulfate 0.0304 KG TON

2801700010 N‐P‐K (multi‐grade nutrient fertilizers) 0.0243 KG TON

2801700011 Calcium Ammonium Nitrate 0.0243 KG TON

2801700013 Diammonium Phosphate 0.0607 KG TON

2801700014 Monoammonium Phosphate 0.0607 KG TON

2801700015 Liquid Ammonium Polyphosphate 0.0607 KG TON

2801700099 Miscellaneous Fertilizers 0.0729 KG TON

   
64 

Emission Summary

SCC SCC Description 2008 NH3 kg 2011 NH3 kg Difference

Percent

Difference

2801700001 Anhydrous Ammonia

  

6,508,195.69

  

6,667,800.11

  

159,604.42 2%

2801700003 Nitrogen Solutions

  

8,222,267.30

  

5,431,111.59

  

(2,791,155.71) ‐34%

2801700004 Urea

  

19,551,950.55

  

18,886,390.18

  

(665,560.37) ‐3%

2801700005 Ammonium Nitrate

  

1,659,824.69

  

1,098,153.70

  

(561,670.99) ‐34%

2801700006 Ammonium Sulfate

  

759,576.49

  

889,572.72

  

129,996.23 17%

2801700007

Ammonium

Thiosulfate

  

41,721.99

  

34,842.65

  

(6,879.34) ‐16%

2801700010

N‐P‐K (multi‐grade

nutrient fertilizers)

  

488,699.96

  

281,237.57

  

(207,462.40) ‐42%

2801700011

Calcium Ammonium

Nitrate

  

‐   

  

355.88

  

355.88  ‐

2801700013

Diammonium

Phosphate

  

2,618,123.49

  

2,146,871.10

  

(471,252.39) ‐18%

2801700014

Monoammonium

Phosphate

  

536,826.86

  

598,113.86

  

61,287.00 11%

2801700015

Liquid Ammonium

Polyphosphate

  

60,483.64

  

72,731.82

  

12,248.18 20%

2801700099

Miscellaneous

Fertilizers

  

237,664.43

  

3,048,347.85

  

2,810,683.41 1183%

Statewide Total

  

40,685,335.09

  

39,155,529.02

  

(1,529,806.08) ‐4%

   
65 

8.4 Industrial and Commercial/Institutional (ICI) and Residential Fuel Combustion

Missouri worked with CenSARA’s contractor who built the entire nonpoint fuel combustion emissions

estimate.  Documentation is provided in Appendix B‐3. The CenSARA tool does not estimate residential

wood combustion.  Residential Wood Combustion emissions are described in section 8.23.

   
66 

8.5   Agriculture Livestock Waste

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  The documentation

below was developed by EPA.  

Source Category Description

Livestock refers to domesticated animals intentionally reared for the production of food, fiber, or other

goods or for the use of their labor. The definition of livestock in this category includes beef cattle, dairy

cattle, ducks, geese, goats, horses, poultry, sheep, and swine.

Due to resource constraints at EPA, 2011 emissions are assumed to be the same as 2008 emissions.  The

approach to calculating emissions for the assigned SCCs consisted of four general steps, as follows:

 Determining county‐level population of animals for 2007.

 For beef, dairy, poultry, and swine, apportioning animal populations to a manure

management train (MMT) for each county. Animal populations for ducks, geese, goats,

horses, and sheep were not apportioned to MMTs.

 Modifying the emission factor files provided with the CMU Ammonia Model v. 3.6 to

ensure that every county had an assigned emission factor.1

 Using the CMU Ammonia Model v. 3.6 to calculate ammonia emissions based on the

updated county‐level animal populations and emission factors.

For this source category, the following SCCs were assigned:

SCC Descriptor 2 Descriptor 4 Descriptor 7 Descriptor 8

2805001100 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Beef cattle ‐  

finishing operations

on feedlots (drylots)

Confinement

2805001200 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Beef cattle ‐  

finishing operations

on feedlots (drylots)

Manure handling

and storage

2805001300 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Beef cattle ‐  

finishing operations

on feedlots (drylots)

Land application of

manure
67 

SCC Descriptor 2 Descriptor 4 Descriptor 7 Descriptor 8

2805002000 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Beef cattle

production

composite

Not Elsewhere

Classified

2805003100 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Beef cattle ‐  

finishing operations

on pasture/range

Confinement

2805007100 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Poultry production ‐

layers with dry

manure

management

systems

Confinement

2805007300 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Poultry production ‐

layers with dry

manure

management

systems

Land application of

manure

2805008100 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Poultry production ‐

layers with wet

manure

management

systems

Confinement

2805008200 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Poultry production ‐

layers with wet

manure

management

systems

Manure handling

and storage

2805008300 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Poultry production ‐

layers with wet

manure

management

systems

Land application of

manure

2805009100 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Poultry production ‐

broilers

Confinement

2805009200 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Poultry production ‐

broilers

Manure handling

and storage
68 

SCC Descriptor 2 Descriptor 4 Descriptor 7 Descriptor 8

2805009300 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Poultry production ‐

broilers

Land application of

manure

2805010100 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Poultry production ‐

turkeys

Confinement

2805010200 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Poultry production ‐

turkeys

Manure handling

and storage

2805010300 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Poultry production ‐

turkeys

Land application of

manure

2805018000 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Dairy cattle

composite

Not Elsewhere

Classified

2805019100 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Dairy cattle ‐ flush

dairy

Confinement

2805019200 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Dairy cattle ‐ flush

dairy

Manure handling

and storage

2805019300 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Dairy cattle ‐ flush

dairy

Land application of

manure

2805021100 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Dairy cattle ‐ scrape

dairy

Confinement

2805021200 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Dairy cattle ‐ scrape

dairy

Manure handling

and storage

2805021300 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Dairy cattle ‐ scrape

dairy

Land application of

manure

2805022100 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Dairy cattle ‐ deep

pit dairy

Confinement
69 

SCC Descriptor 2 Descriptor 4 Descriptor 7 Descriptor 8

Livestock

2805022200 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Dairy cattle ‐ deep

pit dairy

Manure handling

and storage

2805022300 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Dairy cattle ‐ deep

pit dairy

Land application of

manure

2805023100 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Dairy cattle ‐

drylot/pasture dairy

Confinement

2805023200 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Dairy cattle ‐

drylot/pasture dairy

Manure handling

and storage

2805023300 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Dairy cattle ‐

drylot/pasture dairy

Land application of

manure

2805025000 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Swine production

composite

Not Elsewhere

Classified (see also

28‐05‐039, ‐047, ‐

053)

2805030000 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Poultry Waste

Emissions

Not Elsewhere

Classified (see also

28‐05‐007, ‐008, ‐

009)

2805030007 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Poultry Waste

Emissions

Ducks

2805030008 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Poultry Waste

Emissions

Geese

2805035000 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Horses and Ponies

Waste Emissions

Not Elsewhere

Classified
70 

SCC Descriptor 2 Descriptor 4 Descriptor 7 Descriptor 8

2805039100 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Swine production ‐

operations with

lagoons (unspecified

animal age)

Confinement

2805039200 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Swine production ‐

operations with

lagoons (unspecified

animal age)

Manure handling

and storage

2805039300 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Swine production ‐

operations with

lagoons (unspecified

animal age)

Land application of

manure

2805040000 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Sheep and Lambs

Waste Emissions

Total

2805045000 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Goats Waste

Emissions

Not Elsewhere

Classified

2805047100 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Swine production ‐

deep‐pit house

operations

(unspecified animal

age)

Confinement

2805047300 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Swine production ‐

deep‐pit house

operations

(unspecified animal

age)

Land application of

manure

2805053100 Miscellaneous

Area Sources

Agriculture

Production ‐ 

Livestock

Swine production ‐

outdoor operations

(unspecified animal

age)

Confinement

Activity Data

County‐level animal numbers for 2007 were obtained from the U.S. Department of Agriculture’s 2007

Census of Agriculture report.2 For Virginia, the county‐level census data includes animal populations
71 

from Virginia’s 39 independent cities. For some counties and states, census data was withheld to avoid

disclosing data for individual farms. However, the total national‐level animal numbers and most state‐

level animal numbers for each livestock type reported in the Census include those animal numbers not

disclosed at the county‐level. When available, state‐level animal numbers from the USDA NASS online

database were used for states with undisclosed animal numbers in the 2007 Census of Agriculture.3 To

determine the total number of undisclosed animals, disclosed county‐level animal numbers for each

livestock type were summed and subtracted from the total state animal numbers. The total undisclosed

animal population for a specific livestock type was then allocated to those counties reporting

undisclosed data based on the number of farms raising that livestock in each county.2 If the state‐level

data was undisclosed and not available in the NASS database, then national animal numbers were used

to determine undisclosed state numbers. The disclosed county‐level data was then summed and

subtracted from the state‐level data to determine animal numbers not disclosed at the county‐level.

These numbers were then allocated to those counties reporting undisclosed data based on the number

of farms raising that livestock in each county.  

County‐level animal numbers were apportioned to manure management trains. A MMT consists of an

animal confinement area (e.g., drylot, pasture, flush, scrape); components used to store, process, or

stabilize the manure (e.g., anaerobic lagoons, deep pits); and a land application site where manure is

used as a fertilizer source.4 The apportionment was based on county‐level MMT percentages derived

from the CMU Ammonia Model. For each livestock type, the county‐level number of animals in each

MMT was divided by the total county‐level animal population for that livestock type to calculate the

percentage of total animals managed by each MMT. In cases where the county‐level numbers were zero

in the 2002 CMU Ammonia Model input files, the county was assigned state‐level MMT percentages.

The county‐level animal population for each livestock type from the 2007 Census of Agriculture was

multiplied by the MMT percentages to determine the total number of animals in each MMT in 2007.

Animal populations for ducks, geese, goats, horses, and sheep were not apportioned to MMTs.

Cattle reported as “Other Cattle” in the 2007 Census of Agriculture were divided between dairy cattle

and beef cattle at the county‐level using percent allocations derived from county‐level dairy and beef

cattle reported in the 2007 Census of Agriculture and corrected for undisclosed data. The animal

numbers from “Other Cattle” apportioned to dairy and beef cattle were used to create the Dairy Cattle –

Composite and Beef Cattle – Composite activity input files for the CMU Ammonia Model.

County‐level pullet numbers reported in the 2007 Census of Agriculture were used to create the Poultry

– Composite activity input file for the CMU Ammonia Model.

Emission Factors

The emission factor for the poultry composite categories was obtained from an EPA report and is

reported in the corresponding table below.4 The county‐level emission factors for the beef composite

and dairy composite categories were developed using beef and dairy cattle emission factors provided

with the 2002 CMU Model. Specifically, weighted average emission factors were calculated based on the
72 

number of beef or dairy cattle in each MMT from the 2002 CMU Model activity files and the emission

factor assigned to each MMT. All other emission factors were provided with the CMU Ammonia Model

v.3.6. The emission factors for some counties in the CMU Ammonia Model files were zero. To ensure

that all counties with animal populations were assigned emissions factors, the emission factor input files

provided with the CMU Ammonia Model were modified. For all counties with an emission factor of zero,

the emission factor was replaced with the state average emission factor. If all counties in the state had

emission factors of zero, then the county emission factor was replaced with the national average

emission factor. The state average emission factor was calculated by summing the counties with non‐

zero emission factors in the state and dividing the total by the number of counties in that state with

non‐zero emission factors. The national average emission factor was calculated by summing the

counties with non‐zero emission factors in the nation and dividing the total by the number of counties in

the nation with non‐zero emission factors.

Emissions

The livestock activity files provided with the CMU Ammonia Model v.3.6 were replaced with the

updated county‐level animal population files and modified emissions files. County‐level ammonia

emissions were then calculated by running the model.

Sample Calculations

Allocation of Undisclosed Data

From the 2007 Census of Agriculture, the total national number of beef cattle in Alabama is 678,949.

The total number of beef cattle disclosed at the county‐level is 388,827.  

Total number of beef cattle undisclosed at the county‐level = 678,949 ‐ 338,827 = 340,122

From the 2007 Census of Agriculture, the total number of farms in Alabama not disclosing beef cattle

numbers is 10,518.

Average beef cattle per farm not disclosing data = 340,122 / 10,518 = 32.3

For 2007, Baldwin County, Alabama beef cattle data was not disclosed. The total number of farms with

beef cattle in Baldwin County is 343.

Estimated number of beef cattle in Baldwin County = 32.3 x 343 = 11,092

Manure Management Train
73 

From the 2002 CMU Ammonia Model input files, Chilton County, Alabama had 79 beef cattle under

drylot management and 18,900 beef cattle under pasture management in 2002.  

Total beef cattle = 79 + 18,900 = 18,979

% of beef cattle under drylot management = 79 / 18,979 = 0.42

% of beef cattle under pasture management = 18,900 / 18,979 = 99.58

The total number of beef cattle for Chilton County reported in the 2007 Census of Agriculture is 7,939.  

Number of beef cattle under drylot management in 2007 = 7,939 x 0.0042 = 33

Number of beef cattle under pasture management in 2007 = 7,939 x 0.9958 = 7,906

“Other Cattle”

For Clay County, Alabama, the 2007 Census of Agriculture reports the number of “Other Cattle” as

5,471, the number of dairy cattle as 216, and the number of beef cattle as 9,096.

Total beef and dairy cattle reported = 216 + 9,096 = 9,312

% of other cattle assigned to beef cattle = (9,096/9,312)*100 = 97.68

% of other cattle assigned to dairy cattle = (216/9,312)*100 = 2.32

Other cattle allocated to beef cattle = 5,471 x .9768 = 5,344

Other cattle allocated to dairy cattle = 5,471 x 0.0232 = 127

QA/QC

EPA proposes to use 2008 emissions for 2011 emissions due to budget constraints.  The 2008 emissions

are based upon population data from the 2007 Census of Agriculture.  Current estimates of livestock and

poultry populations can be obtained from United States Department of Agriculture, National Agricultural

Statistics Service, Missouri Field Office.6

  Current estimates for major categories of livestock and poultry

populations are general three (3) to ten (10) percent lower than those found in the 2007 census.  This

population difference is not expected to alter the overall emissions enough to justify running the CMU

Ammonia Model v. 3.6.
74 

References

1. Cliff Davidson, Peter Adams, Ross Strader, Rob Pinder, Natalie Anderson, Marian Goebes, and

Josh Ayers. The Environmental Institute, Carnegie Mellon University, CMU Ammonia Model

v.3.6., 2004, at http://www.cmu.edu/ammonia/, accessed 25 April 2009.

2. U.S. Department of Agriculture, 2007 Census of Agriculture, at http://www.agcensus.usda.gov/,

accessed 30 April 2009.

3. U.S. Department of Agriculture, National Agricultural Statistics Service, at

http://www.nass.usda.gov/Data_and_Statistics/Quick_Stats/, accessed 28 January 2010.

4. U.S. Environmental Protection Agency, National Emission Inventory – Ammonia Emissions from

Animal Agricultural Operations, Revised Draft Report, 22 April 2005, p. 4‐6, at

http://www.epa.gov/ttn/chief/net/2002inventory.html, accessed 5 May 2009.

5. Jonathan Dorn, E.H. Pechan & Associates. 2009. A weighted average emission factor calculated

using data from the 2002 CMU Ammonia Model v.3.6.

6. U.S. Department of Agriculture, National Agricultural Statistics Service, Missouri Field Office, at

http://www.nass.usda.gov/Statistics_by_State/Missouri/Publications/Current_Estimates/index.

asp, accessed 7 December 2012.

Livestock Emission Factors

Description

Pollutant

Code

Emission

Factor Emission Factor Unit

Emission Factor

Reference

Beef Cattle ‐ Composite NH3 county‐specific kg NH3/cow/month 5

Beef Cattle ‐ Drylot Operation ‐ Confinement NH3 9.45E‐01 kg NH3/cow/month 1

Beef Cattle ‐ Drylot Operation ‐ Land Application NH3 state‐specific kg NH3/cow/month 1

Beef Cattle ‐ Drylot Operation ‐ Manure Storage NH3 3.78E‐04 kg NH3/cow/month 1

Beef Cattle ‐ Pasture Operation ‐ Confinement NH3 county‐specific kg NH3/cow/month 1

Dairy Cattle ‐ Composite NH3 county‐specific kg NH3/cow/month 5

Dairy Cattle ‐ Deep Pit Dairy Confinement NH3 2.42E+00 kg NH3/cow/month 1

Dairy Cattle ‐ Deep Pit Dairy Land Application NH3 state‐specific kg NH3/cow/month 1

Dairy Cattle ‐ Deep Pit Dairy Manure Storage NH3 1.13E‐01 kg NH3/cow/month 1

Dairy Cattle ‐ Drylot Dairy Confinement NH3 state‐specific kg NH3/cow/month 1

Dairy Cattle ‐ Drylot Dairy Land Application NH3 state‐specific kg NH3/cow/month 1

Dairy Cattle ‐ Drylot Dairy Manure Storage NH3 state‐specific kg NH3/cow/month 1

Dairy Cattle ‐ Flush Dairy Confinement NH3 2.00E+00 kg NH3/cow/month 1
75 

Description

Pollutant

Code

Emission

Factor Emission Factor Unit

Emission Factor

Reference

Dairy Cattle ‐ Flush Dairy Land Application NH3 state‐specific kg NH3/cow/month 1

Dairy Cattle ‐ Flush Dairy Manure Storage NH3 state‐specific kg NH3/cow/month 1

Dairy Cattle ‐ Scrape Dairy Confinement NH3 state‐specific kg NH3/cow/month 1

Dairy Cattle ‐ Scrape Dairy Land Application NH3 state‐specific kg NH3/cow/month 1

Dairy Cattle ‐ Scrape Dairy Manure Storage NH3 state‐specific kg NH3/cow/month 1

Ducks NH3 7.67E‐02 kg NH3/duck/month 1

Geese NH3 7.67E‐02 kg NH3/goose/month 1

Goats NH3 5.29E‐01 kg NH3/goat/month 1

Horses NH3 1.02E+00 kg NH3/horse/month 1

Poultry ‐ Broiler Operation ‐ Confinement NH3 8.32E‐03 kg NH3/bird/month 1

Poultry ‐ Broiler Operation ‐ Land Application NH3 6.80E‐03 kg NH3/bird/month 1

Poultry ‐ Broiler Operation ‐ Manure Storage NH3 1.51E‐03 kg NH3/bird/month 1

Poultry ‐ Composite NH3 2.00E‐02 kg NH3/bird/month 4

Poultry ‐ Layers ‐ Dry Manure Operation ‐ 

Confinement NH3 3.36E‐02 kg NH3/bird/month 1

Poultry ‐ Layers ‐ Dry Manure Operation ‐ Land

Application NH3 county‐specific kg NH3/bird/month 1

Poultry ‐ Layers ‐ Wet Manure Operation ‐ 

Confinement NH3 9.45E‐03 kg NH3/bird/month 1

Poultry ‐ Layers ‐ Wet Manure Operation ‐ Land

Application NH3 county‐specific kg NH3/bird/month 1

Poultry ‐ Layers ‐ Wet Manure Operation ‐ 

Manure Storage NH3 county‐specific kg NH3/bird/month 1

Poultry ‐ Turkey Operation ‐ Confinement NH3 3.78E‐02 kg NH3/bird/month 1

Poultry ‐ Turkey Operation ‐ Land Application NH3 3.40E‐02 kg NH3/bird/month 1

Poultry ‐ Turkey Operation ‐ Storage NH3 6.80E‐03 kg NH3/bird/month 1

Sheep NH3 2.65E‐01 kg NH3/sheep/month 1

Swine ‐ Composite NH3 county‐specific kg NH3/pig/month 1

Swine ‐ Deep Pit Operation ‐ Confinement NH3 2.65E‐01 kg NH3/pig/month 1

Swine ‐ Deep Pit Operation ‐ Land Application NH3 county‐specific kg NH3/pig/month 1

Swine ‐ Lagoon Operation ‐ Confinement NH3 2.27E‐01 kg NH3/pig/month 1

Swine ‐ Lagoon Operation ‐ Land Application NH3 county‐specific kg NH3/pig/month 1

Swine ‐ Lagoon Operation ‐ Manure Storage NH3 county‐specific kg NH3/pig/month 1

Swine ‐ Outdoor Operation ‐ Confinement NH3 county‐specific kg NH3/pig/month 1

   
76 

8.6 Aviation Gasoline Distribution:  Stage I

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  The documentation

below was developed by EPA.   

a. Source Category Description

Aviation gasoline (also called “AvGas”) is the only aviation fuel that contains tetraethyl lead (TEL) as a

knock‐out component for small reciprocating, piston‐engine crafts in civil aviation.1

  Commercial and

military aviation rarely use this fuel.  AvGas is shipped to airports and is filled into bulk terminals, and

then into tanker trucks.  These processes fall under the definition of stage I, displacement vapors during

the transfer of gasoline from tank trucks to storage tanks, and vice versa.  These processes are subject to

EPA’s maximum available control technology (MACT) standards for gasoline distribution.2

For this source category, the following SCC was assigned:

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

2501080050 Storage and

Transport

Petroleum and Petroleum

Product Storage

Airports : Aviation

Gasoline

Stage 1: Total

b. Activity Data

The amount of AvGas consumed was obtained from the Petroleum Supply Annual for designated

Petroleum Administration Districts, or PADs.3

  A nationwide total of 5,603,000 barrels of AvGas were

consumed in 2008.3

  (The EPA used the same activity values for the 2011 as they did for the 2008 NEI

due to limited resources.) This information was used to calculate national‐level emissions estimates for

one criteria pollutant and ten hazardous air pollutants (HAPs).  Assumptions for bulk plant processes are

summarized in the corresponding table below.   

c. Emission Factors

Emission factors were provided by ESD and EIG publications.1,4,5,6

d. Emissions

In general, national‐level emissions were calculated by multiplying AvGas consumption by the

appropriate emission factors and then summing emissions. The national‐level emission estimates were
77 

first allocated based on consumption reported for each PAD, and then allocated to the counties within

the PADs based on 2008 Landing‐Take Off (LTO) data for general aviation flights.7

  General aviation

flights were used in this allocation because they are the primary consumers of AvGas.

There are five PADs across the United States3

PAD 1 comprises seventeen states plus the District of Columbia along the Atlantic Coast; 

PAD 2 comprises fifteen states in the Midwest; 

PAD 3 comprises six states in South Central U.S.; 

PAD 4 comprises five states in the Rocky Mountains; and 

PAD 5 comprises seven states along the West Coast. 

Summary of AvGas Consumed and LTOs by PAD in 2008

PAD

AvGas Consumed

(barrels) LTOs

1

1,039,000 17,588,837

2 1,652,000 16,520,073

3 2,021,000 9,883,668

4 158,000 3,311,438

5 733,000 12,641,441

5,603,000 59,945,457

e. Sample Calculations

National‐Level Calculations

Amount of AvGas consumed in 2008 (barrels) = 5,603,000

Conversion:   1 barrel = 42 gallons

1 gallon = 3.78 liters

1 kg = 2.205 lb
78 

1 kg = 1,000,000 mg

1 ton = 2000 lb

Step 1 ‐ Convert AvGas consumption into gallons using conversion factors.

 Amount of AvGas consumed in 2008 (gallons) = 5,603,000 barrels * 42 gallons/barrel 

Amount of AvGas consumed in 2008 (gallons) = 235,326,000

Step 2 ‐ Use the gallons of AvGas consumed and apply the non‐fugitive VOC emission factors in the

corresponding table below to calculate non‐fugitive VOC estimates.   

Unloading/Tank Filling: tank fill VOC emissions = 0.009021383 LB/GAL * 

235,326,000 GAL / 2,000 LB/TON 

Unloading/Tank Filling:  tank fill VOC emissions = 1,061.48 tpy

Unloading/Tank Filling: Storage tank VOC emissions = 0.003605215 LB/GAL * 

235,326,000 GAL / 2,000 LB/TON 

Unloading/Tank Filling: Storage tank VOC emissions = 424.20 tpy 

Tank Truck Filling - Composite VOC Emissions = 0.010306575 LB/GAL * 235,326,000 

GAL * / 2,000 LB/TON 

Tank Truck Filling ‐ Composite VOC Emissions = 1,212.70 tpy

Storage Tank - Breathing losses VOC Emissions = 0.001694117 LB/GAL * 235,326,000 

GAL * / 2,000 LB/TON 

Storage Tank ‐ Breathing losses VOC Emissions = 199.33 tpy

Total non‐fugitive VOC emissions = 1,061.48 tpy + 424.20 tpy + 1,212.70 tpy + 199.33 tpy  =  

2,897.72 tpy

Step 3 ‐ Use the assumptions in and the fugitive VOC emission factors in the corresponding tables below

to generate fugitive VOC emissions.

AvGas - Fugitive from valves VOC Emissions = (# Bulk Plant 

Equivalents)*(#valves/plant)*EF*days 

AvGas ‐ Fugitive from valves VOC Emissions = (2442 plants) * (50 valves/plant) * (0.573201882

LB/valve/day)* 300 days / 2,000 LB/TON

AvGas ‐ Fugitive from valves VOC Emissions = 10,498.19 tpy
79 

AvGas - Fugitive from pumps VOC Emissions = (# Bulk Plant 

Equivalents)*(#pumps/plant)* (#seals/pump) * EF * days 

AvGas ‐ Fugitive from pumps VOC Emissions = (2442 plants) * (2 pumps/plant) * (4 seals/pump)

* (5.952481079 LB/seal/day)* 300 days / 2,000 LB/TON

AvGas ‐ Fugitive from pumps VOC Emissions = 17,443.15 tpy

Total fugitive VOC emissions = 10,498.19 tpy + 17,443.15 tpy

Total fugitive VOC emissions = 27,941.34 tpy

Step 4 ‐ Sum the fugitive and non‐fugitive VOC emissions together for total VOC emissions.

Total VOC emissions = 2,897.72 tpy + 27,941.34 tpy = 30,839.06 tpy

Step 5 ‐ Apply the speciation emission factors in the corresponding table below for tetraethyl lead, 2,2,4‐

trimethylpentane, benzene, cumene, ethylbenzene, hexane, naphthalene, toluene, and xylene to

calculate HAP emissions.

Tetraethyl Lead emissions = 30,839.06 tpy VOC * 9.78 E-6 = 0.30 tpy 

2,2,4-Trimethylpentane emissions = 30,839.06 tpy VOC * 0.008 = 246.71 tpy 

Benzene emissions = 30,839.06 tpy VOC * 0.009 = 277.55 tpy 

Cumene emissions = 30,839.06 tpy VOC * 0.0001 = 3.08 tpy 

Ethylbenzene emissions = 30,839.06 tpy VOC * 0.0010 = 30.84 tpy 

Hexane emissions = 30,839.06 tpy VOC * 0.0160 = 493.43 tpy 

Naphthalene emissions = 30,839.06 tpy VOC * 0.0005 = 15.42 tpy 

Toluene emissions = 30,839.06 tpy VOC * 0.0130 = 400.91 tpy 

Xylene emissions = 30,839.06 tpy VOC * 0.005 = 154.20 tpy 

Step 6 ‐ Use the ethylene dichloride emission factor in the corresponding table below to calculate

ethylene dichloride emissions.

Ethylene dichloride emissions = 235,326,000 GAL * 2.167E-6 LB/GAL * TON/2000 LB 

= 0.25 tpy 
80 

Assumptions Used For Bulk Terminals Using AvGas

Parameter Data Reference

Number of Bulk Plant Equivalents (U.S.) 2,442 plants

1

Number of valves per bulk plant 50 valves/plant

Number of pumps per bulk plant 2 pumps/plant

Number of seals per bulk plant 4 seals/pump

Number of days per year used 300 days

VOC Emission Factors

Pollutant Emission Source Emission Factor Emission

Factor Units

Factor

Reference

VOC Aviation Gas Unloading/ Tank

Filling ‐ tank fill

0.009021383

LB/GAL AvGas

1

Aviation Gas Unloading/ Tank

Filling ‐ Storage tank working

0.003605215

Aviation Gas Tank Truck Filling ‐ 

Composite

0.010306575

Aviation Gas Storage Tank ‐ 

Breathing losses

0.001694117

Aviation Gas ‐ Fugitive from

valves

0.573201882 LB/valve/day

Aviation Gas ‐ Fugitive from

pumps

5.952481079 LB/seal/day
81 
82 

HAP Emission Factors

Pollutant Emission Source Emission

Factor

Emission Factor

Units

Factor

Reference

Ethylene Dichloride All processes 2.167 E‐6 LB/GAL AvGas 4

Tetraethyl Lead (TEL) All processes 9.78 E‐6 LB/LB VOC 1

2,2,4‐Trimethylpentane All processes 0.0080

LB/ LB VOC

Benzene All processes 0.0090 5

Cumene All processes 0.0001 6

Ethylbenzene All processes 0.0010

5

Hexane All processes 0.0160

Naphthalene All processes 0.0005

Toluene All processes 0.0130

Xylene All processes 0.0050

Example Calculations for Wake County, NC

Wake County VOC emissions = (National VOC emissions) * (PAD 1 consumption/Total consumption) *

(Wake County LTOs/PAD 1 LTOs)

Wake County VOC emissions = (30,839.06 tpy) * (1,039,000 bbl/5,603,000 bbl) * (95,234

LTOs/17,588,837 LTOs)

Wake County VOC emissions = 30.96 tpy

Wake County Benzene Emissions = (Wake County VOC emissions)*(Benzene Emission Factor)
83 

Wake County Benzene Emissions = (30.96 tpy VOC) * (0.0090 LB benzene/ LB VOC)* (2000 LB VOC/2000

LB benzene)

Wake County Benzene Emissions = 0.28 tpy

f. References

1. TRC Environmental Corporation.  Estimation of Alkylated Lead Emissions, Final Report.  Prepared

for U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards.  RTP, NC

1993.

2. U.S. Environmental Protection Agency.  National Emission Standards for Source Categories:  

Gasoline Distribution (Stage I).  40 CFR Part 63.  Office of Air Quality Planning and Standards.  

RTP, NC.  February 28, 1997.  Pages 9087‐9093.

3. Energy Information Administration. Petroleum Annual Supply, 2008.  Tables 3, 5, 7, 9, and 11.  

U.S. Department of Energy.  Washington, D.C.  June 2009.  (Internet address:

http://www.eia.doe.gov/oil_gas/petroleum/data_publications/petroleum_supply_annual/psa_v

olume1/psa_volume1.html)

4. U.S. Environmental Protection Agency.  Locating and Estimating Air Emissions from Sources of

Ethylene Dichloride.  EPA‐450/4‐84‐007d.  RTP, NC.  March 1984.

5. Memorandum from Greg LaFlam and Tracy Johnson (PES) to Stephen Shedd (EPA/OAQPS).  

Speciated Hazardous Air Pollutants ‐ Baseline Emissions and Emissions Reductions Under the

Gasoline Distribution NESHAP.  August 9, 1996.

6. Personal Communication via e‐mail from Stephen Shedd (EPA/OAQPS) to Laurel Driver

(EPA/OAQPS).  E‐mail dated May 29, 2002.

7. [LTObyCtyandSCC.mdb], electronic file from Laurel Driver, U.S. Environmental Protection

Agency, OAQPS, to U.S. Environmental Protection Agency, OAQPS, November 12, 2009. Aircraft

operations data compiled from FAA’s Terminal Area Forecasts (TAF) and 5010 Forms.  

   
84 

8.7 Aviation Gasoline Distribution:  Stage II

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  The documentation

below was developed by EPA.  

a. Source Category Description

Aviation gasoline (also called “AvGas”) is the only aviation fuel that contains tetraethyl lead (TEL) as a

knock‐out component for small reciprocating, piston‐engine crafts in civil aviation.1

  Commercial and

military aviation rarely use this fuel.  AvGas is shipped to airports and is filled into bulk terminals, and

then into tanker trucks.  These processes fall under the definition of stage I are subject to EPA’s

maximum available control technology (MACT) standards for gasoline distribution.2 Stage II, discussed

here, involves the transfer of fuel from the tanker trucks into general aviation aircraft.

For this source category, the following SCC was assigned:

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

2501080100 Storage and

Transport

Petroleum and Petroleum

Product Storage

Airports : Aviation

Gasoline

Stage 2: Total

b. Activity Data

The amount of AvGas consumed was obtained from the Petroleum Supply Annual for designated

Petroleum Administration Districts, or PADs.3

  A nationwide total of 5,603,000 barrels of AvGas were

consumed in 2008.3

  (The EPA used the same activity values for the 2011 as they did for the 2008 NEI

due to limited resources.) This information was used to calculate national‐level emissions estimates for

one criteria pollutant and ten hazardous air pollutants (HAPs).   

c. Emission Factors

Emission factors were provided by ESD and EIG publications.1,4,5,6    

d. Emissions
85 

In general, national‐level emissions were calculated by multiplying AvGas consumption by the

appropriate emission factors and then summing emissions. The national‐level emission estimates were

first allocated based on consumption reported for each PAD, and then allocated to the counties within

the PADs based on 2008 Landing‐Take Off (LTO) data for general aviation flights.7

  General aviation

flights were used in this allocation because they are the primary consumers of AvGas.

There are five PADs across the United States3

PAD 1 comprises seventeen states plus the District of Columbia along the Atlantic Coast; 

PAD 2 comprises fifteen states in the Midwest; 

PAD 3 comprises six states in South Central U.S.; 

PAD 4 comprises five states in the Rocky Mountains; and 

PAD 5 comprises seven states along the West Coast. 

Summary of AvGas Consumed and LTOs by PAD in 2008

PAD

AvGas Consumed

(barrels) LTOs

1

1,039,000 17,588,837

2 1,652,000 16,520,073

3 2,021,000 9,883,668

4 158,000 3,311,438

5 733,000 12,641,441

5,603,000 59,945,457

e. Sample Calculations

National‐Level Calculations

Amount of AvGas consumed in 2008 (barrels) = 5,603,000
86 

Conversion:   1 barrel = 42 gallons

1 gallon = 3.78 liters

1 kg = 2.205 lb

1 kg = 1,000,000 mg

1 ton = 2000 lb

Step 1 ‐ Convert AvGas consumption into gallons using conversion factors.

 Amount of AvGas consumed in 2008 (gallons) = 5,603,000 barrels * 42 gallons/barrel 

Amount of AvGas consumed in 2008 (gallons) = 235,326,000

Step 2 ‐ Use the gallons of AvGas consumed and apply the refueling VOC emission factors from the

corresponding table below to first calculate refueling VOC estimates.

AvGas Refueling VOC emissions = (1.36 E‐2 LB/gal AvGas) * 235,326,000 gallons * 1 ton/2000 LB

AvGas Refueling VOC emissions = 1,600.22 tpy

Step 3 ‐ Apply the speciation emission factors in the corresponding table below for 2,2,4‐

trimethylpentane, benzene, cumene, ethylbenzene, hexane, naphthalene, toluene, and xylene to

calculate HAP emissions.

2,2,4-Trimethylpentane emissions = 1,600.22 tpy VOC * 0.008 = 12.80 tpy 

Benzene emissions = 1,600.22 tpy VOC * 0.009 = 14.40 tpy 

Cumene emissions = 1,600.22 tpy VOC * 0.0001 = 0.16 tpy 

Ethylbenzene emissions = 1,600.22 tpy VOC * 0.0010 = 1.60 tpy 

Hexane emissions = 1,600.22 tpy VOC * 0.0160 = 25.60 tpy 

Naphthalene emissions = 1,600.22 tpy VOC * 0.0005 = 0.80 tpy 

Toluene emissions = 1,600.22 tpy VOC * 0.0130 = 20.80 tpy 

Xylene emissions = 1,600.22 tpy VOC * 0.005 = 8.00 tpy 

Step 6 ‐ Use the ethylene dichloride and tetraethyl lead emission factors in the corresponding table below

to calculate ethylene dichloride emissions.

Ethylene dichloride emissions = 235,326,000 GAL * 1.883 E-6 LB/GAL * TON/2000 

LB = 0.22 tpy 

Tetraethyl lead emissions = 235,326,000 GAL * 1.327E-7 LB/GAL * TON/2000 LB = 

0.015 tpy 
87 

  

VOC Emission Factor

Pollutant Emission Source Emission Factor Emission

Factor Units

Factor

Reference

VOC Fuel Transfer from Tanker

Trucks to General Aviation

Aircraft

0.0136 LB/GAL AvGas 1

HAP Emission Factors

Pollutant Emission Source Emission

Factor

Emission Factor

Units

Factor

Reference

Ethylene Dichloride All processes 1.883 E‐6 LB/GAL AvGas 4

Tetraethyl Lead (TEL) All processes 1.327 E‐7 LB/GAL AvGas 1

2,2,4‐Trimethylpentane All processes 0.0080

LB/ LB VOC

Benzene All processes 0.0090 5

Cumene All processes 0.0001 6

Ethylbenzene All processes 0.0010

5

Hexane All processes 0.0160

Naphthalene All processes 0.0005

Toluene All processes 0.0130

Xylene All processes 0.0050
88 

Example Calculations for Wake County, NC

Wake County VOC emissions = (National VOC emissions) * (PAD 1 consumption/Total consumption) *

(Wake County LTOs/PAD 1 LTOs)

Wake County VOC emissions = (1,600.22 tpy) * (1,039,000 bbl/5,603,000 bbl) * (95,234 LTOs/17,588,837

LTOs)

Wake County VOC emissions = 1.61 tpy

Wake County Benzene Emissions = (Wake County VOC emissions)*(Benzene Emission Factor)

Wake County Benzene Emissions = (1.61 tpy VOC) * (0.0090 LB benzene/ LB VOC)* (2000 lb VOC/2000 lb

benzene)

Wake County Benzene Emissions = 0.014 tpy

f. References

1. TRC Environmental Corporation.  Estimation of Alkylated Lead Emissions, Final Report.  Prepared

for U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards.  RTP, NC

1993.

2. U.S. Environmental Protection Agency.  National Emission Standards for Source Categories:  

Gasoline Distribution (Stage I).  40 CFR Part 63.  Office of Air Quality Planning and Standards.  

RTP, NC.  February 28, 1997.  Pages 9087‐9093.

3. Energy Information Administration. Petroleum Annual Supply, 2008.  Tables 3, 5, 7, 9, and 11.  

U.S. Department of Energy.  Washington, D.C.  June 2009.  (Internet address:

http://www.eia.doe.gov/oil_gas/petroleum/data_publications/petroleum_supply_annual/psa_v

olume1/psa_volume1.html)

4. U.S. Environmental Protection Agency.  Locating and Estimating Air Emissions from Sources of

Ethylene Dichloride.  EPA‐450/4‐84‐007d.  RTP, NC.  March 1984.

5. Memorandum from Greg LaFlam and Tracy Johnson (PES) to Stephen Shedd (EPA/OAQPS).  

Speciated Hazardous Air Pollutants ‐ Baseline Emissions and Emissions Reductions Under the

Gasoline Distribution NESHAP.  August 9, 1996.

6. Personal Communication via e‐mail from Stephen Shedd (EPA/OAQPS) to Laurel Driver

(EPA/OAQPS).  E‐mail dated May 29, 2002.
89 

7. [LTObyCtyandSCC.mdb], electronic file from Laurel Driver, U.S. Environmental Protection

Agency, OAQPS, to U.S. Environmental Protection Agency, OAQPS, November 12, 2009. Aircraft

operations data compiled from FAA’s Terminal Area Forecasts (TAF) and 5010 Forms.  

   
90 

8.8 Commercial Cooking

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  The documentation

below was developed by EPA.  Subsection f contains Missouri’s audit of EPA’s estimate.

a. Source Category Description 

Commercial cooking emissions are for five source categories based on equipment type.  Emissions

estimates are for all types of meat cooked in a particular piece of equipment. Deep fat frying of french

fries was also included.

For this source category, the following SCCs were assigned:

Source

Classification Code

SCC Level One SCC Level Two SCC Level Three SCC Level Four

2302002100 Industrial

Processes

Food and Kindred

Products: SIC 20

Commercial Cooking ‐ 

Charbroiling

Conveyorized

Charbroiling

2302002200 Industrial

Processes

Food and Kindred

Products: SIC 20

Commercial Cooking ‐ 

Charbroiling

Under‐fired

Charbroiling

2302003000 Industrial

Processes

Food and Kindred

Products: SIC 20

Commercial Cooking ‐ 

Frying

Deep Fat Frying

2302003100 Industrial

Processes

Food and Kindred

Products: SIC 20

Commercial Cooking ‐ 

Frying

Flat Griddle Frying

2302003200 Industrial

Processes

Food and Kindred

Products: SIC 20

Commercial Cooking ‐ 

Frying

Clamshell Griddle

Frying

b. Emission Factors and Equation 

The emission factors used to estimate commercial cooking emissions for the 2011 NEI were developed

by dividing SCC and pollutant‐specific national emissions from the 2002 NEI by 2002 population to

obtain per capita emission factors for each SCC and pollutant.  These emission factors were developed
91 

and reviewed by an ERTAC advisory panel composed of state and EPA personnel (Contact: Roy Huntley,

huntley.roy@epa.gov).  The PM‐CON emission factors were derived by subtracting PM10‐FIL from PM10‐

PRI and the PM2.5‐PRI emission factors were derived by adding PM2.5‐FIL and PM‐CON. The resulting

emission factors are listed in the corresponding table below.   

c. Activity Data 

The activity data used to estimate emissions from commercial cooking was 2010 county‐level population

data, which was obtained from the US Census Bureau’s county‐level population estimates for the 2010

Census.1

  The per capita emission factors were then multiplied by the 2010 county‐level population

estimates.

d. Control Factors 

While no control factors were directly applied to develop the 2011 NEI, the 2002 emissions used to

calculate the per capita emission factors used in the 2011 NEI include controls on chain‐driven

commercial charbroiling in the South Coast Air Quality Management District (SCAQMD) in California.  

Thus, the effect of these controls from the 2002 NEI will lead to slightly lower emissions nationwide in

this category for the 2011 NEI, rather than a more substantial reduction in emissions just in the

SCAQMD area.  

e. Sample Calculations 

Emissions are calculated for each county using emission factors and activity as:

Ex,p = Ax × EFx,p

where:

Ex,p = annual emissions for category x and pollutant p;

Ax = 2010 county‐level population data associated with category x;
92 

EFx,p = emission factor for category x and pollutant p (lb/person).

Example:

Using conveyorized charbroiling in Allegheny County, PA as an example:

According to the US Census Bureau, the population on April 1, 2010 is 1,223,348

The emission factor for PM10‐PRI is 0.0498 lb/person

EPM10‐PRI  = 1,223,348 people × 0.0498 lb PM10‐PRI/person

         = 60,918 lb PM10‐PRI or 30.5 ton PM10‐PRI

f. QA/QC 

1. Source Data – population, EF

Population data listed in the spreadsheet and database were compared to 2010 Missouri

population data listed on the US Census Bureau’s website and is accurate both at the county

level in total population.  

2. Calculations  

Calculations for Missouri county emissions using the per capita emission factors and county

populations were checked and confirmed to be accurate using Excel functions and comparisons.

3. Overall – This is a sound method for estimating emissions from commercial cooking facilities.  

Missouri has no more specific EF or county‐allocation methods.

g. References 
93 

1. DOC, 2011:  U.S. Department of Commerce, Bureau of the Census, County Intercensal Estimates

(2000‐2010), Washington, DC.  

http://www.census.gov/popest/data/intercensal/county/county2010.html  
94 

Commercial Cooking Emission Factors Developed by ERTAC

SCC SCC description

Pollutant

Code

Factor

Numeric

Value

Factor

Unit

Numerator

Factor Unit

Denominator

2302002100 Conveyorized Charbroiling 100027 1.326E‐05 LB EACH

2302002200 Under‐fired Charbroiling 100027 6.385E‐05 LB EACH

2302002100 Conveyorized Charbroiling 100414 7.668E‐05 LB EACH

2302002200 Under‐fired Charbroiling 100414 5.312E‐04 LB EACH

2302002100 Conveyorized Charbroiling 100425 3.730E‐04 LB EACH

2302002200 Under‐fired Charbroiling 100425 2.747E‐03 LB EACH

2302002100 Conveyorized Charbroiling 106445 7.003E‐06 LB EACH

2302002200 Under‐fired Charbroiling 106445 4.214E‐05 LB EACH

2302002100 Conveyorized Charbroiling 107062 2.682E‐05 LB EACH

2302002200 Under‐fired Charbroiling 107062 2.183E‐04 LB EACH

2302002100 Conveyorized Charbroiling 108883 3.597E‐04 LB EACH

2302002200 Under‐fired Charbroiling 108883 2.496E‐03 LB EACH

2302002100 Conveyorized Charbroiling 108952 4.421E‐05 LB EACH

2302002200 Under‐fired Charbroiling 108952 3.063E‐04 LB EACH

2302002100 Conveyorized Charbroiling 120127 5.943E‐06 LB EACH

2302002200 Under‐fired Charbroiling 120127 1.914E‐05 LB EACH

2302003100 Flat Griddle Frying 120127 8.487E‐06 LB EACH

2302002100 Conveyorized Charbroiling 123386 1.466E‐04 LB EACH

2302002200 Under‐fired Charbroiling 123386 1.113E‐03 LB EACH

2302002100 Conveyorized Charbroiling 129000 8.852E‐06 LB EACH

2302002200 Under‐fired Charbroiling 129000 3.587E‐05 LB EACH
95 

SCC SCC description

Pollutant

Code

Factor

Numeric

Value

Factor

Unit

Numerator

Factor Unit

Denominator

2302003100 Flat Griddle Frying 129000 3.139E‐05 LB EACH

2302002100 Conveyorized Charbroiling 130498292 2.709E‐04 LB EACH

2302002200 Under‐fired Charbroiling 130498292 7.911E‐04 LB EACH

2302003100 Flat Griddle Frying 130498292 2.589E‐04 LB EACH

2302002100 Conveyorized Charbroiling 1330207 7.799E‐07 LB EACH

2302002200 Under‐fired Charbroiling 1330207 1.560E‐06 LB EACH

2302002100 Conveyorized Charbroiling 191242 1.309E‐06 LB EACH

2302002200 Under‐fired Charbroiling 191242 2.542E‐06 LB EACH

2302002100 Conveyorized Charbroiling 193395 1.278E‐06 LB EACH

2302002200 Under‐fired Charbroiling 193395 1.723E‐06 LB EACH

2302002100 Conveyorized Charbroiling 206440 6.484E‐06 LB EACH

2302002200 Under‐fired Charbroiling 206440 2.638E‐05 LB EACH

2302003100 Flat Griddle Frying 206440 2.371E‐05 LB EACH

2302002100 Conveyorized Charbroiling 208968 2.476E‐05 LB EACH

2302002200 Under‐fired Charbroiling 208968 6.372E‐05 LB EACH

2302003100 Flat Griddle Frying 208968 4.886E‐06 LB EACH

2302002100 Conveyorized Charbroiling 50000 7.796E‐04 LB EACH

2302002200 Under‐fired Charbroiling 50000 5.876E‐03 LB EACH

2302002100 Conveyorized Charbroiling 50328 1.450E‐06 LB EACH

2302002200 Under‐fired Charbroiling 50328 2.332E‐06 LB EACH

2302003100 Flat Griddle Frying 50328 1.154E‐06 LB EACH

2302002100 Conveyorized Charbroiling 56553 1.772E‐06 LB EACH
96 

SCC SCC description

Pollutant

Code

Factor

Numeric

Value

Factor

Unit

Numerator

Factor Unit

Denominator

2302002200 Under‐fired Charbroiling 56553 5.432E‐06 LB EACH

2302003100 Flat Griddle Frying 56553 2.918E‐06 LB EACH

2302002100 Conveyorized Charbroiling 71432 1.006E‐03 LB EACH

2302002200 Under‐fired Charbroiling 71432 7.351E‐03 LB EACH

2302002100 Conveyorized Charbroiling 75070 5.562E‐04 LB EACH

2302002200 Under‐fired Charbroiling 75070 4.242E‐03 LB EACH

2302002100 Conveyorized Charbroiling 83329 1.613E‐06 LB EACH

2302002200 Under‐fired Charbroiling 83329 2.776E‐06 LB EACH

2302003100 Flat Griddle Frying 83329 1.357E‐06 LB EACH

2302002100 Conveyorized Charbroiling 84742 4.140E‐06 LB EACH

2302002200 Under‐fired Charbroiling 84742 2.413E‐05 LB EACH

2302002100 Conveyorized Charbroiling 85018 2.771E‐05 LB EACH

2302002200 Under‐fired Charbroiling 85018 8.647E‐05 LB EACH

2302003100 Flat Griddle Frying 85018 6.021E‐05 LB EACH

2302002100 Conveyorized Charbroiling 86737 6.408E‐06 LB EACH

2302002200 Under‐fired Charbroiling 86737 2.003E‐05 LB EACH

2302003100 Flat Griddle Frying 86737 6.484E‐06 LB EACH

2302002100 Conveyorized Charbroiling 91203 1.135E‐04 LB EACH

2302002200 Under‐fired Charbroiling 91203 2.649E‐04 LB EACH

2302003100 Flat Griddle Frying 91203 1.308E‐04 LB EACH

2302002100 Conveyorized Charbroiling 92524 1.271E‐05 LB EACH

2302002200 Under‐fired Charbroiling 92524 2.613E‐05 LB EACH
97 

SCC SCC description

Pollutant

Code

Factor

Numeric

Value

Factor

Unit

Numerator

Factor Unit

Denominator

2302003100 Flat Griddle Frying 92524 2.788E‐06 LB EACH

2302002100 Conveyorized Charbroiling 95476 6.167E‐05 LB EACH

2302002200 Under‐fired Charbroiling 95476 4.387E‐04 LB EACH

2302002100 Conveyorized Charbroiling 95487 3.482E‐06 LB EACH

2302002200 Under‐fired Charbroiling 95487 2.111E‐05 LB EACH

2302002100 Conveyorized Charbroiling 98862 4.991E‐06 LB EACH

2302002200 Under‐fired Charbroiling 98862 3.250E‐05 LB EACH

2302002100 Conveyorized Charbroiling CO 4.245E‐02 LB EACH

2302002200 Under‐fired Charbroiling CO 1.350E‐01 LB EACH

2302003000 Deep Fat Frying CO 0.000E+00 LB EACH

2302003100 Flat Griddle Frying CO 1.269E‐02 LB EACH

2302003200 Clamshell Griddle Frying CO 0.000E+00 LB EACH

2302002200 Under‐fired Charbroiling NOX 0.000E+00 LB EACH

2302002100 Conveyorized Charbroiling PM10‐FIL 1.648E‐04 LB EACH

2302002200 Under‐fired Charbroiling PM10‐FIL 1.048E‐03 LB EACH

2302003100 Flat Griddle Frying PM10‐FIL 2.727E‐04 LB EACH

2302003200 Clamshell Griddle Frying PM10‐FIL 1.981E‐05 LB EACH

2302002100 Conveyorized Charbroiling PM10‐PRI 4.980E‐02 LB EACH

2302002200 Under‐fired Charbroiling PM10‐PRI 3.528E‐01 LB EACH

2302003000 Deep Fat Frying PM10‐PRI 0.000E+00 LB EACH

2302003100 Flat Griddle Frying PM10‐PRI 1.031E‐01 LB EACH

2302003200 Clamshell Griddle Frying PM10‐PRI 6.994E‐03 LB EACH
98 

SCC SCC description

Pollutant

Code

Factor

Numeric

Value

Factor

Unit

Numerator

Factor Unit

Denominator

2302002100 Conveyorized Charbroiling PM2.5‐FIL 1.597E‐04 LB EACH

2302002200 Under‐fired Charbroiling PM2.5‐FIL 1.013E‐03 LB EACH

2302003100 Flat Griddle Frying PM2.5‐FIL 2.074E‐04 LB EACH

2302003200 Clamshell Griddle Frying PM2.5‐FIL 1.685E‐05 LB EACH

2302002100 Conveyorized Charbroiling PM2.5‐PRI 4.979E‐02 LB EACH

2302002200 Under‐fired Charbroiling PM2.5‐PRI 3.527E‐01 LB EACH

2302003000 Deep Fat Frying PM2.5‐PRI 0.000E+00 LB EACH

2302003100 Flat Griddle Frying PM2.5‐PRI 1.030E‐01 LB EACH

2302003200 Clamshell Griddle Frying PM2.5‐PRI 6.991E‐03 LB EACH

2302002100 Conveyorized Charbroiling PM‐CON 4.963E‐02 LB EACH

2302002200 Under‐fired Charbroiling PM‐CON 3.517E‐01 LB EACH

2302003000 Deep Fat Frying PM‐CON 0.000E+00 LB EACH

2302003100 Flat Griddle Frying PM‐CON 1.028E‐01 LB EACH

2302003200 Clamshell Griddle Frying PM‐CON 6.974E‐03 LB EACH

2302002200 Under‐fired Charbroiling SO2 0.000E+00 LB EACH

2302002100 Conveyorized Charbroiling VOC 1.206E‐02 LB EACH

2302002200 Under‐fired Charbroiling VOC 4.148E‐02 LB EACH

2302003000 Deep Fat Frying VOC 1.261E‐02 LB EACH

2302003100 Flat Griddle Frying VOC 5.943E‐03 LB EACH

2302003200 Clamshell Griddle Frying VOC 2.316E‐04 LB EACH
99 

   
100 

8.9 Fugitive Dust:  Construction Activities Roads

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  The documentation

below was developed by EPA.  Missouri’s audit of EPA’s estimate can be found near the end of this

section.

a. Source Category Description 

Emissions from road construction activity are a function of the acreage disturbed for road construction. 

Road construction activity is developed from data obtained from the Federal Highway Administration 

(FHWA). Fugitive dust emissions from road construction were estimated for PM10-PRI, PM10-FIL, 

PM2.5-PRI, and PM2.5-FIL. Since there are no PM-CON emissions for this category, PM10-PRI emissions 

are equal to PM10-FIL emissions and PM2.5-PRI emissions are equal to PM2.5-FIL. 

For this category, the following SCC was assigned: 

Source 

Classification 

Code 

SCC Level One SCC Level Two SCC Level Three SCC Level Four 

2311030000 Industrial 

Processes 

Construction: SIC 

15 - 17 Road Construction Total 

b. Activity Data 

The Federal Highway Administration has Highway Statistics, Section IV - Highway Finance, Table SF12A, State Highway Agency Capital Outlay1 for 2008 which outlines spending by state in several different 

categories. For this SCC, the following columns are used: New Construction, Relocation, Added 

Capacity, Major Widening, and Minor Widening. These columns are also differentiated according to the 

following six classifications: 

1. Interstate, urban 

2. Interstate, rural 

3. Other arterial, urban 

4. Other arterial, rural 

5. Collectors, urban 

6. Collectors, rural 

The State expenditure data are then converted to new miles of road constructed using $/mile conversions 

obtained from the North Carolina Department of Transportation (NCDOT) in 2000. A conversion of $4 
101 

million/mile is applied to the interstate expenditures. For expenditures on other arterial and collectors, a 

conversion factor of $1.9 million/mile is applied, which corresponds to all other projects. 

The new miles of road constructed are used to estimate the acreage disturbed due to road construction. 

The total area disturbed in each state is calculated by converting the new miles of road constructed to 

acres using an acres disturbed/mile conversion factor for each road type as given in the table below: 

Spending per Mile and Acres Disturbed per Mile by Highway Type 

Road Type 

Thousand 

Dollars per 

mile 

Total Affected 

Roadway Width 

(ft)*3 

Acres Disturbed 

per mile3 

Urban Areas, Interstate 4,000 125 15.2

Rural Areas, Interstate 4,000 125 15.2

Urban Areas, Other Arterials 1,900 125 15.2

Rural Areas, Other Arterials 1,900 105 12.7

Urban Areas, Collectors 1,900 81 9.8

Rural Areas, Collectors 1,900 65 7.9

*Total Affected Roadway Width = (lane width (12 ft) * number of lanes) + (shoulder 

width * number of shoulders) + area affected beyond road width (25 ft) 

The acres disturbed per mile data shown in the table above is calculated by multiplying the total affected 

roadway width (including all lanes, shoulders, and areas affected beyond the road width) by one mile and 

converting the resulting land area to acres. Building permits2

 are used to allocate the state-level acres 

disturbed by road construction to the county. A ratio of the number of building starts in each county to 

the total number of building starts in each state is applied to the state-level acres disturbed to estimate the 

total number of acres disturbed by road construction in each county. 

c. Emission Factors 

Initial PM10 emissions from construction of roads are calculated using an emission factor of 0.42 

tons/acre-month.3

 This emission factor represents the large amount of dirt moved during the construction 

of roadways, reflecting the high level of cut and fill activity that occurs at road construction sites. The 

duration of construction activity for road construction is assumed to be 12 months. 

Regional variances in construction emissions are corrected using soil moisture level and silt content. 

These correction parameters are applied to initial PM10 emissions from road construction to develop the 

final emissions inventory. 

To account for the soil moisture level, the PM10 emissions are weighted using the 30-year average 

precipitation-evaporation (PE) values from Thornthwaite’s PE Index. Average precipitation evaporation 

values for each State were estimated based on PE values for specific climatic divisions within a State.3

 

To account for the silt content, the PM10 emissions are weighted using average silt content for each 

county. A data base containing county-level dry silt values was complied. These values were derived by 
102 

applying a correction factor developed by the California Air Resources Board to convert wet silt values to 

dry silt values.4

The equation for PM10 emissions corrected for soil moisture and silt content is: 

where: Corrected EPM10 = PM10 emissions corrected for soil moisture and silt content, 

PE = precipitation-evaporation value for each State, 

S = % dry silt content in soil for area being inventoried. 

Once PM10 adjustments have been made, PM2.5 emissions are set to 10% of PM10. Primary PM emissions 

are equal to filterable emissions since there are no condensable emissions from road construction. 

d. Example Calculation 

EmissionsPM10 = ∑(HDrt x MCrt x ACrt) x (HSCounty / HSState) x EFAdj x M 

Where HDrt = Highway Spending for a specific road type 

MCrt = Mileage conversion for a specific road type 

ACrt = Acreage conversion for a specific road type 

HSCounty = Housing Starts in a given county 

HSState = Housing Starts in a given State 

EFAdj = Adjusted PM10 Emission Factor 

M = duration of construction activity 

As an example in 2010, in Newport County, Rhode Island, acres disturbed and PM10 emissions from 

urban interstate and urban other arterial road construction are calculated as follows: 

EmissionsPM10 = ∑(HDrt x MCrt x ACrt) x (HSCounty / HSState) x EFAdj x M 

 = ($35,474/$4,000/mi x 15.2 acres/mi) * (187/1058) + ($21,332/$1,600/mi x 15.2 acres/mi) * (187/1058) 

= 54 acres x 0.28ton/acre-month x 12 months 

= 181.4 tons PM10

Where EFAdj is calculated as follows: 

Corrected E Initial

PE

S

PM PM E 10 10  

24

9%
103 

EFAdj = 0.42 ton/acre-month * (24/110.1 * 33/9) 

= 0.28 ton/acre-month 

e. QA/QC 

Missouri audited EPA’s estimate by: 

1. Data:  Missouri added a sentence to the Source Category Description indicating the pollutants for

which estimates were created using this method for the non‐residential construction category.  

Missouri checked the first reference listed to verify 2008 funding spent by Missouri and verified 

it matches the information included in EPA’s worksheets. Missouri also checked the building 

permits data from the Census Bureau, and verified that the 2008 number for building permits 

matched the data in EPA’s worksheets. It is noted that 2010 building starts data is now 

available, and might be more representative of the activity in 2011 than the 2008 data.

Missouri notes that the North Carolina Department of Transportation (NCDOT) figures for $/mile

include no reference citation.  Missouri suggests adding a reference to these figures so that

they can be verified.   

Missouri also made efforts to verify the emission factor of 0.42 tons PM10/acre‐month, which

was used for non‐residential construction. Missouri was unable to locate the report cited in the

references for this value; however, Missouri was able to find other State’s that cite this same

reference and used this same emission factor to develop PM emissions inventories for road

construction activity.  Also, the equation used to correct for silt content and soil moisture

content was verified in the student manual of APTI course 419b.  Missouri made no changes to

EPA’s NEI results for this source category based on the review of the data.

2. Math: Missouri reviewed the calculations and formulas in EPA’s worksheets and found no 

mathematical or formula errors. Missouri made no changes to EPA’s NEI results for this source 

category based on the review of the math. 

3. Method: Missouri evaluated the reasonableness of the method. In general, the method of 

developing the activity data and emissions seems reasonable. 

It is noted that in comparing the 2008 NEI data to the 2011 NEI data for PM emissions from road 

construction, that there is a 312 percent increase. This is largely due to the increase in funding 

spent on road construction, as the funding spent in Missouri on road construction categories, as 

reported by the Federal Highway Administration (FHWA), increased by more than three-fold 

from 2006 to 2008, and therefore the emissions increase seems reasonable. It is noted that this is 

the 2011 NEI and the activity data is based on 2008 funding levels. While not preferred, there is 

no more recent year of funding levels available on FHWA’s website, and therefore, it seems 

reasonable to use 2008 funding levels for the activity data calculations. However, if newer 

versions of this NEI are created and more recent funding levels become available on FHWA’s 
104 

website, then Missouri would suggest using the more recent data at that time, as it would likely 

be more representative of the 2011 road construction data.

It is noted that the NCDOT figures for converting funding spent to miles of road built was 

obtained in 2000. Due to inflation, it is possible that these figures are no longer representative of 

the cost per mile of road constructed. Missouri suggests that in future NEIs, if resources 

permit, the PPI index could be looked at for road construction or another similar category for 

both 2000 and the year for which the NEI is being calculated and through comparison of these 

two PPIs, an adjustment factor could be developed to account for inflation since 2000 and be 

applied to the $/mile figures.

Additionally it is noted that Missouri counties have one of two different silt content ratios (52% 

or 28.8%). The method of picking one soil classification for each county is acceptable if the 

majority of the land in the county is that particular soil classification, but this may not always be 

the case. Although acceptable, it is also noted that it rarely would be the case that all land in a 

county is of the same soil classification, and for future NEIs if resources permit, Missouri 

suggests using weighted percentages for soil classifications to develop the silt content percentage 

for each county, as this would likely yield more accurate values. While Missouri has several 

suggestions for how the method used in the emission estimation for this source category could be 

improved upon, no changes were made to EPA’s NEI results for this source category based on the 

review of the method. 

f. References 

1. 2008 Highway Spending : http://www.fhwa.dot.gov/policyinformation/statistics/2008/sf12a.cfm

2. 2008 Building Permits data from US Census “BPS01”, 

http://www.census.gov/support/USACdataDownloads.html 

3. Midwest Research Institute. Improvement of Specific Emission Factors (BACM Project No. 1). 

Prepared for South Coast Air Quality Management District. March 29, 1996. 

4. Campbell, 1996: Campbell, S.G., D.R. Shimp, and S.R. Francis. Spatial Distribution of PM-10 

Emissions from Agricultural Tilling in the San Joaquin Valley, pp. 119-127 in Geographic 

Information Systems in Environmental Resources Management, Air and Waste Management 

Association, Reno, NV. 1996. 

   
105 

8.10 Fugitive Dust:  Construction Activities Non‐residential

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  The documentation

below was developed by EPA.  Subsection e contains Missouri’s audit of EPA’s estimate.

a. Source Category Description 

Emissions from non-residential construction activity are a function of the acreage disturbed for nonresidential construction. Fugitive dust emissions from non-residential construction were estimated for 

PM10-PRI, PM10-FIL, PM2.5-PRI, and PM2.5-FIL. Since there are no PM-CON emissions for this category, 

PM10-PRI emissions are equal to PM10-FIL emissions and PM2.5-PRI emissions are equal to PM2.5-FIL. 

For this source category, the following SCC was assigned: 

Source 

Classification 

Code 

SCC Level One SCC Level Two SCC Level Three SCC Level Four 

2311020000 Industrial 

Processes 

Construction: SIC 

15 - 17 

Heavy 

Construction Total 

b. Activity Data 

Annual Value of Construction Put in Place in the U.S1 has the 2011 National Value of Non-residential 

construction. The national value of non-residential construction put in place (in millions of dollars) was 

allocated to counties using county-level non-residential construction (NAICS Code 2362) employment 

data from 2009, which was obtained from County Business Patterns2

 (CBP). Because some counties 

employment data was withheld due to privacy concerns, the following procedure was adopted: 

1. State totals for the known county level employees was subtracted from the number of employees 

reported in the state level version of CBP. This results in the total number of withheld employees 

in the state. 

2. A starting guess of the midpoint of the range code was used (so for instance in the 1-19 

employees range, a guess of 10 employees would be used) and a state total of the withheld 

counties was computed. 

3. A ratio of guessed employees (Step 2) to withheld employees (Step 1) was then used to adjust the 

county level guesses up or down so the state total of adjusted guesses should match state total of 

withheld employees (Step 1) 

Once the number of employees was developed for each county, this number was divided by the total 

number of employees in the country to get a national allocation factor. The national allocation factor was 
106 

then multiplied by the 2011 National Value of Non-residential construction in order to estimate the value 

of non-residential construction in each county. Then in order to estimate the acres disturbed in each 

county, the value of non-residential construction in each county was multiplied by the adjusted 2011 ratio 

for acres per $106

, which was developed by the method below. 

In 1999 a figure of 2 acres/$106

 was developed. The Bureau of Labor Statistics Producer Price Index3

lists costs of the construction industry from 1999-2011. 

2011 acres per $106

 = 1999 acres per $106 x (1999 PPI / 2011 PPI) 

=2 acres/$106

 * (132.9 / 229.3) 

= 1.159 acres per $106 

c. Emission Factors 

Initial PM10 emissions from construction of non-residential buildings are calculated using an emission 

factor of 0.19 tons/acre-month4

. The duration of construction activity for non-residential construction is 

assumed to be 11 months. Since there are no condensable emissions, primary PM emissions are equal to 

filterable emissions. Once PM10-PRI emissions are developed, PM2.5-PRI emissions are estimated by 

applying a particle size multiplier of 0.10 to PM10-PRIemissions. 

Regional variances in construction emissions are corrected using soil moisture level and silt content. 

These correction parameters are applied to initial PM10 emissions from non-residential construction to 

develop the final emissions inventory. 

To account for the soil moisture level, the PM10 emissions are weighted using the 30-year average 

precipitation-evaporation (PE) values from Thornthwaite’s PE Index. Average precipitation evaporation 

values for each State were estimated based on PE values for specific climatic divisions within a State.4

 

To account for the silt content, the PM10 emissions are weighted using average silt content for each 

county. A data base containing county-level dry silt values was complied. These values were derived by 

applying a correction factor developed by the California Air Resources Board to convert wet silt values to 

dry silt values.5

The equation for PM10 emissions corrected for soil moisture and silt content is: 

Corrected E Initial

PE

S

PM PM E 10 10  

24

9%

where: Corrected EPM10 = PM10 emissions corrected for soil moisture and silt content, 

PE = precipitation-evaporation value for each State, 

S = % dry silt content in soil for area being inventoried. 

Once PM10 adjustments have been made, PM2.5 emissions are set to 10% of PM10. 
107 

d. Example Calculation 

EmissionsPM10 = NSpending x (Empcounty / EmpNational) x Apd x EFAdj x M 

Where NSpending = National spending on non-residential construction (million dollars) 

Empcounty = County level employment in non-residential construction 

EmpNational = National level employment in non-residential construction 

Apd = Acres per million dollars (national data) 

EFAdj = Adjusted PM10 emission factor (ton/acre-month) 

M = duration of construction activity (months) 

As an example, in Grand Traverse County, Michigan, 2011 acres disturbed and PM10 emissions from nonresidential construction are calculated as follows: 

EmissionsPM10 = 269,045 x 106

 $ x (130/651,996) x 1.159 acres/106$ x EFAdj x M 

= 62.2 acres x 0.059 ton/acre-month x 11 months 

= 40.4 tons PM10

Where EFAdj is calculated as follows: 

EFAdj = 0.19 ton/acre-month * (24/103.6 * 12/9) 

= 0.059 ton/acre-month 

e. QA/QC 

Missouri audited EPA’s estimate by: 

1. Data:  Missouri added a sentence to the Source Category Description indicating the pollutants for

which estimates were created using this method for the non‐residential construction category.  

Missouri also added language to the activity data section in this document to more clearly explain

the method of determining the number of acres disturbed by non‐residential construction in

each county.

Missouri checked the first reference listed to verify the annual value of the non-residential 

construction put in place in the U.S. and compared this to the values included in EPA’s 

worksheet. The values for non-residential construction included on reference 1 do not match 

the values in EPA’s worksheet. It is possible that the data has been updated since EPA 

developed their worksheet. It is also possible that EPA added other categories that were not 

included in reference 1, such as public safety, sewer and waste disposal, water supply, 

conservation, and development and these categories make up the difference; however, if this is 

the case it should be noted both in this documentation and on the EPA worksheet. If the data 

has changed since the worksheet was developed or if this is an error, then the numbers 
108 

currently included in reference 1 should be entered into the worksheet so that the 

current/accurate data is used for the NEI results. The updated numbers are input to the 

spreadsheet and used for calculations of the number of acres disturbed.

Missouri checked the second reference listed to verify the employment numbers used for

Missouri.  After researching the data, it was determined that the employment data from 2009,

was used in the EPA worksheets.  Missouri verified the total number of employees and spot

checked several counties and no discrepancies between the data included on EPA’s worksheet

and the 2009 employment data were found.  Missouri also added language to the activity data

section of this document to explain that the employment data is for 2009.  It is noted that 2010

employment data is now available, and for Missouri the total number of employees in the

non‐residential construction category has reduced by over 4,000 from 2009 to 2010, which is

over 20 percent and would have a significant impact on the estimation of emissions if the 2010

data was used instead of 2009.

This documentation states that in 1999 a figure of 2 acres/$106 was developed.  This

documentation does not cite a reference for this figure.  Missouri suggests citing a reference

for this figure so that it can be verified by people reviewing the document.  Further the EPA

worksheet, which contains the values that were used to adjust this ratio from 1999 to 2011,

uses PPI data from the Bureau of Labor Statistics for the non‐residential maintenance and repair

category.  Missouri reviewed the PPI data from 1999 to 2011 for the non‐residential

maintenance and repair category and found no discrepancies between the values included in

EPA’s worksheet and the values reported by the Bureau of Labor Statistics.  

Missouri also made efforts to verify the emission factor of 0.19 tons PM10/acre‐month, which

was used for non‐residential construction. Missouri was unable to locate the report cited in the

references for this value; however, Missouri was able to find other State’s that cite this same

reference and used this same emission factor to develop PM emissions inventories for non‐

residential construction activity.

Also, the equation used to correct for silt content and soil moisture content was verified in the

student manual of APTI course 419b.   

2. Math: Missouri reviewed the calculations and formulas in EPA’s worksheets and found no 

mathematical or formula errors. As stated above, several changes were made to the 

documentation that more clearly state the method of calculating the acres of soil disturbed; 

however Missouri made no changes to EPA’s NEI results for this source category based on the 

review of the math. 

3. Method: Missouri evaluated the reasonableness of the method. In general, the method of 

developing the activity data and emissions seems reasonable. 
109 

As noted above in the review of the data, the method of adjusting the ratio of acres/$106 from 

1999 to 2011, uses PPI data from the non-residential maintenance and repair category. It is noted 

that PPI data from the for non-residential construction is not available for years prior to 2010, and 

therefore could not be used to adjust the 1999 figure; however, the category BNEW (new 

construction) is available from 1999 through 2011, and Missouri believes that the PPI from the 

new construction category might better characterize the PPI for the non-residential construction 

category than the non-residential maintenance and repair category. Logic would indicate that the 

materials and labor for new construction would more closely relate to non-residential construction 

than the materials and labor for the maintenance and repair of non-residential facilities. Missouri 

adjusted the 1999 – 2011 PPI data from the new construction category (BNEW) in order to 

adjust the 1999 figure to 2011 for acres/$106

. The estimated acres disturbed per million dollars 

spent went from 1.15 to 1.30, and with the revised private construction put in place, the total 

national acreage disturbed went from 311,871 to 337,915 acres. 

Additionally it is noted that Missouri counties have one of two different silt content ratios (52% 

or 28.8%). The method of picking one soil classification for each county is acceptable if the 

majority of the cropland in the county is that particular soil classification, but this may not always 

be the case. Although acceptable, it is also noted that it rarely would be the case that all cropland 

in a county is of the same soil classification, and for future NEIs if resources permit, Missouri 

suggests using weighted percentages for soil classifications to develop the silt content percentage 

for each county, as this would likely yield more accurate values. While Missouri has several 

suggestions for how the method used in the emission estimation for this source category could be 

improved upon, no changes were made to EPA’s NEI results for this source category based on the 

review of the method. 

e. References 

1. Annual Value of Construction Put in Place: http://www.census.gov/const/C30/priv2011.pdf

2. County Business Patterns: http://www.census.gov/econ/cbp/index.html

3. Bureau of Labor Statistics: http://data.bls.gov/pdq/SurveyOutputServlet Table BMNR 

4. Midwest Research Institute. Improvement of Specific Emission Factors (BACM Project No. 1). 

Prepared for South Coast Air Quality Management District. March 29, 1996. 

5. Campbell, 1996: Campbell, S.G., D.R. Shimp, and S.R. Francis. Spatial Distribution of PM-10 

Emissions from Agricultural Tilling in the San Joaquin Valley, pp. 119-127 in Geographic 

Information Systems in Environmental Resources Management, Air and Waste Management 

Association, Reno, NV. 1996. 

8.11 Fugitive Dust:  Construction Activities Residential

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  The documentation

below was developed by EPA.  Subsection e contains Missouri’s audit of EPA’s estimate.
110 

a. Source Category Description 

Emissions from residential construction activity are a function of the acreage disturbed and volume of soil excavated 

for residential construction. Residential construction activity is developed from data obtained from the U.S. 

Department of Commerce (DOC)’s Bureau of the Census. Fugitive dust emissions from residential construction 

were estimated for PM10-PRI, PM10-FIL, PM2.5-PRI, and PM2.5-FIL. Since there are no PM-CON emissions for this 

category, PM10-PRI emissions are equal to PM10-FIL emissions and PM2.5-PRI emissions are equal to PM2.5-FIL. 

For this source category, the following SCC was assigned: 

Source 

Classification 

Code 

SCC Level One SCC Level Two SCC Level Three SCC Level Four 

2311010000 Industrial 

Processes 

Construction: SIC 

15 - 17 

General Building 

Construction Total 

b. Activity Data

There are two activity calculations performed for this SCC, acres of surface soil disturbed and volume of soil 

removed for basements.

b.1. Surface soil disturbed

The US Census Bureau has 2010 data for Housing Starts - New Privately Owned Housing Units Started1 which 

provides regional level housing starts based on the groupings of the following unit types: 1 unit, 2-4 units, 5 or more 

units. A consultation with the Census Bureau in 2002 gave a breakdown estimated at 36.84 percent of the housing 

starts being for 2 unit structures, and 63.16 percent being for 3 and 4 unit structures. The 2-4 unit category was then 

divided into 2-units, and 3-4 units based on these percentages. To get the number of structures for each grouping, the 

1 unit category was divided by 1, the 2 unit category was divided by 2, and the 3-4 unit category was divided by 3.5. 

The 5 or more unit category listed may be made up of more than one structure. New Privately Owned Housing Units 

Authorized Unadjusted Units2

 gives a conversion factor to determine the ratio of units to structures in the 5 or more 

unit category. For example if a county has one 40 unit apartment building, the ratio would be 40/1. If there are 5 

different 8 unit buildings in the same project, the ratio would be 40/5. Structures started by category are then 

calculated at a regional level. The table Annual Housing Units Authorized by Building Permit3

 has 2010 building 

permit data at the county level. This data was used by comparing the building permit data by unit type at the county 

level to the regional level to determine the ratio of county building permits to regional building permits by unit type. 

This ratio was then applied to allocate the regional housing starts data to the county level by unit type. This results in 

county level housing starts by unit type. The following surface areas were assumed disturbed for each unit type:

Surface Soil disturbed per unit type

1-Unit 1/4 acre/structure

2-Unit 1/3 acre/structure

Apartment 1/2 acre/structure 
111 

The 3-4 unit category was considered to be an apartment. Multiplication of housing starts to soil removed results in 

number of acres disturbed for each unit category. 

b.2. Basement soil removal

To calculate basement soil removal, 2010 Characteristics of New Houses4 is used to estimate the percentage of 1 

unit structures that have a basement (on the regional level). The county level estimate of number of 1 unit starts is 

multiplied by the percent of 1 unit houses in the region that have a basement to get the number of basements in a 

county. Basement volume is calculated by assuming a 2000 square foot house has a basement dug to a depth of 8 

feet (making 16,000 ft3

 per basement). An additional 10% is added for peripheral dirt bringing the total to 17,600 ft3

per basement. 

c. Emission Factors 

Initial PM10 emissions from construction of single family, two family, and apartments structures are calculated using 

the emission factors given in the table below. The duration of construction activity for houses is assumed to be 6 

months and the duration of construction for apartments is assumed to be 12 months. 

Emission Factors for Residential Construction5

Type of Structure Emission Factor Duration of 

Construction 

Apartments 0.11 tons PM10/acre-month 12 months 

2-Unit Structures 0.032 tons PM10/acre-month 6 months 

1-Unit Structures w/o 

Basements 

0.032 tons PM10/acre-month 6 months 

1-unit Structures with 

Basements 

0.011 tons PM10/acre-month 6 months 

0.059 tons PM10/1000 cubic 

yards 

Regional variances in construction emissions are corrected using soil moisture level and silt content. These 

correction parameters are applied to initial PM10 emissions from residential construction to develop the final 

emissions inventory. 

To account for the soil moisture level, the PM10 emissions are weighted using the 30-year average precipitationevaporation (PE) values from Thornthwaite’s PE Index. Average precipitation evaporation values for each State 

were estimated based on PE values for specific climatic divisions within a State. 

To account for the silt content, the PM10 emissions are weighted using average silt content for each county. A data 

base containing county-level dry silt values was compiled. These values were derived by applying a correction 

factor developed by the California Air Resources Board to convert wet silt values to dry silt values.6
112 

The equation for PM10 emissions corrected for soil moisture and silt content is:

Corrected E Initial

PE

S

PM PM E 10 10  

24

9%

where: Corrected EPM10 = PM10 emissions corrected for soil moisture and silt content, 

PE = precipitation-evaporation value for each State, 

S = % dry silt content in soil for area being inventoried. 

Once PM10 adjustments have been made, PM2.5-FIL emissions are estimated by applying a particle size multiplier 

of 0.10 to PM10-FIL emissions7

. Primary PM emissions are equal to filterable emissions since there are no 

condensable emissions from residential construction. 

d. Example Calculation 

PM10 Emissions = ∑( Aunit x Tconstruction x EFunit ) x AdjPM

Where Aunit = HSUnit x SMUnit

HSUnit = Regional Housing Starts x (county building permits/Regional building permits) 

SMUnit = Area or volume of soil moved for the given unit type 

TConstruction = Construction time (in months) for given unit type 

EFUnit = Unadjusted emission factor for PM10 for the given unit type 

AdjPM = PM Adjustment factor 

As an example, in Beaufort County, North Carolina, 2010 acres disturbed and PM10 emissions from 1-unit housing 

starts without a basement are calculated as follows: 

Aunit = 247,000 x (211/232,280) x 0.907(Fraction without basement) * 0.25 acres/unit 

= 203 units * 0.25 acres/unit = 50.9 acres 

AdjPM = (24/110.1) * (10/9) = 0.242 

PM10 Emissions = (50.9 acres x 6 months x 0.032 tons PM10/acre-month) x 0.242 = 2.37 tons PM10 

e. QA/QC 

Missouri audited EPA’s estimate by: 

4. Data:  Missouri added a sentence to the Source Category Description indicating the pollutants for which

estimates were created using this method for the residential construction category.  Missouri reviewed

EPA’s worksheets and the Activity data section of this document, and made several changes to the
113 

language in section b.1, to more accurately describe the methods that were used to determine the amount

of soil disturbed through residential construction in each county.  Specifically, when referring to breaking

down the 2‐4 unit category, this document originally said that 1/3 were 2‐unit structures and 2/3 were 3‐

unit or 4‐unit structures based on 2002 Census Bureau data, Missouri inserted the actual  percentages that

EPA used in their worksheets in order to provide more clarity.  Additionally, when referring to the method

of determining the number of structures for apartment buildings, Missouri changed the order in which the

ratio was stated for the amount of structures for a given number of units to more clearly state this method.  

Language was also added to more clearly state how the EPA’s worksheets used the building permit data to

convert regional level housing starts to county level housing starts.  Finally, in keeping with the language

used in section b.1, the title of first table was changed from soil “removed” to soil “disturbed”.

Missouri also evaluated the values in in the first table.  Missouri notes that there is no reference cited for

the values in this table.  The following website is the California Air Resources Board’s CARB’s method for

determining fugitive dust emissions from building construction, updated 1997:

http://www.arb.ca.gov/ei/areasrc/fullpdf/full7‐7prev.pdf.  Missouri notes that 1‐unit structures in

CARB;’s method range from 1/7 of an acre disturbed to 1/5 of an acre disturbed, both of which are less

than the value in Table 1 of 1/4 of an acre disturbed per 1‐unit structure.  Missouri suggests that a source

be cited that was used to obtain the values in this table so that the values can be verified.

Similarly, the values in second table were evaluated by Missouri.  Missouri was unable to locate the report

cited in the references for the values in this table.  However, CARB’s method of determining these

emissions cites the exact same source, and uses instead a value of 0.11 tons PM10 per acre‐month for all

building types.  Missouri suggests that the values in the second table be verified.   

Also, the equation used to correct for silt content and soil moisture content was verified in the student

manual of APTI course 419b.  As noted above, Missouri has several suggestions for how the data used in

this emission estimation method could be improved upon; however, no changes were made to EPA’s NEI

results for this source category.  Only changes to this narrative documentation were made.

5. Math: Two counties were missing from the county soil disturbed worksheet (29085 Hickory County and 

29223 Wayne County). The lookup tables in the emissions calculations for these two counties used the 

same county soil disturbed data as the counties with the next lowest County FIPS Code. This resulted in 

calculations for these two counties matching identically to the emissions calculations from Henry and 

Washington Counties, respectively. This is an obvious mistake; however, since the state doesn’t have the 

county level building permit data and these two counties are not included on the CO2010A worksheet, this 

error cannot be corrected by the State. Missouri suggests that EPA find the building permit data for these 

two counties and adjust the values in the worksheets to correct this error.

Missouri manually verified the emission calculations in EPA’s worksheet for numerous counties in 

Missouri. All of the manually calculated emission values agreed with the final values in EPA’s worksheet, 

except for the two discrepancies listed above for Hickory and Wayne Counties. Further, Missouri 

evaluated the formulas in EPA’s excel worksheet for this source category and found no errors in any of the 

formulas, but the lookup tables in the emissions calculations worksheet could be enhanced by using 

“FALSE” as the range_lookup argument because doing so would return an error for counties that are not 

included on the soil disturbed worksheet as opposed to using the data for the county with the next lowest 

FIPS. As stated above, several changes were made to the documentation that more clearly state the 

actual method of calculating the area of soil surface disturbed, and Missouri strongly suggests that EPA 

correct the errors for Hickory and Wayne Counties. However, Missouri was unable to make any changes 

to EPA’s NEI results for this source category based on the review of the math. 
114 

6. Method: Missouri evaluated the reasonableness of the method. In general, the method of developing the 

activity data and emissions seems reasonable. However, the method of determining the number of 

structures included in the 5 or more unit structures and applying the same amount of acreage disturbed for 

each of such structures, regardless of the actual number of units in the structure seems like it could be 

improved upon. Logic indicates that structures with more units will inherently disturb more soil than 

structures with fewer units. Missouri would suggest obtaining an average number of units per structure 

by region or county for the 5 or more unit category and then apply a derived factor to this average in 

order to more accurately estimate the area disturbed for the 5 or more unit category. Additionally it is 

noted that Missouri counties have one of two different silt content ratios (52% or 28.8%). The method of 

picking one soil classification for each county is acceptable if the majority of the cropland in the county is 

that particular soil classification, but this may not always be the case. Although acceptable, it is also noted 

that it rarely would be the case that all cropland in a county is of the same soil classification, and for future 

NEIs if resources permit, Missouri suggests using weighted percentages for soil classifications to develop 

the silt content percentage for each county, as this would likely yield more accurate values. While 

Missouri has several suggestions for how the method used in the emission estimation for this source category 

could be improved upon, no changes were made to EPA’s NEI results for this source category. 

f. References 

1. New Privately Owned Housing Units Started for 2010 (Not seasonally adjusted), available at: 

http://www.census.gov/const/startsua.pdf

2. Table 2au. New Privately Owned Housing Units Authorized - Unadjusted Units for Regions, Divisions, and 

States, Annual 2010, available at: http://www.census.gov/const/C40/Table2/tb2u2010.txt

3. Annual Housing Units Authorized by Building Permits CO2010A, purchased from US Department of 

Census 

4. Type of Foundation in New One-Family Houses Completed, available at: 

http://www.census.gov/const/C25Ann/sftotalfoundation.pdf

5. Midwest Research Institute. Improvement of Specific Emission Factors (BACM Project No. 1). Prepared 

for South Coast Air Quality Management District. March 29, 1996. 

6. Campbell, 1996: Campbell, S.G., D.R. Shimp, and S.R. Francis. Spatial Distribution of PM-10 Emissions 

from Agricultural Tilling in the San Joaquin Valley, pp. 119-127 in Geographic Information Systems in 

Environmental Resources Management, Air and Waste Management Association, Reno, NV. 1996. 

7. "Proposed Revisions to Fine Fraction Ratios Used for AP-42 Fugitive Dust Emission Factors," C. 

Cowherd, J. Donaldson and R. Hegarty, Midwest Research Institute; D. Ono, Great Basin UAPCD. 

http://www.epa.gov/ttn/chief/conference/ei15/session14/cowherd.pdf

   
115 

8.12 Fugitive Dust:  Mining and Quarrying

The Missouri DNR developed the following estimate of emission from this source category.  

a. Source Category Description

Mining and quarrying activities produce particulate emissions due to the variety of processes used to extract the

ore and associated overburden, including drilling and blasting, loading and unloading, and overburden

replacement. Fugitive dust emissions for mining and quarrying operations are the sum of emissions from the

mining of metallic and nonmetallic ores and coal. Each of these mining operations has specific emission factors

accounting for the different means by which the resources are extracted.  

For this source category the following SCC was assigned:

Source Classification Code SCC Level One SCC Level Two SCC Level Three SCC Level Four

2325000000

Industrial

Processes

Mining and Quarrying: SIC

14

All Processes Total

b. Emission Factors and Equations

Metallic Ore Mining

The emissions factor for metallic ore mining includes overburden removal, drilling and blasting, and loading and

unloading activities. The TSP emission factors developed for copper ore mining are applied to all three activities

with PM10/TSP ratios of 0.35 for overburden removal, 0.81 for drilling and blasting, and 0.43 for loading and

unloading operations.1 The emissions factor equation for metallic ore mining is:

EFmo =  EFo + (B x EFb) + EFl + EFd

where,   EFmo = metallic ore mining emissions factor (lbs/ton)

EFo = PM10 open pit overburden removal emission factor for copper ore (lbs/ton)

B = fraction of total ore production that is obtained by blasting at metallic ore mines

EFb = PM10 drilling/blasting emission factor for copper ore (lbs/ton)

EFl = PM10 loading emission factor for copper ore (lbs/ton)

EFd = PM10 truck dumping emission factor for copper ore (lbs/ton)
116 

Applying the copper ore mining TSP emissions factors2 and PM10/TSP ratios yields the following metallic ore mining

emissions factor:

EFmo = 0.0003 + (0.57625 x 0.0008) + 0.022 + 0.032 = 0.0548 lbs/ton

Non‐Metallic Ore Mining

The emissions factor for non‐metallic ore mining includes overburden removal, drilling and blasting, and loading

and unloading activities. The emissions factor is based on western surface coal mining operations.

EFnmo = EFv + (D x EFr) + EFa + 0.5 (EFe + EFt)

where,   EFnmo =  non‐metallic ore mining emissions factor (lbs/ton)

EFv = PM10 open pit overburden removal emission factor at western surface coal mining operations

(lbs/ton)

D = fraction of total ore production that is obtained by blasting at non‐metallic ore mines

EFr = PM10 drilling/blasting emission factor at western surface coal mining operations (lbs/ton)

EFa = PM10 loading emission factor at western surface coal mining operations (lbs/ton)

EFe = PM10 truck unloading: end dump‐coal emission factor at western surface coal mining operations

(lbs/ton)

EFt = PM10 truck unloading: bottom dump‐coal emission factor at western surface coal

mining operations (lbs/ton)

Applying the TSP emissions factors developed for western surface coal mining operations from AP‐423 and a

PM10/TSP ratio of 0.44 yields the following non‐metallic ore mining emissions factor:

EFnmo = 0.225 + (0.61542 x 0.00005) + 0.05 + 0.5 (0.0035 + 0.033) = 0.293 lbs/ton

Coal Mining
117 

The emissions factor for coal mining includes overburden removal, drilling and blasting, loading and unloading and

overburden replacement activities. The amount of overburden material handled is assumed to equal ten times the

quantity of coal mined and coal unloading is assumed to split evenly between end‐dump and bottom‐dump

operations. The emissions factor equation for coal mining is:

EFc = (10 × (EFto + EFor + EFdt)) + EFv + EFr +EFa + (0.5 × (EFe + EFt))

where,   EFc = coal mining emissions factor (lbs/ton)

EFto = PM10 emission factor for truck loading overburden at western surface coal mining operations

(lbs/ton of overburden)

EFor = PM10 emission factor for overburden replacement at western surface coal mining operations

(lbs/ton of overburden)

EFdt = PM10 emission factors for truck unloading: bottom dump‐overburden at western surface coal

mining operations (lbs/ton of overburden)

EFv = PM10 open pit overburden removal emission factor at western surface coal mining operations

(lbs/ton)

EFr = PM10 drilling/blasting emission factor at western surface coal mining operations (lbs/ton)

EFa = PM10 loading emission factor at western surface coal mining operations (lbs/ton)

EFe = PM10 truck unloading: end dump‐coal emission factor at western surface coal mining operations

(lbs/ton)

EFt = PM10 truck unloading: bottom dump‐coal emission factor at western surface coal mining operations

(lbs/ton)

Applying the PM10 emissions factors developed for western surface coal mining operations3 yields the following

coal mining emissions factor:

EFc = (10 × (0.015 + 0.001 + 0.006)) + 0.225 + 0.00005 + 0.05 + (0.5 × (0.0035 + 0.033)) = 0.513 lbs/ton

PM‐FIL emissions factors are assumed to be the same as PM‐PRI emissions factors; however, in reality, there is a

small amount of PM‐CON emissions included in the PM‐PRI emissions but insufficient data exists to tease out the

PM‐CON portion. In 2006, the EPA adopted new PM2.5/PM10 ratios for several fugitive dust categories and

concluded that the PM2.5/PM10 ratios for fugitive dust categories should be in the range of 0.1 to 0.15.5
118 

Consequently, a ratio of 0.125 was applied to the PM10 emissions factors to estimate PM2.5 emissions factors for

mining and quarrying. A summary of emissions factors is presented in the table below.

Summary of Emission Factors

Mining Type Pollutant Code Factor Numeric Value Factor Unit Numerator Factor Unit Denominator

Coal PM10‐PRI 0.513 LB TON

Coal PM10‐FIL 0.513 LB TON

Coal PM2.5‐PRI 0.064 LB TON

Coal PM2.5‐FIL 0.064 LB TON

Metallic PM10‐PRI 0.0548 LB TON

Metallic PM10‐FIL 0.0548 LB TON

Metallic PM2.5‐PRI 0.0068 LB TON

Metallic PM2.5‐FIL 0.0068 LB TON

Non‐Metallic PM10‐PRI 0.293 LB TON

Non‐Metallic PM10‐FIL 0.293 LB TON

Non‐Metallic PM2.5‐PRI 0.037 LB TON

Non‐Metallic PM2.5‐FIL 0.037 LB TON

c. Activity

Emissions were estimated by obtaining state‐level metallic and non‐metallic crude ore handled at surface mines

from the U.S. Geologic Survey (USGS) 6 and mine specific coal production data for surface mines from the Energy

Information Administration (EIA) 7

. Since some of the USGS metallic and non‐metallic minerals waste data

associated with ore production are withheld to avoid disclosing company proprietary data, an allocation procedure

was developed to estimate the withheld data. For states with withheld waste data, the state fraction of national

ore production was multiplied by the national undisclosed waste value to estimate the state withheld data. In

addition, the USGS only reports metallic and non‐metallic minerals production data separately at the national‐level

(e.g., the production data is combined at the state‐level). To estimate metallic versus non‐metallic ore production

and associated waste at the state‐level, the state‐level total production and waste data were multiplied by the

national metallic or non‐metallic percentage of total production.  

d. Activity Allocation Procedure
119 

State‐level metallic and non‐metallic crude ore and associated waste handled was allocated to the county‐level

using employment. Specifically, state‐level activity data was multiplied by the ratio of county‐ to state‐level

number of employees in the metallic and non‐metallic mining industries (see table below for a list of NAICS codes).  

NAICS Codes for Metallic and Non‐Metallic Mining

NAICS Code Description

2122 Metal Ore Mining

212210 Iron Ore Mining

21222 Gold Ore and Silver Ore Mining

212221 Gold Ore Mining

212222 Silver Ore Mining

21223 Copper, Nickel, Lead, and Zinc Mining

212231 Lead Ore and Zinc Ore Mining

212234 Copper Ore and Nickel Ore Mining

21229 Other Metal Ore Mining

212291 Uranium‐Radium‐Vanadium Ore Mining

212299 All Other Metal Ore Mining

2123 Nonmetallic Mineral Mining and Quarrying

21231 Stone Mining and Quarrying

212311 Dimension Stone Mining and Quarrying

212312 Crushed and Broken Limestone Mining and Quarrying

212313 Crushed and Broken Granite Mining and Quarrying

212319 Other Crushed and Broken Stone Mining and Quarrying

21232 Sand, Gravel, Clay, and Ceramic and Refractory Minerals Mining and Quarrying

212321 Construction Sand and Gravel Mining

212322 Industrial Sand Mining

212324 Kaolin and Ball Clay Mining

212325 Clay and Ceramic and Refractory Minerals Mining

21239 Other Nonmetallic Mineral Mining and Quarrying

212391 Potash, Soda, and Borate Mineral Mining

212392 Phosphate Rock Mining

212393 Other Chemical and Fertilizer Mineral Mining

212399 All Other Nonmetallic Mineral Mining

Employment data was obtained from the U.S. Census Bureau’s 2009 County Business Patterns (CBP).8

  Due to

concerns with releasing confidential business information, the CBP does not release exact numbers for a given
120 

NAICS code if there are enough data that individual businesses could be identified.  Instead a series of range codes

is used.  To estimate withheld counties the following procedure was used for each NAICS code being computed.  

1. County level data for counties with known employment were totaled by state.  

2. #1 subtracted from the state total reported in state‐level CBP.

3. Each of the withheld counties is assigned the midpoint of the range code (e.g., A:1‐19 employees would

be assigned 10).  

4. These midpoints are then summed to the state level.  

5. #2 is divided by #4 as an adjustment factor to the midpoints.  

6. #5 is multiplied by #3 to get the adjusted county‐level employment.

For example, take the 2006 CBP data for NAICS 31‐33 (Manufacturing) in Maine provided in the table below.

2006 County Business Pattern for NAICS 31‐33 in Maine

fipsstate fipscty naics empflag emp

23 001 31‐‐‐‐ 6774

23 003 31‐‐‐‐ 3124

23 005 31‐‐‐‐ 10333

23 007 31‐‐‐‐ 1786

23 009 31‐‐‐‐ 1954

23 011 31‐‐‐‐ 2535

23 013 31‐‐‐‐ 1418

23 015 31‐‐‐‐ F 0

23 017 31‐‐‐‐ 2888

23 019 31‐‐‐‐ 4522

23 021 31‐‐‐‐ 948

23 023 31‐‐‐‐ I 0

23 025 31‐‐‐‐ 4322

23 027 31‐‐‐‐ 1434

23 029 31‐‐‐‐ 1014

23 031 31‐‐‐‐ 9749
121 

1. The total of employees not including counties 015 and 023 is 52801.

2. The state‐level CBP reports 59322 employees for NAICS 31‐‐‐‐.  The difference is 6521.

3. County 015 is given a midpoint of 1750 (since range code F is 1000‐2499) and County 023 is given a

midpoint of 17500.

4. State total for these two counties is 19250.  

5. 6521/19250 = 0.33875.

6. The adjusted employment for county 015 is 1750*0.33875 = 592.82. County 023 has an adjusted

employment of 17500*0.33875 = 5928.18.

In the event that data at the state level is withheld, a similar procedure is first performed going from the U.S. level

to the state level.  For example, known state‐level employees are subtracted from the U.S. total yielding the total

withheld employees.  Next the estimated midpoints of the withheld states are added together and compared (by

developing a ratio) to the U.S. total withheld employees.  The midpoints are then adjusted by the ratio to give an

improved estimate of the state total.  

e. Controls

No controls were accounted for in the emissions estimation.

f. Emissions Equation and Sample Calculation

Fugitive dust emissions for mining and quarrying operations are the sum of emissions from the mining of metallic

and nonmetallic ores and coal:

E = Em + En + Ec

where,   E = PM10 emissions from mining and quarrying operations

Em = PM10 emissions from metallic ore mining operations

En = PM10 emissions from non‐metallic ore mining  

Ec = PM10 emissions from coal mining operations
122 

Four specific activities are included in the emissions estimate for mining and quarrying operations: overburden

removal, drilling and blasting, loading and unloading, and overburden replacement. Not included are the transfer

and conveyance operations, crushing and screening operations, and storage since the dust emissions from these

activities are assumed to be well controlled. Emissions for each activity are calculated using the following equation:

E = EF × A

where,   E = PM10 emissions from operation (e.g., metallic ore, non‐metallic ore, or coal mining; lbs)

EF = emissions factor associated with operation (lbs/ton)

A = ore handled in mining operation (tons)

As an example, in 2009 Autauga County, Alabama handled 456,346 tons of metallic ore and associated waste,

714,718 tons of non‐metallic ore and associated waste, and 0 tons of coal. Mining and quarrying PM10‐PRI

emissions for Autauga County are:

EPM10‐PRI, Autauga County  = [(456,346×0.0548) + (714,718×0.293) + (0×0.513)]/2000  = 117 tons

The division by 2000 is to convert from pounds to tons.

g. References

1. United States Environmental Protection Agency. Generalized Particle Size Distributions for Use in Preparing Size‐

Specific Particulate Emissions Inventories, EPA‐450/4‐86‐013, July 1986.

2. United States Environmental Protection Agency, National Air Pollutant Emission Trends Procedure Document for

1900‐1996, EPA‐454/R‐98‐008, May 1998.

3. United States Environmental Protection Agency, AP‐42, Fifth Edition, Volume 1, Chapter 11: Mineral Products

Industry, Section 11.9: Western Surface Coal Mining, available at

http://www.epa.gov/ttn/chief/ap42/ch11/final/c11s09.pdf (accessed November 2011).

4. United States Environmental Protection Agency, AIRS Facility Subsystem Source Classification Codes and

Emission Factor Listing for Criteria Air Pollutants, EPA‐450/4‐90‐003, March 1990.
123 

5. Midwest Research Institute, Background Document for Revisions to Fine Fraction Ratios Used for AP‐42 Fugitive

Dust Emission Factors, MRI Project No. 110397, November 2006, available at

http://www.epa.gov/ttnchie1/ap42/ch13/bgdocs/b13s02.pdf (accessed December 2011).

6. United States Geologic Survey, “Minerals Yearbook 2009”,

http://minerals.usgs.gov/minerals/pubs/commodity/m&q/index.html#myb (accessed April 2012).

7. Energy Information Administration, “Production by Company and Mine ‐ 2009”,

http://www.eia.gov/coal/data.cfm#production (accessed April 2012).

8. U.S. Census Bureau, 2009 County Business Patterns, available at

http://www.census.gov/econ/cbp/download/index.htm (accessed April 2012)

   

   
124 

8.13 Fugitive Dust:  Mining and Quarrying Lead Ore

The Missouri DNR developed the following estimate of emissions from this source category.

a. Source Category Description

Lead ore mining and milling is the process by which lead ore deposits are extracted and processed for transport to

primary lead smelting and refining.  The USGS1 demonstrates that six lead mines operate in Missouri, and their

emissions are reported as part of the point or nonpoint data category for the National Emissions Inventory (NEI).  

The Air Emissions Reporting Rule2 (AERR) §51.50 instructs states to submit point source data on the three‐year

cycle for those sources with potential to emit over specific pollutant thresholds.  Two of the six mines in Missouri

meet the point source threshold (see section C.).  Detailed information on those two operations is submitted based

on AERR requirements, including the list of emission generating equipment, control devices, and emission release

points.  Four of the mines, and their associated milling operations, do not meet the requirements to be submitted

as point sources, so their emission estimates are provided as a county‐total nonpoint category.   

For this nonpoint source category, the following source classification code (SCC) was created specifically at the

request of Missouri:

List of nonpoint SCC codes 

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

2325060000 Industrial Processes Mining and

Quarrying: SIC 10

Lead Ore Mining

and Milling

Total

b. Estimation Method

Missouri chose between two methods to develop emissions for this category:  use emission inventory data

collected from specific, stationary mining and milling sites, or use surrogate mining activity data with emission

assumptions.

The Emission Inventory Improvement Program4 (EIIP) Volume 3, Chapter 1 describes area source (now known as

nonpoint source) emission estimation methods states can choose from.  To obtain the most accurate inventory,

the most specific data collected and quality assured is preferable to surrogate activity data that is allocated to the

geographic region of interest.  For the lead mining and milling category, these facilities have reported emissions

directly to the state of Missouri as described in section c.  Using quality assured facility‐reported data ensures that

the inventory is developed in a bottom‐up fashion, as opposed to a top‐down method where activity data from a

much larger geographic region is used to estimate emissions and allocated down to the county level.    

c. Source Identification

The list of all lead mining and milling sites are listed in the corresponding tables below.  The lists are extracted from

emission inventory data collected for Missouri sources subject to 10 CSR 10‐6.1103

, for Standard Industrial

Classification (SIC) 1031 – Lead and Zinc Ores.  These sources obtain operating permits under 10 CSR 10‐6.0653

based on their potential to emit.  Nonpoint sources are those with Basic operating permits whose potential to emit

do not meet the AERR point source requirements.  
125 

List of Nonpoint Lead Ore Mining and Milling Facilities 

County

Plant

Id

Plant Name Site Name SIC Operating

Permit

Reynolds 0004 DOE RUN COMPANY SWEETWATER MINE/MILL 1031 Basic

Reynolds 0005

DOE RUN COMPANY‐

BRUSHY CREEK MINE/MILL VIBURNUM (BRUSHY CREEK) 1031

Basic

Iron 0017 DOE RUN COMPANY VIBURNUM DIVISION (CENTRAL) 1031 Basic

Iron 0023 DOE RUN COMPANY CASTEEL MINE 1031 Basic

Iron 0031 K AND D CRUSHING CASTEEL MINE 1031 Basic

Washington 0041 K AND D CRUSHING 29 MINE AREA 1031 Basic

List of Point Source Lead Ore Mining and Milling Facilities 

County

Plant

Id

Plant Name Site Name SIC Operating

Permit

Reynolds 0006 DOE RUN COMPANY BUNKER (FLETCHER MINE) 1031 Part 70

Iron 0005 DOE RUN COMPANY BUICK MILL 1031 Part 70

Additional searches were performed on Missouri databases to search for other mining or milling operations.  

Name searches for “lead”, “ore”, “milling”, “mining”, and other iterations returned various other facilities who

were investigated, but their permit documents excluded lead ore as their primary activity.  The archive of all

Missouri permit documents was searched for the same terms, but returned only facilities in tables above.  A search

of any other facility reporting lead emissions provided another list to review, but their permit documents and SICs

quickly eliminated them from consideration.  The lists above comprehensively cover the lead ore mining and

milling category.

d. External Data Source Comparison for Lead

EPA’s Toxics Release Inventory5 (TRI) was consulted as an external database to compare lead emissions as reported

to Missouri against those reported to EPA.  Missouri collects emission inventory data from all permitted sources on

the schedule outlined in 10 CSR 10‐6.110, including the nonpoint sources with Basic operating permits.  This   

Lead Emission Comparison 

County Plant Id Plant Name Site Name

Missouri Inventory Lead

Emissions (tons per year)

TRI Lead Emissions

(tons per year)

Reynolds 0004 DOE RUN COMPANY SWEETWATER MINE/MILL 0.29

1.45

Reynolds 0005

DOE RUN COMPANY‐

BRUSHY CREEK

MINE/MILL

VIBURNUM (BRUSHY CREEK) 0.70 .99

Iron 0017 DOE RUN COMPANY VIBURNUM DIVISION (CENTRAL) 0.18

0

Iron 0023 DOE RUN COMPANY CASTEEL MINE 0.20

NA

Iron 0031 K AND D CRUSHING CASTEEL MINE 0.20

NA

Washington 0041 K AND D CRUSHING 29 MINE AREA 0.0044 NA
126 

e. Emissions

The emission reports from the nonpoint facilities listed include both PM and lead emissions.  The point source SCC

codes used in these reports are:

SCC SCC Description

30501049 Wind Erosion: Exposed Areas

30502001 Primary Crushing

30502002 Secondary Crushing/Screening

30502006

Miscellaneous Operations:

Screen/Convey/Handling

30502009 Blasting: General

30502010 Drilling

30502011 Hauling

30502031 Truck Unloading

30502032 Truck Loading: Conveyor

30502507 Storage Piles

30301012 Raw Material Storage Piles

30301013 Raw Material Transfer

30303009 Raw Material Handling and Transfer

The emissions to be reported in the nonpoint category List of Nonpoint Lead Ore Mining and Milling Facilities are

summed in the Lead Emission Comparison Table so they can be allocated to the county level.   

f. References

1. USGS Commodity Statistics and Information 2012  

http://minerals.usgs.gov/minerals/pubs/commodity/lead/mcs‐2012‐lead.pdf

2. USEPA’s Air Emissions Reporting Rule, published December 4, 2008.  http://www.epa.gov/ttnchie1/aerr/

3. Missouri Code of State Regulations.  http://www.sos.mo.gov/adrules/csr/current/10csr/10c10‐6a.pdf
127 

4. Emission Inventory Improvement Program, EIIP Technical Report Series 3‐ Area Sources 2001.  

http://www.epa.gov/ttn/chief/eiip/techreport/volume03/index.html

5. USEPA’s Toxics Release Inventory (TRI) 2011 TRI Data Explorer.  http://www.epa.gov/TRI/

   

   
128 

8.14 Fugitive Dust Paved Roads

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  The documentation

below was developed by EPA.   

a. Source Category Description

Mining and quarrying activities produce particulate emissions due to the variety of processes used to extract the

ore and associated overburden, including drilling and blasting, loading and unloading, and overburden

replacement. Fugitive dust emissions for mining and quarrying operations are the sum of emissions from the

mining of metallic and nonmetallic ores and coal. Each of these mining operations has specific emission factors

accounting for the different means by which the resources are extracted.  

For this source category the following SCC was assigned:

Source Classification Code SCC Level One SCC Level Two SCC Level Three SCC Level Four

2325000000

Industrial

Processes

Mining and Quarrying: SIC

14

All Processes Total

b. Emission Factors and Equations

Metallic Ore Mining

The emissions factor for metallic ore mining includes overburden removal, drilling and blasting, and loading and

unloading activities. The TSP emission factors developed for copper ore mining are applied to all three activities

with PM10/TSP ratios of 0.35 for overburden removal, 0.81 for drilling and blasting, and 0.43 for loading and

unloading operations.1 The emissions factor equation for metallic ore mining is:

EFmo =  EFo + (B x EFb) + EFl + EFd

where,   EFmo = metallic ore mining emissions factor (lbs/ton)

EFo = PM10 open pit overburden removal emission factor for copper ore (lbs/ton)

B = fraction of total ore production that is obtained by blasting at metallic ore mines

EFb = PM10 drilling/blasting emission factor for copper ore (lbs/ton)

EFl = PM10 loading emission factor for copper ore (lbs/ton)
129 

EFd = PM10 truck dumping emission factor for copper ore (lbs/ton)

Applying the copper ore mining TSP emissions factors2 and PM10/TSP ratios yields the following metallic ore mining

emissions factor:

EFmo = 0.0003 + (0.57625 x 0.0008) + 0.022 + 0.032 = 0.0548 lbs/ton

Non‐Metallic Ore Mining

The emissions factor for non‐metallic ore mining includes overburden removal, drilling and blasting, and loading

and unloading activities. The emissions factor is based on western surface coal mining operations.

EFnmo = EFv + (D x EFr) + EFa + 0.5 (EFe + EFt)

where,   EFnmo =  non‐metallic ore mining emissions factor (lbs/ton)

EFv = PM10 open pit overburden removal emission factor at western surface coal mining operations

(lbs/ton)

D = fraction of total ore production that is obtained by blasting at non‐metallic ore mines

EFr = PM10 drilling/blasting emission factor at western surface coal mining operations (lbs/ton)

EFa = PM10 loading emission factor at western surface coal mining operations (lbs/ton)

EFe = PM10 truck unloading: end dump‐coal emission factor at western surface coal mining operations

(lbs/ton)

EFt = PM10 truck unloading: bottom dump‐coal emission factor at western surface coal

mining operations (lbs/ton)

Applying the TSP emissions factors developed for western surface coal mining operations from AP‐423 and a

PM10/TSP ratio of 0.44 yields the following non‐metallic ore mining emissions factor:

EFnmo = 0.225 + (0.61542 x 0.00005) + 0.05 + 0.5 (0.0035 + 0.033) = 0.293 lbs/ton
130 

Coal Mining

The emissions factor for coal mining includes overburden removal, drilling and blasting, loading and unloading and

overburden replacement activities. The amount of overburden material handled is assumed to equal ten times the

quantity of coal mined and coal unloading is assumed to split evenly between end‐dump and bottom‐dump

operations. The emissions factor equation for coal mining is:

EFc = (10 × (EFto + EFor + EFdt)) + EFv + EFr +EFa + (0.5 × (EFe + EFt))

where,   EFc = coal mining emissions factor (lbs/ton)

EFto = PM10 emission factor for truck loading overburden at western surface coal mining operations

(lbs/ton of overburden)

EFor = PM10 emission factor for overburden replacement at western surface coal mining operations

(lbs/ton of overburden)

EFdt = PM10 emission factors for truck unloading: bottom dump‐overburden at western surface coal

mining operations (lbs/ton of overburden)

EFv = PM10 open pit overburden removal emission factor at western surface coal mining operations

(lbs/ton)

EFr = PM10 drilling/blasting emission factor at western surface coal mining operations (lbs/ton)

EFa = PM10 loading emission factor at western surface coal mining operations (lbs/ton)

EFe = PM10 truck unloading: end dump‐coal emission factor at western surface coal mining operations

(lbs/ton)

EFt = PM10 truck unloading: bottom dump‐coal emission factor at western surface coal mining operations

(lbs/ton)

Applying the PM10 emissions factors developed for western surface coal mining operations3 yields the following

coal mining emissions factor:

EFc = (10 × (0.015 + 0.001 + 0.006)) + 0.225 + 0.00005 + 0.05 + (0.5 × (0.0035 + 0.033)) = 0.513 lbs/ton
131 

PM‐FIL emissions factors are assumed to be the same as PM‐PRI emissions factors; however, in reality, there is a

small amount of PM‐CON emissions included in the PM‐PRI emissions but insufficient data exists to tease out the

PM‐CON portion. In 2006, the EPA adopted new PM2.5/PM10 ratios for several fugitive dust categories and

concluded that the PM2.5/PM10 ratios for fugitive dust categories should be in the range of 0.1 to 0.15.5

Consequently, a ratio of 0.125 was applied to the PM10 emissions factors to estimate PM2.5 emissions factors for

mining and quarrying. A summary of emissions factors is presented in the table below.

Summary of Emission Factors

Mining Type Pollutant Code Factor Numeric Value Factor Unit Numerator Factor Unit Denominator

Coal PM10‐PRI 0.513 LB TON

Coal PM10‐FIL 0.513 LB TON

Coal PM2.5‐PRI 0.064 LB TON

Coal PM2.5‐FIL 0.064 LB TON

Metallic PM10‐PRI 0.0548 LB TON

Metallic PM10‐FIL 0.0548 LB TON

Metallic PM2.5‐PRI 0.0068 LB TON

Metallic PM2.5‐FIL 0.0068 LB TON

Non‐Metallic PM10‐PRI 0.293 LB TON

Non‐Metallic PM10‐FIL 0.293 LB TON

Non‐Metallic PM2.5‐PRI 0.037 LB TON

Non‐Metallic PM2.5‐FIL 0.037 LB TON

c. Activity

Emissions were estimated by obtaining state‐level metallic and non‐metallic crude ore handled at surface mines

from the U.S. Geologic Survey (USGS) 6 and mine specific coal production data for surface mines from the Energy

Information Administration (EIA) 7

. Since some of the USGS metallic and non‐metallic minerals waste data

associated with ore production are withheld to avoid disclosing company proprietary data, an allocation procedure

was developed to estimate the withheld data. For states with withheld waste data, the state fraction of national

ore production was multiplied by the national undisclosed waste value to estimate the state withheld data. In

addition, the USGS only reports metallic and non‐metallic minerals production data separately at the national‐level

(e.g., the production data is combined at the state‐level). To estimate metallic versus non‐metallic ore production

and associated waste at the state‐level, the state‐level total production and waste data were multiplied by the

national metallic or non‐metallic percentage of total production.  
132 

d. Activity Allocation Procedure

State‐level metallic and non‐metallic crude ore and associated waste handled was allocated to the county‐level

using employment. Specifically, state‐level activity data was multiplied by the ratio of county‐ to state‐level

number of employees in the metallic and non‐metallic mining industries (see table below for a list of NAICS codes).  

NAICS Codes for Metallic and Non‐Metallic Mining

NAICS Code Description

2122 Metal Ore Mining

212210 Iron Ore Mining

21222 Gold Ore and Silver Ore Mining

212221 Gold Ore Mining

212222 Silver Ore Mining

21223 Copper, Nickel, Lead, and Zinc Mining

212231 Lead Ore and Zinc Ore Mining

212234 Copper Ore and Nickel Ore Mining

21229 Other Metal Ore Mining

212291 Uranium‐Radium‐Vanadium Ore Mining

212299 All Other Metal Ore Mining

2123 Nonmetallic Mineral Mining and Quarrying

21231 Stone Mining and Quarrying

212311 Dimension Stone Mining and Quarrying

212312 Crushed and Broken Limestone Mining and Quarrying

212313 Crushed and Broken Granite Mining and Quarrying

212319 Other Crushed and Broken Stone Mining and Quarrying

21232 Sand, Gravel, Clay, and Ceramic and Refractory Minerals Mining and Quarrying

212321 Construction Sand and Gravel Mining

212322 Industrial Sand Mining

212324 Kaolin and Ball Clay Mining

212325 Clay and Ceramic and Refractory Minerals Mining

21239 Other Nonmetallic Mineral Mining and Quarrying

212391 Potash, Soda, and Borate Mineral Mining

212392 Phosphate Rock Mining

212393 Other Chemical and Fertilizer Mineral Mining

212399 All Other Nonmetallic Mineral Mining
133 

Employment data was obtained from the U.S. Census Bureau’s 2009 County Business Patterns (CBP).8  Due to

concerns with releasing confidential business information, the CBP does not release exact numbers for a given

NAICS code if there are enough data that individual businesses could be identified.  Instead a series of range codes

is used.  To estimate withheld counties the following procedure was used for each NAICS code being computed.  

7. County level data for counties with known employment were totaled by state.  

8. #1 subtracted from the state total reported in state‐level CBP.

9. Each of the withheld counties is assigned the midpoint of the range code (e.g., A:1‐19 employees would

be assigned 10).  

10. These midpoints are then summed to the state level.  

11. #2 is divided by #4 as an adjustment factor to the midpoints.  

12. #5 is multiplied by #3 to get the adjusted county‐level employment.

For example, take the 2006 CBP data for NAICS 31‐33 (Manufacturing) in Maine provided in the table below.

2006 County Business Pattern for NAICS 31‐33 in Maine

fipsstate fipscty naics empflag emp

23 001 31‐‐‐‐ 6774

23 003 31‐‐‐‐ 3124

23 005 31‐‐‐‐ 10333

23 007 31‐‐‐‐ 1786

23 009 31‐‐‐‐ 1954

23 011 31‐‐‐‐ 2535

23 013 31‐‐‐‐ 1418

23 015 31‐‐‐‐ F 0

23 017 31‐‐‐‐ 2888

23 019 31‐‐‐‐ 4522

23 021 31‐‐‐‐ 948

23 023 31‐‐‐‐ I 0

23 025 31‐‐‐‐ 4322

23 027 31‐‐‐‐ 1434
134 

fipsstate fipscty naics empflag emp

23 029 31‐‐‐‐ 1014

23 031 31‐‐‐‐ 9749

7. The total of employees not including counties 015 and 023 is 52801.

8. The state‐level CBP reports 59322 employees for NAICS 31‐‐‐‐.  The difference is 6521.

9. County 015 is given a midpoint of 1750 (since range code F is 1000‐2499) and County 023 is given a

midpoint of 17500.

10. State total for these two counties is 19250.  

11. 6521/19250 = 0.33875.

12. The adjusted employment for county 015 is 1750*0.33875 = 592.82. County 023 has an adjusted

employment of 17500*0.33875 = 5928.18.

In the event that data at the state level is withheld, a similar procedure is first performed going from the U.S. level

to the state level.  For example, known state‐level employees are subtracted from the U.S. total yielding the total

withheld employees.  Next the estimated midpoints of the withheld states are added together and compared (by

developing a ratio) to the U.S. total withheld employees.  The midpoints are then adjusted by the ratio to give an

improved estimate of the state total.  

e. Controls

No controls were accounted for in the emissions estimation.

f. Emissions Equation and Sample Calculation

Fugitive dust emissions for mining and quarrying operations are the sum of emissions from the mining of metallic

and nonmetallic ores and coal:

E = Em + En + Ec

where,   E = PM10 emissions from mining and quarrying operations

Em = PM10 emissions from metallic ore mining operations

En = PM10 emissions from non‐metallic ore mining  

Ec = PM10 emissions from coal mining operations
135 

Four specific activities are included in the emissions estimate for mining and quarrying operations: overburden

removal, drilling and blasting, loading and unloading, and overburden replacement. Not included are the transfer

and conveyance operations, crushing and screening operations, and storage since the dust emissions from these

activities are assumed to be well controlled. Emissions for each activity are calculated using the following equation:

E = EF × A

where,   E = PM10 emissions from operation (e.g., metallic ore, non‐metallic ore, or coal mining; lbs)

EF = emissions factor associated with operation (lbs/ton)

A = ore handled in mining operation (tons)

As an example, in 2009 Autauga County, Alabama handled 456,346 tons of metallic ore and associated waste,

714,718 tons of non‐metallic ore and associated waste, and 0 tons of coal. Mining and quarrying PM10‐PRI

emissions for Autauga County are:

EPM10‐PRI, Autauga County  = [(456,346×0.0548) + (714,718×0.293) + (0×0.513)]/2000  = 117 tons

The division by 2000 is to convert from pounds to tons.

g. References

1. United States Environmental Protection Agency. Generalized Particle Size Distributions for Use in Preparing Size‐

Specific Particulate Emissions Inventories, EPA‐450/4‐86‐013, July 1986.

2. United States Environmental Protection Agency, National Air Pollutant Emission Trends Procedure Document for

1900‐1996, EPA‐454/R‐98‐008, May 1998.

3. United States Environmental Protection Agency, AP‐42, Fifth Edition, Volume 1, Chapter 11: Mineral Products

Industry, Section 11.9: Western Surface Coal Mining, available at

http://www.epa.gov/ttn/chief/ap42/ch11/final/c11s09.pdf (accessed November 2011).

4. United States Environmental Protection Agency, AIRS Facility Subsystem Source Classification Codes and

Emission Factor Listing for Criteria Air Pollutants, EPA‐450/4‐90‐003, March 1990.
136 

5. Midwest Research Institute, Background Document for Revisions to Fine Fraction Ratios Used for AP‐42 Fugitive

Dust Emission Factors, MRI Project No. 110397, November 2006, available at

http://www.epa.gov/ttnchie1/ap42/ch13/bgdocs/b13s02.pdf (accessed December 2011).

6. United States Geologic Survey, “Minerals Yearbook 2009”,

http://minerals.usgs.gov/minerals/pubs/commodity/m&q/index.html#myb (accessed April 2012).

7. Energy Information Administration, “Production by Company and Mine ‐ 2009”,

http://www.eia.gov/coal/data.cfm#production (accessed April 2012).

8. U.S. Census Bureau, 2009 County Business Patterns, available at

http://www.census.gov/econ/cbp/download/index.htm (accessed April 2012)

   
137 

8.15 Fugitive Dust:  Unpaved Roads

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation was

provided by EPA.

   
138 

8.16 Asphalt Plants

The Missouri DNR developed the following estimate of emissions from this source category.

a. Source Category Description 

Asphalt plants operate throughout the state to provide materials for public and private road paving. The Air 

Emissions Reporting Rule2

 (AERR) §51.50 instructs states to submit point source data on the three-year cycle for 

those sources with potential to emit over specific pollutant thresholds. Of the 110 asphalt plants in Missouri, 12 are 

submitted as point sources. Detailed information on those 12 operations is submitted based on AERR requirements, 

including the list of emission generating equipment, control devices, and emission release points. 98 of the 

facilities, and their associated asphalt operations, do not meet the requirements to be submitted as point sources, so 

their emission estimates are provided as a county-total nonpoint category. 

For this nonpoint source category, the following source classification code (SCC) will report nonpoint asphalt plant 

emissions: 

List of nonpoint SCC codes 

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4 

2306000000 Industrial Processes Petroleum

Refining: SIC 29 All Processes Total

b. Estimation Method 

Missouri chose between two methods to develop emissions for this category: use emission inventory data collected 

from specific, stationary asphalt plants, or use surrogate activity data with emission assumptions. 

The Emission Inventory Improvement Program4

 (EIIP) Volume 3, Chapter 1 describes area source (now known as 

nonpoint source) emission estimation methods states can choose from. To obtain the most accurate inventory, the 

most specific data collected and quality assured is preferable to surrogate activity data that is allocated to the 

geographic region of interest. For the asphalt plant category, these facilities have reported emissions directly to the 

state of Missouri as described in section c. Using quality assured facility-reported data ensures that the inventory is 

developed in a bottom-up fashion, as opposed to a top-down method where activity data from a much larger 

geographic region is used to estimate emissions and allocated down to the county level. 

c. Source Identification 

The names of all asphalt sites are listed in the corresponding tables above. The lists are extracted from emission 

inventory data collected for Missouri sources subject to 10 CSR 10-6.1103

. Any facility reporting an SCC for 

asphalt plant , is included in these lists. Nonpoint sources are those with Basic (BAS) or Intermediate (INT) 

operating permits whose potential to emit do not meet the AERR point source requirements. Other facilities with no 

operating permits (NOP) are included because they have voluntarily taken limits via a construction permit. 

Facilities with a construction permit are required to submit emission reports to the state. 

Missouri had 33 asphalt plants that reported their 2011 Missouri emissions under a portable number. They can 

move their equipment to different counties in the state (and also out of state). The asphalt emissions from the 

portable equipment are approximately a third of the total nonpoint emissions for Missouri. This is a significant 

amount and it was decided to include these emissions in the inventory. These emissions are proportioned to the 

counties that reported asphalt emissions. The distribution of the portable emissions is weighted based upon the 

amount of reported nonpoint emissions from the stationary sources in each county. 

List of Nonpoint Asphalt Facilities 

County Plant ID Plant Name Site Name
139 

County Plant ID Plant Name Site Name

29001 0002 W. L. MILLER COMPANY KIRKSVILLE PLANT

29009 0042 HUTCHENS CONSTRUCTION COMPANY PURDY PLANT

29019 0065 APAC MISSOURI PLANT 03

29023 0021 DELTA ASPHALT INC POPLAR BLUFF PLANT

29027 0054 CHRISTENSEN ASPHALT KINGDOM CITY

29027 P028 APAC MISSOURI MILLERSBURG ‐ PLANT 15

29029 0016 APAC MISSOURI PLANT 8 ‐ LINN CREEK

29037 0032 APAC KANSAS INC HARRISONVILLE ASPHALT PLANT

29043 0005 LEO JOURNAGAN CONSTRUCTION CO OZARK

29047 0182 IDEKER INC MOSBY

29047 2219 SUPERIOR ASPHALT COMPANY INC KANSAS CITY

29047 2221 CARTER‐WATERS CORPORATION SKILES FACILITY

29051 0040 ASPHALT PRODUCTS INC JEFFERSON CITY PLANT

29055 0048 ASPHALT PRODUCTS INC CRAWFORD LIME

29055 P027 N. B. WEST CONTRACTING CO INC BOURBON

29071 0202 MID MISSOURI ASPHALT LLC ST. CLAIR

29071 P123 N. B. WEST CONTRACTING CO INC PACIFIC PLANT

29077 0131 APAC MISSOURI WILLARD PLANT 2

29077 0259 BLEVINS ASPHALT CONSTRUCTION CO INC HWY 60

29079 0014 TRENTON STREET DEPARTMENT TRENTON STREET DEPARTMENT

29083 0011 APAC MO, INC TIGHTWAD (LEESVILLE) QUARRY

29091 0077 FOSTER REDI‐MIX PLANT #1 WEST PLAINS

29091 0083 PACE CONSTRUCTION DOSS & HARPER QUARRY

29095 0003 J. M. FAHEY CONSTRUCTION COMPANY TRACY PLANT

29095 0061 APAC KANSAS SUGAR CREEK PLANT

29095 0089 SUPERIOR ASPHALT INC LEE'S SUMMIT PLANT

29095 0176 SUPERIOR BOWEN ASPHALT CO LLC MANCHESTER ROAD SITE

29095 0192 SUPERIOR BOWEN ASPHALT COMPANY LLC LEE'S SUMMIT (PLANT 3)

29095 2052 SUPERIOR ASPHALT PORTABLE PLANT KANSAS CITY

29095 2440 HOT MIX MATERIALS INC 85TH ST

29097 0017 CARTHAGE CRUSHED LIMESTONE CARTHAGE CRUSHED LIMESTONE

29097 0139 SWIFT CONSTRUCTION COMPANY INC JOPLIN PLANT

29097 0146 BLEVINS ASPHALT CONSTRUCTION CO INC CARTHAGE ‐ CIVIL WAR ROAD

29099 0007 FRED WEBER INC FESTUS ASPHALT PLANT

29099 0098 FRED WEBER INC TRAUTMAN ASPHALT PLANT

29099 0146 PACE CONSTRUCTION CO ANTONIA ASPHALT PLANT

29099 P094 N. B. WEST CONTRACTING CO INC HOUSE SPRINGS ASPHALT

29101 0031 HILTY QUARRIES INC WARRENSBURG II QUARRY

29105 0027 WILLARD QUARRIES INC SLEEPER QUARRY

29113 0032 G & M CONCRETE AND ASPHALT CO INC TROY PLANT

29113 0069 PACE CONSTRUCTION CO CENTRAL‐MOSCOW MILLS
140 

County Plant ID Plant Name Site Name

29119 0024 HUTCHENS CONSTRUCTION COMPANY BELLA VISTA FACILITY

29139 0025 PACE CONSTRUCTION CO DANVILLE PLANT

29143 0003 DELTA ASPHALT INC NEW MADRID PLANT

29151 0037 HIGGINS QUARRY LLC MUENKS QUARRY SITE

29157 0032 LAFARGE WEST INC PERRYVILLE ASPHALT

29159 0002 APAC‐MISSOURI SEDALIA QUARRY & ASPHALT

29159 0038 MID‐MISSOURI LIMESTONE INC HOUSTONIA QUARRY

29161 0009 ASPHALT PRODUCTS INC ROLLA PLANT

29161 0034 MELROSE QUARRY AND ASPHALT LLC ROLLA

29165 2402 SUPERIOR BOWEN ASPHALT CO LLC 144TH (PLANT 2)

29165 2422 SUPERIOR BOWEN ASPHALT CO LLC KCI

29169 0027 WILLARD QUARRIES COMPANY INC ST. ROBERT QUARRY

29173 0019 C. B. ASPHALT INC HUNTINGTON PLANT (PLANT #4)

29175 0049 APAC MISSOURI PLANT #5

29183 0096 PACE CONSTRUCTION CO ST. CHARLES PLANT

29187 0001 LEAD BELT MATERIALS CO INC PARK HILLS

29187 0072 BASE ROCK MINERALS INC BONNE TERRE PLANT

29189 0040 PACE CONSTRUCTION CO. JEFFERSON BARRICKS PLANT

29189 0201 PACE CONSTRUCTION CO ANTIRE QUARRY PLANT

29189 1521 PACE CONSTRUCTION CO FLORISSANT

29189 1523 MISSOURI VALLEY ASPHALT LLC BRIDGETON

29195 0005 APAC MISSOURI MARSHALL PLANT

29207 0001 ASA ASPHALT INC ADVANCE

29213 0003 TABLE ROCK ASPHALT CONSTR CO INC HWY 248 QUARRY

29777 0016 LEO JOURNAGAN CONSTRUCTION CO LEO JOURNAGAN CONSTRUCTION CO

29777 0059 LEO JOURNAGAN CONSTRUCTION CO LEO JOURNAGAN CONSTRUCTION CO

29777 0061 APAC MISSOURI APAC MISSOURI

29777 0093 APAC MISSOURI PORTABLE PLANT #403

29777 0150 APAC MISSOURI APAC MISSOURI

29777 0157 APAC MISSOURI

MASTERS JACKSON/SPRINGFIELD DIV. PORT

#2

29777 0232 C. B. ASPHALT INC PLANT #6

29777 0269 C. B. ASPHALT INC PLANT #7

29777 0310 DELTA ASPHALT INC CEDAR RAPIDS PORTABLE

29777 0352 NORRIS ASPHALT PAVING CO NORRIS ASPHALT PAVING CO

29777 0361 FRED WEBER INC FRED WEBER INC

29777 0363 W. L. MILLER CO W. L. MILLER CO

29777 0396 APAC MISSOURI CMI‐ASPHALT

29777 0414 APAC MISSOURI APAC MISSOURI

29777 0439 APAC MISSOURI APAC‐CENTRAL

29777 0441 C. B. ASPHALT INC C. B. ASPHALT INC
141 

County Plant ID Plant Name Site Name

29777 0447 HERZOG CONTRACTING HERZOG CONTRACTING

29777 0501 PACE CONSTRUCTION COMPANY PACE CONSTRUCTION COMPANY

29777 0518 FRED WEBER INC PORTABLE CMI #1

29777 0520 C. B. ASPHALT INC PLANT # 9

29777 0521 HILTY QUARRIES INC HILTY QUARRIES INC

29777 0525 LEO JOURNAGAN CONSTRUCTION CO LEO JOURNAGAN CONSTRUCTION CO

29777 0546 NORRIS ASPHALT PAVING CO PLANT 500

29777 0547

LAKE ASPHALT PAVING AND

CONSTRUCTION LAKE ASPHALT PAVING AND CONSTRUCTION

29777 0549 LEO JOURNAGAN CONSTRUCTION CO 10‐009

29777 0552 APAC‐SHEARS APAC‐SHEARS

29777 0562 IDEKER INC IDEKER INC

29777 0564 PACE CONSTRUCTION CO PACE CONSTRUCTION CO

29777 0581 APAC MISSOURI APAC MISSOURI

29777 0657 A.E. SIMPSON CONSTRUCTION PORTABLE ASPHALT

29777 0658 MAGRUDER PAVING LLC PORTABLE ASPHALT

29777 0661 FRED WEBER INC PORTABLE CMI #2

29777 0667 MAGRUDER PAVING MAGRUDER PAVING

List of Point Source Asphalt Facilities 

County Plant ID Plant Name Site Name

29003 P011 KELLER CONSTRUCTION COMPANY ST. JOSEPH

29031 0002 DELTA ASPHALT INC CAPE GIRARDEAU

29095 0037 VANCE BROTHERS INC BRIGHTON

29095 0064 VANCE BROTHERS INC CHELSEA

29183 0004 FRED WEBER INC O'FALLON ASPHALT PLANT

29187 0054 LEAD BELT MATERIALS CO INC BONNE TERRE

29189 0111 MISSOURI ASPHALT PRODUCTS, LLC WEST LAKE QUARRY & MATERIAL CO

29189 1226 SIMPSON CONSTRUCTION MATERIALS LLC VALLEY PARK

29189 1248 FRED WEBER INC. ‐ SOUTH ASPHALT (BATCH) SOUTH ASPHALT

29189 1249 FRED WEBER INC ‐ NORTH ASPHALT H AND B NORTH ASPHALT, H&B

29189 1250 FRED WEBER INC. ‐ NORTH ASPHALT B‐G NORTH ASPHALT, B‐G

29510 0047 FRED WEBER INC ASPHALT PLANT

d. Controls and Emission Factors 

Almost all controls at a typical Missouri asphalt plant are for PM emissions. These controls are for haul roads and 

storage piles which are watered to keep the dust down. 

The source of emission factors for the asphalt operations is almost exclusively from AP-42or FIRE. Haul road and 

storage pile worksheets are also used to determine emission factors. Formulas in these worksheets are pulled from 

AP-42. 
142 

e. Emissions 

The emission reports from the nonpoint facilities listed include the pollutants in the table below. HAPs are not 

included except for Lead which Missouri collects from all sources. HAPs, when they are reported, are usually 

reported as a sum total and not broken out into specific pollutants. None of the 98 non-point sources on our list 

reported NH3. 

List of Pollutants

Pollutant Name

PM10-PRI

PM2.5-PRI

SO2

NOX

VOC

CO

Lead

List of Asphalt SCCs and Description

SCC

Description

Level 1

Description

Level 2

Description

Level 3 Description Level 4

30500201

Industrial

Processes

Mineral

Products

Asphalt

Concrete Rotary Dryer: Conventional Plant (see 3‐05‐002‐50 to ‐53 for subtypes)

30500202

Industrial

Processes

Mineral

Products

Asphalt

Concrete Batch Mix Plant: Hot Elevs, Screens, Bins&Mixer (also see ‐45 thru ‐47

30500203

Industrial

Processes

Mineral

Products

Asphalt

Concrete Storage Piles

30500204

Industrial

Processes

Mineral

Products

Asphalt

Concrete Cold Aggregate Handling

30500205

Industrial

Processes

Mineral

Products

Asphalt

Concrete Drum Dryer: Drum Mix Plant (see 3‐05‐002‐55 thru ‐63 for subtypes)

30500206

Industrial

Processes

Mineral

Products

Asphalt

Concrete Asphalt Heater: Natural Gas

30500207

Industrial

Processes

Mineral

Products

Asphalt

Concrete Asphalt Heater: Residual Oil

30500208

Industrial

Processes

Mineral

Products

Asphalt

Concrete Asphalt Heater: Distillate Oil

30500209

Industrial

Processes

Mineral

Products

Asphalt

Concrete Asphalt Heater: LPG

30500211

Industrial

Processes

Mineral

Products

Asphalt

Concrete Rotary Dryer Conventional Plant with Cyclone ** use 3‐05‐002‐01 w/CTL

30500212

Industrial

Processes

Mineral

Products

Asphalt

Concrete Heated Asphalt Storage Tanks

30500213

Industrial

Processes

Mineral

Products

Asphalt

Concrete Storage Silo

30500214

Industrial

Processes

Mineral

Products

Asphalt

Concrete Truck Load‐out

30500216

Industrial

Processes

Mineral

Products

Asphalt

Concrete Cold Aggregate Feed Bins

30500217

Industrial

Processes

Mineral

Products

Asphalt

Concrete Cold Aggregate Conveyors and Elevators

30500231

Industrial

Processes

Mineral

Products

Asphalt

Concrete Hot Bins and Screens: Continuous Process

30500240

Industrial

Processes

Mineral

Products

Asphalt

Concrete Mixers: Batch Process (also see ‐45 thru ‐47 for combos w/scr,bins

30500245 Industrial Mineral Asphalt Batch Mix Plant: Hot Elevators, Screens, Bins, Mixer & NG Rot Dryer
143 

SCC

Description

Level 1

Description

Level 2

Description

Level 3 Description Level 4

Processes Products Concrete

30500246

Industrial

Processes

Mineral

Products

Asphalt

Concrete Batch Mix Plant: Hot Elevators, Screens, Bins, Mixer& #2 Oil Rot Dryer

30500247

Industrial

Processes

Mineral

Products

Asphalt

Concrete Batch Mix Plant: Hot Elevs, Scrns, Bins, Mixer& Waste/Drain/#6 Oil Rot

30500251

Industrial

Processes

Mineral

Products

Asphalt

Concrete Batch Mix Plant: Rotary Dryer, Natural Gas‐Fired (also see ‐45)

30500252

Industrial

Processes

Mineral

Products

Asphalt

Concrete Batch Mix Plant: Rotary Dryer, Oil‐Fired (also see ‐46)

30500255

Industrial

Processes

Mineral

Products

Asphalt

Concrete Drum Mix Plant: Rotary Drum Dryer / Mixer, Natural Gas‐Fired

30500257

Industrial

Processes

Mineral

Products

Asphalt

Concrete Drum Mix Plant: Rotary Drum Dryer / Mixer, Natural Gas, Counterflow

30500258

Industrial

Processes

Mineral

Products

Asphalt

Concrete Drum Mix Plant: Rotary Drum Dryer / Mixer, #2 Oil‐Fired

30500259

Industrial

Processes

Mineral

Products

Asphalt

Concrete Drum Mix Plant: Rotary Drum Dryer / Mixer, #2 Oil‐Fired, Parallel Flow

30500260

Industrial

Processes

Mineral

Products

Asphalt

Concrete Drum Mix Plant: Rotary Drum Dryer / Mixer, #2 Oil‐Fired, Counterflow

30500261

Industrial

Processes

Mineral

Products

Asphalt

Concrete Drum Mix Plant: Rotary Drum Dryer/Mixer, Waste/Drain/#6 Oil‐Fired

30500263

Industrial

Processes

Mineral

Products

Asphalt

Concrete

Drum Mix Pl: Rotary Drum Dryer/Mixer, Waste/Drain/#6 Oil,

Counterflow

30500290

Industrial

Processes

Mineral

Products

Asphalt

Concrete Haul Roads: General

30500298

Industrial

Processes

Mineral

Products

Asphalt

Concrete Other Not Classified

30500299

Industrial

Processes

Mineral

Products

Asphalt

Concrete See Comment **

30505005

Industrial

Processes

Mineral

Products

Asphalt

Processing

(Blowing) Asphalt Storage (Prior to Blowing)

30505022

Industrial

Processes

Mineral

Products

Asphalt

Processing

(Blowing) Asphalt Heater: Distillate Oil

The emissions to be reported in the nonpoint category for facilities List of Nonpoint Asphalt Facilities are summed 

to the county level in the table below. 

Nonpoint County Total Emissions for Asphalt Processes (tons per year)

StateFIPs County PM10‐PRI

PM2.5‐

PRI SO2 NOX VOC CO Lead

29001 ADAIR 1.13 0.60 0.30 0.36 0.17 1.05   

29009 BARRY 1.62 0.41 1.10 2.15 0.54 1.95   

29019 BOONE 5.04 0.40 0.11 5.34 2.91 11.25   

29023 BUTLER 8.59 1.98 3.46 4.87 3.44 9.66 0.0017

29027 CALLAWAY 6.86 1.24 9.77 13.55 5.62 11.96   

29037 CASS 6.23 0.46 3.00 4.79 3.73 2.85   
144 

StateFIPs County PM10‐PRI

PM2.5‐

PRI SO2 NOX VOC CO Lead

29043 CHRISTIAN 2.39 0.04 1.01 6.60 7.62 29.43   

29047 CLAY 19.57 0.59 1.05 8.33 9.31 30.64   

29051 COLE 1.55 0.08 4.93 4.01 5.69 8.56   

29055 CRAWFORD 10.76    1.70 7.79 4.25 7.64 0.0001

29071 FRANKLIN 4.17 0.20 7.24 5.58 2.32 9.86 0.0003

29077 GREENE 9.96 0.68 0.43 13.62 8.47 32.73 0.0001

29079 GRUNDY 2.27 0.17 0.11 0.58 0.26 0.29   

29083 HENRY 5.03    2.44 0.95 0.61 0.79   

29091 HOWELL 6.66 0.00 3.66 3.49 2.39 0.56   

29095 JACKSON 30.71 1.14 8.27 26.59 27.86 83.08   

29097 JASPER 24.42 0.95 0.69 11.45 7.47 21.02   

29099 JEFFERSON 19.76 0.00 10.83 2.15 0.53 4.64   

29101 JOHNSON 0.97    12.59 2.63 1.02 4.10   

29105 LACLEDE 3.26 0.13 0.57 2.43 1.32 5.12 0.0009

29113 LINCOLN 3.76    7.86 10.13 6.88 11.72 0.0001

29119 MCDONALD 0.91    2.42 1.96 1.07 4.13 0.0007

29139 MONTGOMERY 2.96    0.03 0.24 0.15 0.15   

29143 NEW MADRID 0.79    0.05 0.49 0.15 7.03   

29151 OSAGE 1.33    3.14 0.96 0.43 1.67   

29157 PERRY 4.29 0.01 1.12 1.28 0.67 0.55   

29159 PETTIS 8.27 0.62 5.36 6.10 1.16 18.25   

29161 PHELPS 6.03 0.72 0.51 1.75 2.03 15.80   

29165 PLATTE 5.99    0.97 7.63 8.55 28.16   

29169 PULASKI 12.05 0.43 0.67 4.16 5.43 17.66 0.0003

29173 RALLS 8.73    3.88 10.05 1.50 2.28   

29175 RANDOLPH 2.27    0.82 2.33 1.26 4.86   

29183 ST. CHARLES 15.35    0.52 2.22 0.72 5.59   

29187 ST. FRANCOIS 9.88 0.28 3.61 5.45 1.57 19.55 0.0003

29189 ST. LOUIS CO. 8.07    25.33 19.21 8.75 54.26   

29195 SALINE 0.60 0.14 0.11 5.16 2.81 10.87   

29207 STODDARD 2.49 0.42 5.37 6.25 2.55 18.57   

29213 TANEY 1.58    4.19 1.44 0.42 0.71   

Total 266.30 11.68 139.21 214.06 141.63 498.97 0.0045

e. QA/QC 

Quality assurance and quality checks were performed on the 2011 Emission Inventory Questionnaires as they were 

submitted. Any suspected faulty data was critically inspected by inventory staff and corrected as needed with the 

cooperation of the facilities. Other quality checks of the inventories were done on the data by staff throughout the 

year and for previous reporting years. 
145 

   
146 

8.17 Gas Stations:  Stage II

EPA created the national estimate for this category.  As of February 28, 2014, there is no documentation provided

by EPA for the development of this inventory.  The county‐total emission values were reviewed by Missouri and

accepted.  

   

   
147 

8.18 Gasoline Distribution:  Stage I

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  The documentation

below was developed by EPA.

a. Source Category Description

Stage I gasoline distribution includes the following gasoline emission points:  1) bulk terminals; 2) pipeline facilities;

3) bulk plants; 4) tank trucks; and 5) service stations.  Emissions from Stage I gasoline distribution occur as gasoline

vapors are released into the atmosphere.  These Stage I processes are subject to EPA’s maximum available control

technology (MACT) standards for gasoline distribution.1

  

Emissions from gasoline distribution at bulk terminals and bulk plants take place when gasoline is loaded into a

storage tank or tank truck, from working losses (for fixed roof tanks), and from working losses and roof seals (for

floating roof tanks).  Working losses consist of both breathing and emptying losses.  Breathing losses are the

expulsion of vapor from a tank vapor space that has expanded or contracted because of daily changes in

temperature and barometric pressure; these emissions occur in the absence of any liquid level change in the tank.  

Emptying losses occur when the air that is drawn into the tank during liquid removal saturates with hydrocarbon

vapor and expands, thus exceeding the fixed capacity of the vapor space and overflowing through the pressure

vacuum valve.2

Emissions from tank trucks in transit occur when gasoline vapor evaporates from (1) loaded tank trucks during

transportation of gasoline from bulk terminals/plants to service stations, and (2) empty tank trucks returning from

service stations to bulk terminals/plants.3 Pipeline emissions result from the valves and pumps found at pipeline

pumping stations and from the valves, pumps, and storage tanks at pipeline breakout stations.  Stage I gasoline

distribution emissions also occur when gasoline vapors are displaced from storage tanks during unloading of

gasoline from tank trucks at service stations (Gasoline Service Station Unloading) and from gasoline vapors

evaporating from service station storage tanks and from the lines going to the pumps (Underground Storage Tank

Breathing and Emptying).

The following SCCs are included in Stage I Gasoline Distribution:

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4
148 

2501050120 Storage and Transport Petroleum and

Petroleum Product

Storage

Bulk Terminals:

All Evaporative

Losses

Gasoline

2501055120 Storage and Transport Petroleum and

Petroleum Product

Storage

Bulk Plants: All

Evaporative

Losses

Gasoline

2501060051 Storage and Transport Petroleum and

Petroleum Product

Storage

Gasoline Service

Stations

Stage 1: Submerged

Filling

2501060052 Storage and Transport Petroleum and

Petroleum Product

Storage

Gasoline Service

Stations

Stage 1: Splash Filling

2501060053 Storage and Transport Petroleum and

Petroleum Product

Storage

Gasoline Service

Stations

Stage 1: Balanced

Submerged Filling

2501060201 Storage and Transport Petroleum and

Petroleum Product

Storage

Gasoline Service

Stations

Underground Tank:

Breathing and

Emptying

2505030120 Storage and Transport Petroleum and

Petroleum Product

Transport

Truck Gasoline

2505040120 Storage and Transport Petroleum and

Petroleum Product

Transport

Pipeline Gasoline

b. Bulk Terminals and Pipelines

There are no generally accepted activity‐based VOC emission factors for the pipelines and bulk terminals sectors

because they are generally treated as point sources whose emissions are estimated using site‐specific information.  

For example, emission estimates for bulk terminal storage tanks are typically derived from tank specific

parameters that are input into the TANKS program.4 Therefore, for bulk terminals and pipelines, EPA estimated

2008 national VOC emissions by multiplying 1998 national estimates developed in support of the Gasoline

Distribution MACT standard5 by the 2008 to 1998 ratio of the national volume of wholesale gasoline supplied  (For

2011, EPA used 2008 emission estimates due to resource constraints).  The gasoline supply information was

obtained from Table 2 in Volume I of Petroleum Supply Annual 2008.6
149 

Estimation of National 2008 VOC Emissions for Pipelines and Bulk Terminals

Category

1998 Post‐MACT

Control

Emissions (Mg)

Mg to Ton

Conversion

Factor

1998

Emissions

(tons)

Ratio of 2008 to 1998 Gasoline

Supplied

2008 Emissions

(tons)

Pipelines 79,830 1.1023 87,997 (8,989 thousand barrels per day

/

8,253 thousand barrels per day)

= 1.089

95,844

Bulk Terminals 137,555 1.1023 151,627 165,149

To estimate HAP emissions, EPA applied national average speciation profiles to the VOC emission estimates.7

  The

table below presents these speciation profiles and the national bulk terminal and pipeline HAP emission estimates

(note that unless otherwise noted, all emission values reported in this section exclude estimates for Puerto Rico

and the U.S. Virgin Islands). EPA used total VOC emission estimates, so emissions represent total emissions. Where

necessary, States should perform point source subtractions to obtain nonpoint emissions. The following describes

how total national VOC estimates were allocated to counties.

HAP Speciation Profiles and 2008 Bulk Terminal and Pipeline Emissions

HAP Pollutant

Code

Percentage of

VOC Emissions Reference

2008 National Emissions (tons)

Bulk Terminals Pipelines

Benzene 71432 0.27 7 4.46E+02 2.59E+02

2,2,4‐Trimethylpentane 540841 0.75 7 1.24E+03 7.19E+02

Cumene 98828 0.012 7 1.98E+01 1.15E+01

Ethyl Benzene 100414 0.053 7 8.75E+01 5.08E+01

n‐Hexane 110543 1.8 7 2.97E+03 1.73E+03

Naphthalene 91203 0.00027 7 4.46E‐01 2.59E‐01

Toluene 108883 1.4 7 2.31E+03 1.34E+03

Xylenes 1330207 0.56 7 9.25E+02 5.37E+02

For both categories, EPA allocated national VOC and HAP emissions for these categories in a two‐step manner.  

First, EPA allocated emissions based on 2008 gasoline supply data reported by the U.S. Department of Energy

(DOE).  Next, EPA allocated emissions based on employment data reported in the 2007 County Business Patterns.8

For pipelines, EPA allocated emissions to Petroleum Administration for Defense (PAD) Districts based on the total

amount of finished motor gasoline moved by pipeline in each PAD in year 2008.  There are five PAD Districts across

the United States:   PAD District 1 comprises seventeen states plus the District of Columbia along the Atlantic Coast;

PAD District 2 comprises fifteen states in the Midwest; PAD District 3 comprises six states in South Central U.S.;

PAD District 4 comprises five states in the Rocky Mountains; and PAD District 5 comprises seven states along the

West Coast. These data, which are displayed in the table below, are reported in Table 35 of Volume 1 of Petroleum
150 

Supply Annual 2008.9  Next, EPA allocated pipeline emissions in each PAD District to counties based on County

Business Patterns employment data.  Because employment data for NAICS code 48691 (Pipeline Transportation of

Refined Petroleum Products) are often withheld due to confidentiality reasons, EPA used the number of

employees in NAICS code 42471 (Petroleum Bulk Stations and Terminals) for this allocation.  To better account for

the location of refined petroleum pipelines, however, EPA did not allocate any activity to States which had

employees in this NAICS code, but did not have employees in NAICS code 48691 (i.e., District of Columbia, Idaho,

Maine, New Hampshire, Vermont, and West Virginia).

Movement of Finished Motor Gasoline by Pipeline Between PAD Districts, 2008

From I From II From III From IV From V

To I n/a 393 333,462 0 0

To II 70,895 n/a 99,167 7,442 0

To III 0 9,193 n/a 0 0

To IV 0 8,680 5,778 n/a 0

To V 0 0 25,453 9,287 n/a

For bulk terminals, EPA first allocated national emissions to States based on the 2008 refinery, bulk terminal, and

natural gas plant stocks of motor gasoline reported for each State in Table 33 of Volume 1 of DOE’s Petroleum

Supply Annual 2008 (see table below).9  Next, EPA allocated emissions in each State to counties based on the

number of NAICS code 42471 (Petroleum Bulk Stations and Terminals) employees reported in the 2007 County

Business Patterns.8

   

Refinery, Bulk Terminal, and Natural Gas Plant Stocks of Motor Gasoline, 2008

State

Motor Gasoline

(Thousand Barrels) State

Motor Gasoline

(Thousand Barrels)

Alabama 1,090 Montana 872

Alaska 616 Nebraska 658

Arizona 470 Nevada 102

Arkansas 819 New Hampshire 0

California 460 New Jersey 2,956

Colorado 748 New Mexico 350

Connecticut 0 New York 1,469

Delaware 105 North Carolina 1,724

District of Columbia 0 North Dakota 291

Florida 1,877 Ohio 2,724

Georgia 1,724 Oklahoma 1,245

Hawaii 12 Oregon 525

Idaho 181 Pennsylvania 3,595

Illinois 1,940 Rhode Island 0

Indiana 2,464 South Carolina 720

Iowa 1,090 South Dakota 283
151 

State

Motor Gasoline

(Thousand Barrels) State

Motor Gasoline

(Thousand Barrels)

Kansas 2,347 Tennessee 923

Kentucky 1,045 Texas 9,530

Louisiana 5,209 Utah 793

Maine 374 Vermont 31

Maryland 31 Virginia 1,285

Massachusetts 0 Washington 1,902

Michigan 1,772 West Virginia 183

Minnesota 1,305 Wisconsin 704

Mississippi 1,580 Wyoming 910

Missouri 491

It is important to reiterate that the above discussion addresses the calculation of total VOC emissions. The 2008

point source NEI reports VOC emissions related to bulk terminal and pipeline processes. To obtain nonpoint

emissions, States should subtract the 2008 point source VOC emission estimates from the total VOC emission

estimates reported here. The relevant point source SCCs are listed in the two tables below.

Pipeline Point Source SCCs

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

40600501 Petroleum and

Solvent Evaporation

Transportation and

Marketing of

Petroleum Products

Pipeline Petroleum

Transport ‐ General ‐ 

All Products

Pipeline Leaks

40600502 Petroleum and

Solvent Evaporation

Transportation and

Marketing of

Petroleum Products

Pipeline Petroleum

Transport ‐ General ‐ 

All Products

Pipeline Venting

40600503 Petroleum and

Solvent Evaporation

Transportation and

Marketing of

Petroleum Products

Pipeline Petroleum

Transport ‐ General ‐ 

All Products

Pump Station

40600504 Petroleum and

Solvent Evaporation

Transportation and

Marketing of

Petroleum Products

Pipeline Petroleum

Transport ‐ General ‐ 

All Products

Pump Station Leaks

Bulk Terminal Point Source SCCs

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

40400101 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 13:

Breathing Loss

(67000 Bbl Capacity)

‐ Fixed Roof Tank

40400102 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 10:

Breathing Loss

(67000 Bbl Capacity)

‐ Fixed Roof Tank

40400103 Petroleum and Petroleum Liquids Bulk Terminals Gasoline RVP 7:
152 

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

Solvent Evaporation Storage (non‐

Refinery)

Breathing Loss

(67000 Bbl.

Capacity) ‐ Fixed

Roof Tank

40400104 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 13:

Breathing Loss

(250000 Bbl

Capacity)‐Fixed Roof

Tank

40400105 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 10:

Breathing Loss

(250000 Bbl

Capacity)‐Fixed Roof

Tank

40400106 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 7:

Breathing Loss

(250000 Bbl

Capacity) ‐ Fixed

Roof Tank

40400107 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 13:

Working Loss (Diam.

Independent) ‐ Fixed

Roof Tank

40400108 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 10:

Working Loss

(Diameter

Independent) ‐ Fixed

Roof Tank

40400109 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 7:

Working Loss

(Diameter

Independent) ‐ Fixed

Roof Tank

40400110 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 13:

Standing Loss

(67000 Bbl

Capacity)‐Floating

Roof Tank

40400111 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 10:

Standing Loss

(67000 Bbl

Capacity)‐Floating

Roof Tank

40400112 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 7:

Standing Loss

(67000 Bbl

Capacity)‐ Floating

Roof Tank

40400113 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Bulk Terminals Gasoline RVP 13:

Standing Loss
153 

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

Refinery) (250000 Bbl Cap.) ‐

Floating Roof Tank

40400114 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 10:

Standing Loss

(250000 Bbl Cap.) ‐ 

Floating Roof Tank

40400115 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 7:

Standing Loss

(250000 Bbl Cap.) ‐ 

Floating Roof Tank

40400116 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP

13/10/7:

Withdrawal Loss

(67000 Bbl Cap.) ‐ 

Float Rf Tnk

40400117 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP

13/10/7:

Withdrawal Loss

(250000 Bbl Cap.) ‐ 

Float Rf Tnk

40400118 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 13:

Filling Loss (10500

Bbl Cap.) ‐ Variable

Vapor Space

40400119 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 10:

Filling Loss (10500

Bbl Cap.) ‐ Variable

Vapor Space

40400120 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 7:

Filling Loss (10500

Bbl Cap.) ‐ Variable

Vapor Space

40400131 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 13:

Standing Loss ‐ Ext.

Floating Roof w/

Primary Seal

40400132 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 10:

Standing Loss ‐ Ext.

Floating Roof w/

Primary Seal

40400133 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 7:

Standing Loss ‐ 

External Floating

Roof w/ Primary

Seal

40400141 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 13:

Standing Loss ‐ Ext.

Floating Roof w/

Secondary Seal

40400142 Petroleum and Petroleum Liquids Bulk Terminals Gasoline RVP 10:
154 

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

Solvent Evaporation Storage (non‐

Refinery)

Standing Loss ‐ Ext.

Floating Roof w/

Secondary Seal

40400143 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 7:

Standing Loss ‐ Ext.

Floating Roof w/

Secondary Seal

40400148 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP

13/10/7:

Withdrawal Loss ‐ 

Ext. Float Roof

(Pri/Sec Seal)

40400150 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Miscellaneous

Losses/Leaks:

Loading Racks

40400151 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Valves, Flanges, and

Pumps

40400152 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Vapor Collection

Losses

40400153 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Vapor Control Unit

Losses

40400161 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 13:

Standing Loss ‐ Int.

Floating Roof w/

Primary Seal

40400162 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 10:

Standing Loss ‐ Int.

Floating Roof w/

Primary Seal

40400163 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 7:

Standing Loss ‐ 

Internal Floating

Roof w/ Primary

Seal

40400171 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 13:

Standing Loss ‐ Int.

Floating Roof w/

Secondary Seal

40400172 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 10:

Standing Loss ‐ Int.

Floating Roof w/

Secondary Seal

40400173 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP 7:

Standing Loss ‐ Int.

Floating Roof w/

Secondary Seal
155 

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

40400178 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Gasoline RVP

13/10/7:

Withdrawal Loss ‐ 

Int. Float Roof

(Pri/Sec Seal)

c. Bulk Plants

EPA calculated VOC emissions from bulk plants by developing an average emission factor from the bulk plant

motor gasoline VOC emissions and throughput data developed in support of the Gasoline Distribution MACT

standards.2,5  To estimate 2008 national VOC emissions, the VOC emission factor (8.62 pounds of VOC per 1,000

gallons) was applied to the estimated national volume of gasoline passing through bulk plants in 2008.  The volume

of bulk plant gasoline throughput was assumed to be 9 percent of total gasoline consumption.10 Total gasoline

consumption for 2008 was assumed to be the same as the volume of finished motor gasoline supplied as reported

on the U.S. Energy Information Administration’s Petroleum Navigator website.11 The resulting national VOC

emission estimate was then allocated to counties based on employment data for NAICS code 42471 (Petroleum

Bulk Stations and Terminals).  To estimate benzene emissions from bulk plants, EPA multiplied VOC emission

estimates by county‐level speciation profiles calculated from the annual onroad refueling (Stage 2) emissions from

the 2008 NEI NMIM results.12 All other HAPs were estimated by multiplying VOC emissions by the national average

speciation profiles displayed in the table below.

Bulk Plant HAP Speciation Profiles and Total Emission Estimates

Pollutant Pollutant Code Emission Factor Reference

National Emissions

(tpy)

VOC VOC 8.62 lb./1,000 gallons 2 and 5 5.35E+04

2,2,4‐Trimethylpentane 540841 0.75% of VOC 7 4.01E+02

Cumene 98828 0.012% of VOC 7 6.41E+00

Ethyl Benzene 100414 0.053% of VOC 7 2.83E+01

n‐Hexane 110543 1.8% of VOC 7 9.62E+02

Naphthalene 91203 0.00027% of VOC 7 1.44E‐01

Toluene 108883 1.4% of VOC 7 7.48E+02

Xylenes 1330207 0.56% of VOC 7 2.99E+02

Benzene 71432 county‐specific % of VOC 12 3.94E+02
156 

It is important to reiterate that the above discussion addresses the calculation of total VOC emissions. The 2008

point source NEI reports VOC emissions related to bulk plants. To obtain nonpoint emissions, States should

subtract the 2008 point source VOC emission estimates from the total VOC emission estimates reported here. The

relevant point source SCCs are listed in the table below.

Bulk Plant Point Source SCCs

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

40400201 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 13:

Breathing Loss

(67000 Bbl Capacity)

‐ Fixed Roof Tank

40400202 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 10:

Breathing Loss

(67000 Bbl Capacity)

‐ Fixed Roof Tank

40400203 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 7:

Breathing Loss

(67000 Bbl.

Capacity) ‐ Fixed

Roof Tank

40400204 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 13:

Working Loss (67000

Bbl. Capacity) ‐ Fixed

Roof Tank

40400205 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 10:

Working Loss (67000

Bbl. Capacity) ‐ Fixed

Roof Tank

40400206 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 7:

Working Loss (67000

Bbl. Capacity) ‐ Fixed

Roof Tank

40400207 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 13:

Standing Loss

(67000 Bbl Cap.) ‐ 

Floating Roof Tank

40400208 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 10:

Standing Loss

(67000 Bbl Cap.) ‐ 

Floating Roof Tank

40400209 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 7:

Standing Loss

(67000 Bbl Cap.) ‐ 

Floating Roof Tank

40400210 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP

13/10/7:

Withdrawal Loss

(67000 Bbl Cap.) ‐ 

Float Rf Tnk
157 

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

40400211 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 13:

Filling Loss (10500

Bbl Cap.) ‐ Variable

Vapor Space

40400212 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 10:

Filling Loss (10500

Bbl Cap.) ‐ Variable

Vapor Space

40400213 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 7:

Filling Loss (10500

Bbl Cap.) ‐ Variable

Vapor Space

40400231 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 13:

Standing Loss ‐ Ext.

Floating Roof w/

Primary Seal

40400232 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 10:

Standing Loss ‐ Ext.

Floating Roof w/

Primary Seal

40400233 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 7:

Standing Loss ‐ 

External Floating

Roof w/ Primary

Seal

40400241 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 13:

Standing Loss ‐ Ext.

Floating Roof w/

Secondary Seal

40400242 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 10:

Standing Loss ‐ Ext.

Floating Roof w/

Secondary Seal

40400243 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 7:

Standing Loss ‐ Ext.

Floating Roof w/

Secondary Seal

40400248 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP

10/13/7:

Withdrawal Loss ‐ 

Ext. Float Roof

(Pri/Sec Seal)

40400250 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Loading Racks

40400251 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Valves, Flanges, and

Pumps
158 

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

40400252 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Miscellaneous

Losses/Leaks: Vapor

Collection Losses

40400253 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Miscellaneous

Losses/Leaks: Vapor

Control Unit Losses

40400261 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 13:

Standing Loss ‐ Int.

Floating Roof w/

Primary Seal

40400262 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 10:

Standing Loss ‐ Int.

Floating Roof w/

Primary Seal

40400263 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 7:

Standing Loss ‐ 

Internal Floating

Roof w/ Primary

Seal

40400271 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 13:

Standing Loss ‐ Int.

Floating Roof w/

Secondary Seal

40400272 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 10:

Standing Loss ‐ Int.

Floating Roof w/

Secondary Seal

40400273 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP 7:

Standing Loss ‐ Int.

Floating Roof w/

Secondary Seal

40400278 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Gasoline RVP

10/13/7:

Withdrawal Loss ‐ 

Int. Float Roof

(Pri/Sec Seal)

40400401 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Petroleum Products

‐ Underground

Tanks

Gasoline RVP 13:

Breathing Loss

40400402 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Petroleum Products

‐ Underground

Tanks

Gasoline RVP 13:

Working Loss

40400403 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Petroleum Products

‐ Underground

Tanks

Gasoline RVP 10:

Breathing Loss

40400404 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Petroleum Products

‐ Underground

Tanks

Gasoline RVP 10:

Working Loss
159 

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

40400405 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Petroleum Products

‐ Underground

Tanks

Gasoline RVP 7:

Breathing Loss

40400406 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Petroleum Products

‐ Underground

Tanks

Gasoline RVP 7:

Working Loss

40600101 Petroleum and

Solvent Evaporation

Transportation and

Marketing of

Petroleum Products

Tank Cars and

Trucks

Gasoline: Splash

Loading **

40600126 Petroleum and

Solvent Evaporation

Transportation and

Marketing of

Petroleum Products

Tank Cars and

Trucks

Gasoline:

Submerged Loading

**

40600131 Petroleum and

Solvent Evaporation

Transportation and

Marketing of

Petroleum Products

Tank Cars and

Trucks

Gasoline:

Submerged Loading

(Normal Service)

40600136 Petroleum and

Solvent Evaporation

Transportation and

Marketing of

Petroleum Products

Tank Cars and

Trucks

Gasoline: Splash

Loading (Normal

Service)

40600141 Petroleum and

Solvent Evaporation

Transportation and

Marketing of

Petroleum Products

Tank Cars and

Trucks

Gasoline:

Submerged Loading

(Balanced Service)

40600144 Petroleum and

Solvent Evaporation

Transportation and

Marketing of

Petroleum Products

Tank Cars and

Trucks

Gasoline: Splash

Loading (Balanced

Service)

40600147 Petroleum and

Solvent Evaporation

Transportation and

Marketing of

Petroleum Products

Tank Cars and

Trucks

Gasoline:

Submerged Loading

(Clean Tanks)

d. Tank Trucks in Transit

The EPA calculated VOC emissions from Tank Trucks in Transit by multiplying county‐level tank truck gasoline

throughput by a 0.06 lb of VOC per 1,000 gallon emission factor.  As noted in the table below, this emission factor

is the sum of the individual emission factors reported in the Gasoline Distribution EIIP guidance document for

gasoline‐filled trucks (traveling to service station/bulk plant for delivery) and vapor‐filled trucks (traveling to bulk

terminal/plant for reloading).3 County‐level gasoline consumption was estimated by summing county‐level onroad

and nonroad estimates. County‐level onroad consumption was estimated by subtracting the NMIM‐derived

national nonroad consumption from the EIA’s estimate of finished motor gasoline supplied and then allocating to

counties using NMIM‐derived onroad county‐level CO2 emissions.11,13 County‐level nonroad consumption was

estimated by allocating NMIM‐derived state/SCC‐level nonroad gasoline consumption to the county‐level based on

nonroad county/SCC‐level CO2 emissions.13 Gasoline throughput for tank trucks was computed by multiplying the

county‐level gasoline consumption estimates by a factor of 1.09 to account for gasoline that is transported more

than once in a given area (i.e., transported from bulk terminal to bulk plant and then from bulk plant to service

station).10  Benzene emission estimates were calculated by multiplying county‐level NMIM speciation profiles by

the VOC emission estimates.12  Emissions for the remaining HAPs were calculated by multiplying VOC emissions by

the national speciation profiles presented in the second table below.   
160 

Tank Trucks in Transit VOC Emission Factors

VOC Emission Factor

Vapor‐Filled Trucks 0.055 lb/1,000 gallons

Gasoline Filled Trucks 0.005 lb/1,000 gallons

Total 0.06 lb/1,000 gallons

Tank Trucks in Transit HAP Speciation Profiles and Total Emission Estimates

Pollutant Pollutant

Code

Emission Factor Reference National Emissions

(tpy)

VOC VOC 0.06 lb./1,000 gallons 3

4.51E+03

2,2,4‐Trimethylpentane 540841 0.75% of VOC 7

3.38E+01

Cumene 98828 0.012% of VOC 7

5.41E‐01

Ethyl Benzene 100414 0.053% of VOC 7

2.39E+00

n‐Hexane 110543 1.8% of VOC 7

8.11E+01

Naphthalene 91203 0.00027% of VOC 7

1.22E‐02

Toluene 108883 1.4% of VOC 7

6.31E+01

Xylenes 1330207 0.56% of VOC 7

2.52E+01

Benzene 71432 county‐specific % of VOC 12

3.13E+01

It is important to reiterate that the above discussion addresses the calculation of total VOC emissions. The 2008

point source NEI reports VOC emissions related to tank trucks in transit. To obtain nonpoint emissions, States

should subtract the 2008 point source VOC emission estimates from the total VOC emission estimates reported

here. The relevant point source SCCs are listed in the table below.
161 

Tank Trucks in Transit Point Source SCCs

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

40400154 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Terminals Tank Truck Vapor

Leaks

40400254 Petroleum and

Solvent Evaporation

Petroleum Liquids

Storage (non‐

Refinery)

Bulk Plants Tank Truck Vapor

Losses

40600162 Petroleum and

Solvent Evaporation

Transportation and

Marketing of

Petroleum Products

Tank Cars and

Trucks

Gasoline: Loaded

with Fuel (Transit

Losses)

40600163 Petroleum and

Solvent Evaporation

Transportation and

Marketing of

Petroleum Products

Tank Cars and

Trucks

Gasoline: Return

with Vapor (Transit

Losses)

e. Underground Storage Tank (UST) Breathing and Emptying

The EPA calculated VOC emissions from UST breathing and emptying by multiplying county‐level total gasoline

consumption, calculated as described above in the Tank Trucks in Transit section, by the 1 lb/1,000 gallons

emission factor recommended by the Gasoline Distribution EIIP guidance document.3

  With the exception of

benzene, HAP emissions were estimated by multiplying VOC emissions by the national HAP speciation profiles

listed in the table below.  To estimate benzene emissions, EPA multiplied VOC emissions by county‐level speciation

profiles from NMIM.12   

Underground Storage Tank (UST) Breathing and Emptying Emissions

Pollutant

Pollutant

Code

Emission Factor Reference

National Emissions

(tpy)

VOC VOC 1 lb./1,000 gallons 3 6.89E+04

2,2,4‐Trimethylpentane 540841 0.75% of VOC 7 5.17E+02

Cumene 98828 0.012% of VOC 7 8.27E+00

Ethyl Benzene 100414 0.053% of VOC 7 3.65E+01

n‐Hexane 110543 1.8% of VOC 7 1.24E+03

Naphthalene 91203 0.00027% of VOC 7 1.86E‐01

Toluene 108883 1.4% of VOC 7 9.65E+02

Xylenes 1330207 0.56% of VOC 7 3.86E+02

Benzene 71432 county‐specific % of VOC 12 4.78E+02
162 

It is important to reiterate that the above discussion addresses the calculation of total VOC emissions. The 2008

point source NEI reports VOC emissions related to UST breathing and emptying. To obtain nonpoint emissions,

States should subtract the 2008 point source VOC emission estimates from the total VOC emission estimates

reported here. The relevant point source SCCs are listed in the table below.

UST Breathing and Emptying Point Source SCCs

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

40600307 Petroleum and

Solvent Evaporation

Transportation and

Marketing of

Petroleum Products

Gasoline Retail

Operations ‐ Stage I

Underground Tank

Breathing and

Emptying

40600707 Petroleum and

Solvent Evaporation

Transportation and

Marketing of

Petroleum Products

Consumer

(Corporate) Fleet

Refueling ‐ Stage I

Underground Tank

Breathing and

Emptying

f. Gasoline Service Station Unloading

The EPA estimated uncontrolled VOC emissions from unloading of gasoline into service station tanks from county‐

level total gasoline consumption estimates, calculated as described above in the Tank Trucks in Transit section, and

the following AP‐42 equation:

L = (12.46 x S x P x M)/T        

where:

L = uncontrolled loading loss of liquid loaded (in lb/1,000 gallons)

S = saturation factor;

P = true vapor pressure of liquid loaded (pounds per square inch absolute);

M = molecular weight of vapors (lbs per lb/mole); and

T = temperature of liquid loaded (Rankine).14

This equation requires geographic‐specific information.  This information includes the saturation factor, which

differs by method of loading (e.g., submerged filling), Reid vapor pressure (RVP), temperature, and true vapor

pressure of gasoline.
163 

Gasoline RVP values were obtained from the NMIM 2008 database. Because NMIM is a county‐level database that

reports RVP values by month, EPA developed county‐level monthly gasoline consumption estimates by multiplying

annual county gasoline consumption by monthly allocation factors.  State‐level monthly allocation factors were

developed from monthly gasoline sales data reported in the Federal Highway Administration's Highway Statistics

2008.15  Geographic‐specific information on the temperature of gasoline and the method of loading were obtained

from a Stage I and II gasoline emission inventory study prepared for the EIIP.16  

The true vapor pressure of gasoline was estimated for each county/month using the following equation:

  

where:

P    = Stock true vapor pressure, in pounds per square inch absolute.

T    = Stock temperature, in degrees Fahrenheit.

RVP = Reid vapor pressure, in pounds per square inch.

S    = Slope of the ASTM distillation curve at 10 percent evaporated, in degrees Fahrenheit per percent

(assumed that S = 3.0 for gasoline per Figure 7.1‐14a of AP‐42).17

This equation was used to calculate monthly county‐level true vapor pressure estimates.  In cases where more

than one filling method was assumed to apply in a county (e.g., due to vapor balancing requirement applying to a

portion of a county’s total gasoline throughput due to a throughput exemption), EPA developed two sets of

calculations for each month, one for each filling method.

The EIIP study regional stock temperature information was used to estimate the temperature of gasoline in each

county in each month (see table below).16





























 



 





  



 



  



 













 



 



 





   



 



 



 





 



15 .64

459 .6

8,742 2.013 log ( ) 459 .6

2,416

459 .6

1,042 log ( ) 1.854

459 .6

413 .0 0.7553

exp

10

0.5

10

0.5

T

RVP

T

S

T

S RVP

T

P
164 

Temperature Data Used in Estimating True Vapor Pressure (oF)

Region Jan Feb Mar Apr May June July Aug Sep Oct Nov Dec

1 (Northeast) 46 44 44 48 57 64 70 73 70 64 60 51

2 (Southeast) 66 67 69 74 78 81 80 81 80 77 69 60

3 (Southwest) 60 61 62 66 73 78 81 84 82 78 71 62

4 (Midwest) 33 35 40 47 55 62 71 73 68 65 64 63

5 (West) 50 52 62 66 73 76 80 83 86 84 73 60

6 (Northwest) 49 50 50 52 57 62 67 72 68 60 49 42

Region 1: Alaska, Connecticut, Delaware, DC, Illinois, Indiana, Kentucky, Maine, Maryland, Massachusetts,

Michigan, New Hampshire, New Jersey, New York, Ohio, Pennsylvania, Rhode Island, Vermont, Virginia,

West Virginia, Wisconsin

Region 2: Alabama, Arkansas, Florida, Georgia, Hawaii, Louisiana, Mississippi, N. Carolina, S. Carolina, Tennessee

Region 3: Arizona, New Mexico, Oklahoma, Texas

Region 4: Colorado, Iowa, Kansas, Minnesota, Missouri, Montana, Nebraska, N. Dakota, S. Dakota, Wyoming

Region 5: California, Nevada, Utah

Region 6: Idaho, Oregon, Washington

The EPA incorporated the effect of Stage I Gasoline Service Station vapor balancing controls based on the

county‐level control efficiency values (either 90 or 95 percent) that were compiled for the EIIP study.16 The table

below presents the HAP speciation profiles and total VOC and HAP emission estimates calculated using these

procedures.
165 

Emissions are reported by SCC based on the filling methods used in each county as determined from the EIIP study:

SCC 2501060051 (Submerged Filling); SCC 2501060052 (Splash Filling); and SCC 2501060053 (Balanced Submerged

Filling).

Stage I Service Station Unloading HAP Speciation Profiles and Total Emission Estimates

Pollutant Pollutant

Code

Emission Factor Reference National Emissions

(tpy)

VOC VOC Equation 1 14

3.82E+05

2,2,4‐Trimethylpentane 540841 0.75% of VOC 7

2.86E+03

Cumene 98828 0.012% of VOC 7

4.58E+01

Ethyl Benzene 100414 0.053% of VOC 7

2.02E+02

n‐Hexane 110543 1.8% of VOC 7

6.87E+03

Naphthalene 91203 0.00027% of VOC 7

1.03E+00

Toluene 108883 1.4% of VOC 7

5.35E+03

Xylenes 1330207 0.56% of VOC 7

2.14E+03

Benzene 71432 county‐specific % of VOC 12

2.97E+03

It is important to reiterate that the above discussion addresses the calculation of total VOC emissions. The 2008

point source NEI reports VOC emissions related to service station unloading. To obtain nonpoint emissions, States

should subtract the 2008 point source VOC emission estimates from the total VOC emission estimates reported

here. The relevant point source SCCs are listed in the three tables below below.

Service Station Unloading: Submerged Fill Point Source SCCs

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

40600302 Petroleum and

Solvent Evaporation

Transportation and

Marketing of

Petroleum Products

Gasoline Retail

Operations ‐ Stage I

Submerged Filling

w/o Controls

40600702 Petroleum and

Solvent Evaporation

Transportation and

Marketing of

Petroleum Products

Consumer

(Corporate) Fleet

Refueling ‐ Stage I

Submerged Filling

w/o Controls
166 

Service Station Unloading: Splash Fill Point Source SCCs

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

40600301 Petroleum and

Solvent Evaporation

Transportation and

Marketing of

Petroleum Products

Gasoline Retail

Operations ‐ Stage I

Splash Filling

40600701 Petroleum and

Solvent Evaporation

Transportation and

Marketing of

Petroleum Products

Consumer

(Corporate) Fleet

Refueling ‐ Stage I

Splash Filling

Service Station Unloading: Balanced Submerged Fill Point Source SCCs

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

40600305 Petroleum and

Solvent Evaporation

Transportation and

Marketing of

Petroleum Products

Gasoline Retail

Operations ‐ Stage I

Unloading **

40600306 Petroleum and

Solvent Evaporation

Transportation and

Marketing of

Petroleum Products

Gasoline Retail

Operations ‐ Stage I

Balanced

Submerged Filling

40600706 Petroleum and

Solvent Evaporation

Transportation and

Marketing of

Petroleum Products

Consumer

(Corporate) Fleet

Refueling ‐ Stage I

Balanced

Submerged Filling

Unloading emissions might also be reported in the point source inventory under SCC 40600399 (Gasoline Retail

Operations – Stage I, Not Classified).

g. Example Emission Calculations

Bulk Terminals

2008 national benzene emissions = VOC emissions x HAP speciation factor

       1.65E+05 tons x 0.0027

4.46E+02 tons

Pipelines
167 

2008 national cumene emissions = VOC emissions x HAP speciation factor

9.58E+04 tons x 0.00012

1.15E+01 tons

Bulk Plants

2008 national VOC emissions

= national gasoline consumption x proportion passing through bulk plants x VOC emission factor

= 137,801,370 thousand gallons x 0.09 x 8.62 lbs. VOC/thousand gallons

= 1.07E+08 lbs. / 2000 lbs.

= 5.35E+04 tons

Tank Trucks in Transit

2008 Alamance County, North Carolina VOC emissions

= total county gasoline consumption x (1+proportion of gasoline transported twice) x VOC emission factor

= 61,446 thousand gallons x (1+0.09) x 0.06 lbs. VOC/thousand gallons

= 4.02E+03 lbs. / 2000 lbs.

= 2.01E+00 tons

UST Breathing and Emptying

2008 Alamance County, North Carolina VOC emissions

= total county gasoline consumption x VOC emission factor

= 61,466 thousand gallons x 1 lb. VOC/thousand gallons

= 6.15E+04 lbs. / 2000 lbs.

= 30.73E+00 tons
168 

Stage I Gasoline Service Station Unloading ‐ uncontrolled VOC emissions in July for balanced submerged fill

unloading in Alamance County, NC

= annual county consumption x proportion of annual gasoline sold in July x VOC emission factor

= 61,466 thousand gallons x 0.1087 x VOC emission factor

= 6,681 thousand gallons x ((12.46 x saturation factor x true vapor pressure x vapor molecular weight) /

temperature))

= 6,681 thousand gallons x ((12.46 x 1.0 x 6.309 x 67.811) / 540)

= 65,950 lbs

Incorporate effect of control (vapor balancing requirement)

= Uncontrolled emissions x ((100‐CE)/100)

= 65,950 lbs x ((100‐90)/100)

= 6,595 lbs / 2,000 lbs

= 3.30E+00 tons

h. References

1. U.S. Environmental Protection Agency, “National Emission Standards for Source Categories:  Gasoline

Distribution (Stage I), 40 CFR Part 63.”  Office of Air Quality Planning and Standards, February 28, 1997.  

Pages 9087‐9093.

2. U.S. Environmental Protection Agency, "Gasoline Distribution Industry (Stage I)‐Background Information

for Proposed Standards," EPA‐453/R94‐002a, Office of Air Quality Planning and Standards, January 1994.

3. Eastern Research Group, Inc., "Volume III: Chapter 11, Gasoline Marketing (Stage I and Stage II), Revised

Final," prepared for the Emission Inventory Improvement Program, January 2001.

4. U.S. Environmental Protection Agency, “TANKS Emission Estimation Software,” Office of Air Quality

Planning and Standards, Emission Inventory Group, available from

http://www.epa.gov/ttn/chief/software/tanks/index.html, last updated October 29, 2004.

5. U.S. Environmental Protection Agency, "Gasoline Distribution Industry (Stage I)‐Background Information

for Promulgated Standards," EPA‐453/R94‐002b, Office of Air Quality Planning and Standards, November

1994.
169 

6. U.S. Department of Energy, Energy Information Administration, “U.S. Daily Average Supply and

Distribution of Crude Oil and Petroleum Products,” Table 2 in Petroleum Supply Annual 2008, Volume 1,

retrieved from

http://www.eia.doe.gov/oil_gas/petroleum/data_publications/petroleum_supply_annual/psa_volume1/

psa_volume1.html, released June 2009.

7. Hester, Charles, MACTEC, Inc. Memorandum from Charles Hester, MACTEC, Inc., to Stephen Shedd, U.S.

Environmental Protection Agency, Office of Air Quality Planning and Standards, Emission Standards

Division, "Review of Data on HAP Content in Gasoline," May 18, 2006.

8. U.S. Department of Commerce, Bureau of the Census, County Business Patterns 2007, retrieved from

http://www.census.gov/econ/cbp/index.html, released July 2009.

9. U.S. Department of Energy, Energy Information Administration, "Refinery, Bulk Terminal, and Natural Gas

Plant Stocks of Selected Petroleum Products by PAD District and State, 2008” and "Movements of Crude

Oil and Petroleum Products by Pipeline Between PAD Districts, 2008," Tables 33 and 35 in Petroleum

Supply Annual 2008, Volume 1, retrieved from

http://www.eia.doe.gov/oil_gas/petroleum/data_publications/petroleum_supply_annual/psa_volume1/

psa_volume1.html, released June 2009.

10. Cavalier, Julia, MACTEC, Inc., personal communication, "RE: Percentage of Gasoline Transported Twice By

Truck," with Stephen Shedd, U.S. Environmental Protection Agency, Office of Air Quality Planning and

Standards, Emission Standards Division, July 6, 2004.

11. U.S. Department of Energy, Energy Information Administration, Petroleum Navigator – Product Supplied,

available from http://tonto.eia.doe.gov/dnav/pet/pet_cons_psup_dc_nus_mbblpd_a.htm, accessed

January 2010.

12. Benzene speciation profiles calculated by Jonathan Dorn, E.H. Pechan and Associates, Inc. from county‐

level VOC and benzene emissions developed from a 2008 NMIM run. The NMIM run was performed by

John Van Bruggen, E.H. Pechan and Associates, Inc., January 2010.

13. 2008 NMIM runs performed by John Van Bruggen and Melissa Spivey, E.H. Pechan and Associates, Inc.,

January 2010.

14. U.S. Environmental Protection Agency, "Compilation of Air Pollutant Emission Factors, AP‐42, Fifth Edition,

Volume I:  Stationary Point and Area Sources, Section 5.2 Transportation and Marketing of Petroleum

Liquids," Office of Air Quality Planning and Standards, January 1995.

15. Federal Highway Administration, “Monthly Gasoline/Gasohol Reported by States,” Table MF‐33GA in

Highway Statistics 2008, Office of Highway Policy Information, available from

http://www.fhwa.dot.gov/policyinformation/statistics/2008/, accessed January 2010.

16. Pacific Environmental Services, Inc., "Draft Summary of the Analysis of the Emissions Reported in the 1999

NEI for Stage I and Stage II Operations at Gasoline Service Stations," prepared for the U.S. Environmental

Protection Agency and the Emission Inventory Improvement Program, September 2002.
170 

17. U.S. Environmental Protection Agency, “Compilation of Air Pollutant Emission Factors, AP‐42, Fifth

Edition, Volume I:  Stationary Point and Area Sources, Chapter 7: Liquid Storage Tanks,” Office of Air

Quality Planning and Standards, Emission Inventory Group, September 1997.

  

   
171 

8.19 Open Burning:  Household Waste and Municipal Solid Waste

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  The documentation

below was developed by EPA.

a. Source Category Description

Open burning of residential municipal solid waste (MSW) is the purposeful burning of MSW in outdoor areas.

Criteria air pollutant (CAP) and hazardous air pollutant (HAP) emission estimates for MSW burning are a function of

the amount of waste burned per year.   

For this source category, the following SCC was assigned:

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

2610030000

Waste Disposal,

Treatment, and

Recovery

Open Burning Residential

Household Waste

(use 26‐10‐000‐xxx

for Yard Wastes)

b. Activity Data

The amount of household MSW burned was estimated using data from EPA’s report Municipal Solid Waste

Generation, Recycling, and Disposal in the United States: Facts and Figures for 2010.

1,2  The report presents the

total mass of waste generated from the residential and commercial sectors in the United States by type of waste

for the calendar year 2010.  According to the EPA report, residential waste generation accounts for 55‐65 percent

of the total waste from the residential and commercial sectors.3 For the calculation of per capita household waste

subject to burning, the median value of 60 percent was assumed. This information was used to calculate a daily

estimate of the per capita household waste subject to burning of 1.94 lbs/person/day.  Non‐combustible waste,

such as glass and metals, was not considered to be waste subject to burning.  Burning of yard waste is included in

SCC 2610000100 and SCC 2610000400; therefore, it is not part of residential MSW.  Approximately 25 to 32

percent of all waste that is subject to open burning is actually burned.4,5  A median value of 28 percent is assumed

to be burned in all counties in the United States.   

Since open burning is generally not practiced in urban areas, only the rural population of each county was assumed

to practice open burning.  The ratio of urban to rural population was obtained from 2010 U.S. Census data.6 This

ratio was then multiplied by the 2010 U.S. Census Bureau estimate of the population in each county to obtain the

county‐level rural population for 2010.7

  The county‐level rural population was then multiplied by the per capita

household waste subject to burning to determine the amount of rural household MSW generated in each county in

2010.
172 

c. Controls

Controls for residential MSW burning are generally in the form of a ban on open burning of waste in a given

municipality or county.  Counties that were more than 80% urban were assumed not to practice any open burning.  

Therefore, criteria pollutant and HAP emissions from residential municipal solid waste burning are zero in these

counties.  In addition, the State of Colorado implemented a state‐wide ban on open burning.  Emissions from open

burning of residential waste in all Colorado counties were assumed to be zero.   

d. Emission Factors

Emission factors are reported in the table below. Emission factors for CAPs were developed by the U.S.

Environmental Protection Agency (EPA) in consultation with the Eastern Regional Technical Advisory Committee

and based primarily on the AP‐42 report.8,9 Emission factors for HAPs are from an EPA Control Technology Center

report and emission factors for 17 dioxin congeners were obtained from an EPA dioxin report.10,11

Emission Factors for Open Burning of Residential MSW (2610030000)

Pollutant Pollutant Code Emission Factor

(lb/ton)

Emission Factor

Reference Emission Factor Verification

CO CO 8.50E+01 Reference 9 Correct

NOX NOX 6.00E+00 Reference 9 Correct

PM10‐FIL PM10‐FIL 3.80E+01 Reference 8 Could not access reference paper.

PM10‐PRI PM10‐PRI 3.80E+01 Reference 8 Could not access reference paper.

PM2.5‐FIL PM2.5‐FIL 3.48E+01 Reference 8 Could not access reference paper.

PM2.5‐PRI PM2.5‐PRI 3.48E+01 Reference 8 Could not access reference paper.

SO2 SO2 1.00E+00 Reference 9 Correct

VOC VOC 8.56E+00 Reference 8 Could not access reference paper.

1,2,3,4,6,7,8‐heptachlorodibenzofuran 67562394 2.48E‐07 Reference 11 Could not find emission factor in

reference paper.

1,2,3,4,6,7,8‐heptachlorodibenzo‐p‐dioxin 35822469 7.96E‐08

Reference 11 Could not find emission factor in

reference paper.

1,2,3,4,7,8,9‐heptachlorodibenzofuran 55673897 3.00E‐08

Reference 11 Could not find emission factor in

reference paper.

1,2,3,4,7,8‐hexachlorodibenzofuran 70648269 2.28E‐07

Reference 11 Could not find emission factor in

reference paper.

1,2,3,4,7,8‐hexachlorodibenzo‐p‐dioxin 39227286 1.28E‐08

Reference 11 Could not find emission factor in

reference paper.

1,2,3,6,7,8‐hexachlorodibenzofuran 57117449 7.70E‐08

Reference 11 Could not find emission factor in

reference paper.

1,2,3,6,7,8‐hexachlorodibenzo‐p‐dioxin 57653857 1.94E‐08

Reference 11 Could not find emission factor in

reference paper.

1,2,3,7,8,9‐hexachlorodibenzofuran 72918219 5.00E‐09

Reference 11 Could not find emission factor in

reference paper.

1,2,3,7,8,9‐hexachlorodibenzo‐p‐dioxin 19408743 3.80E‐08

Reference 11 Could not find emission factor in

reference paper.
173 

Pollutant Pollutant Code Emission Factor

(lb/ton)

Emission Factor

Reference Emission Factor Verification

1,2,3,7,8‐pentachlorodibenzofuran 57117416 7.44E‐08

Reference 11 Could not find emission factor in

reference paper.

1,2,3,7,8‐pentachlorodibenzo‐p‐dioxin 40321764 1.62E‐08

Reference 11 Could not find emission factor in

reference paper.

1,2,4‐trichlorobenzene 120821 1.95E‐04 Reference 10 Doesn’t match Table 4.4

1,4‐dichlorobenzene 106467 6.65E‐05 Reference 10 Doesn’t match Table 4.4

2,3,4,6,7,8‐hexachlorodibenzofuran 60851345 1.24E‐07 Reference 11

Could not find emission factor in

reference paper.

2,3,4,7,8‐pentachlorodibenzofuran 57117314 1.30E‐07 Reference 11

Could not find emission factor in

reference paper.

2,3,7,8‐tetrachlorodibenzofuran 51207319 9.12E‐08 Reference 11

Could not find emission factor in

reference paper.

2,3,7,8‐tetrachlorodibenzo‐p‐dioxin 1746016 5.40E‐09 Reference 11

Could not find emission factor in

reference paper.

Acenaphthene

83329

1.54E‐03

Reference 10 Contaminants not listed in Table 4.4

were assumed to be correct and data

results averaged.

Acenaphthylene 208968 2.26E‐02 Reference 10 Matches value in Table 4.4

Acetalaldehyde 75070 8.57E‐01 Reference 10 Not in paper anywhere

Acrolein

107028

6.19E‐02

Reference 10 Contaminants not listed in Table 4.4

were assumed to be correct and data

results averaged.

Anthracene

120127

3.66E‐03

Reference 10 Contaminants not listed in Table 4.4

were assumed to be correct and data

results averaged.

Benz[a]anthracene

56553

4.48E‐03

Reference 10 Contaminants not listed in Table 4.4

were assumed to be correct and data

results averaged.

Benzene

71432

2.48E+00

Reference 10 Contaminants not listed in Table 4.4

were assumed to be correct and data

results averaged.

Benzo[a]pyrene

50328

4.24E‐03

Reference 10 Contaminants not listed in Table 4.4

were assumed to be correct and data

results averaged.

Benzo[b]fluoranthene

205992

5.26E‐03

Reference 10 Contaminants not listed in Table 4.4

were assumed to be correct and data

results averaged.

Benzo[g,h,i,]Perylene

191242

3.95E‐03

Reference 10 Contaminants not listed in Table 4.4

were assumed to be correct and data

results averaged.

Benzo[k]fluoranthene

207089

2.05E‐03

Reference 10 Contaminants not listed in Table 4.4

were assumed to be correct and data

results averaged.

Chlorobenzene

108907

8.48E‐04

Reference 10 Contaminants not listed in Table 4.4

were assumed to be correct and data

results averaged.
174 

Pollutant Pollutant Code Emission Factor

(lb/ton)

Emission Factor

Reference Emission Factor Verification

Chrysene

218019

5.07E‐03

Reference 10 Contaminants not listed in Table 4.4

were assumed to be correct and data

results averaged.

Dibenzo[a,h]anthracene

53703

6.46E‐04

Reference 10 Contaminants not listed in Table 4.4

were assumed to be correct and data

results averaged.

Fluoranthene

206440

8.14E‐03

Reference 10 Contaminants not listed in Table 4.4

were assumed to be correct and data

results averaged.

Fluorene

86737

7.31E‐03

Reference 10 Contaminants not listed in Table 4.4

were assumed to be correct and data

results averaged.

Hexachlorobenzene 118741 4.40E‐05 Reference 10 Matches value in Table 4.4

Hydrochloric Acid

7647010

5.68E‐01

Reference 10 Matches value in Table 4.4 but why not

using the highest value as compared to

the lowest?

Hydrogen Cyanide 74908 9.36E‐01 Reference 10 Matches value in Table 4.4

Indeno[1,2,3‐c,d]pyrene 193395 3.75E‐03 Reference 10

Naphthalene 91203 3.51E‐02 Reference 10 Matches value in Table 4.4

Octachlorodibenzofuran 39001020 7.28E‐08 Reference 11

Could not find emission factor in

reference paper.

Octachlorodibenzo‐p‐dioxin 3268879 9.94E‐08 Reference 11

Could not find emission factor in

reference paper.

Pentachlorophenol

87865

1.06E‐04

Reference 10 Contaminants not listed in Table 4.4

were assumed to be correct and data

results averaged.

Phenanthrene 85018 1.46E‐02 Reference 10 Matches value in Table 4.4

Phenol 108952 2.80E‐01 Reference 10 Matches value in Table 4.4

Polychlorinated Biphenyls

1336363

5.72E‐03

Reference 10 Contaminants not listed in Table 4.4

were assumed to be correct and data

results averaged.

Pyrene

129000

9.66E‐03

Reference 10 Contaminants not listed in Table 4.4

were assumed to be correct and data

results averaged.

Styrene 100425 1.48E+00 Reference 10 Matches value in Table 4.4

e. Emissions

County‐level criteria pollutant and HAP emissions were calculated by multiplying the total amount of residential

municipal solid waste burned per year by an emission factor.   

    

f. Example Calculations
175 

VOC emissions in Autauga County, Alabama from open burning of residential MSW:

Population of Autauga County in 2010 = 54,571

Rural fraction of Autauga County population = 0.42

Per capita MSW generated (lb/person/day) = 1.9435

Fraction of rural population that burns MSW = 0.28

Number of days in a year = 365

Factor to convert from lbs to tons = 1/2000

2010 MSW burning activity in Autauga County = 54,571 * 0.42 * 1.9435 * 0.28 * 365 * 1/2000

2010 MSW activity in Autauga County = 2,276 tons

VOC emissions = MSW burned * VOC emission factor

VOC emission factor = 8.56 lb/ton

VOC emissions from MSW burning in Autauga County = 2,276 tons * 8.56 lbs/ton * 1 ton/2000 lbs

VOC emissions from MSW burning in Autauga County in 2010 = 9.74 tons

g. QA/QC

I. Methodology

The methodology was reviewed and understood with no questions.  EIIP information was also

reviewed and survey information may be beneficial to update Missouri emission factors.

II. Data

The data was checked for the listed emission factors in the emission factor table above.  Please

see column 5 of that table for emission factor review comments.  Many emission factors could be

found, some could not be replicated from the Reference documents available.  Despite these

shortcomings, the amount of time to find replacement emission factors is prohibitive, so EPA’s

factors will be accepted for 2011.  For future NEI submittals, Missouri will spend more time on

verification of emission factors and retrieving reference materials.
176 

III. Math

The formulas from the excel spreadsheet data were check and verified with no discrepancies.

IV. Overall

Missouri will accept EPA’s estimates for the residential municipal solid waste burning category

despite unverified emission factors.

h. References

1. U.S. Environmental Protection Agency, Municipal Solid Waste Generation, Recycling, and Disposal in the

United States: Facts and Figures for 2010, "Table 1. Materials Generated in the Municipal Waste Stream,

1960 to 2010," December 2011, available at

http://www.epa.gov/epawaste/nonhaz/municipal/pubs/2010_MSW_Tables_and_Figures_508.pdf

(accessed April 2012).

2. U.S. Environmental Protection Agency, Municipal Solid Waste Generation, Recycling, and Disposal in the

United States: Facts and Figures for 2010, "Table 2. Materials Recovered in the Municipal Waste Stream,

1960 to 2010," December 2011, available at

http://www.epa.gov/epawaste/nonhaz/municipal/pubs/2010_MSW_Tables_and_Figures_508.pdf

(accessed April 2012).

3. U.S. Environmental Protection Agency, Municipal Solid Waste Generation, Recycling, and Disposal in the

United States: Facts and Figures for 2010—Fact Sheet," p. 4,December 2011, available at

http://www.epa.gov/epawaste/nonhaz/municipal/pubs/msw_2010_rev_factsheet.pdf (accessed April

2012).

4. U.S. Environmental Protection Agency, Region V.  “Emission Characteristics of Burn Barrels.”  Prepared by

Two Rivers Regional Council of Public Officials and Patrick Engineering, Inc.  June 1994.

5. Garbage Burning in Rural Minnesota: Key Results and Findings, prepared by Zenith Research Group for

Minnesota Pollution Control Agency, June 2010, available at

http://www.pca.state.mn.us/index.php/view‐document.html?gid=14316 (accessed June 10, 2011).  

6. U.S. Census Bureau, Decennial Censuses, 2010 Census: SF1, Table P2

7. U.S. Census Bureau.  Annual Estimates of the Resident Population for the United States, Regions, States,

and Puerto Rico: April 1, 2010 to July 1, 2011 (NST‐EST2011‐01), available at

http://www.census.gov/popest/data/national/totals/2011/index.html (accessed April 2012).
177 

8. Huntley, Roy, U.S. Environmental Protection Agency, “state_comparison  ERTAC SS_version7_3 Oct 20

2009 [electronic file],” November 5, 2009.

9. United States Environmental Protection Agency, Office of Air Quality Planning and Standards.  

Compilation of Air Pollutant Emission Factors, AP‐42, Fifth Edition, Volume I:  Stationary Point and Area

Sources, Section 2.5 Open Burning.  Research Triangle Park, NC.  October 1992.

10. U.S. Environmental Protection Agency, Control Technology Center.  “Evaluation of Emissions from the

Open Burning of Household Waste in Barrels.” EPA‐600/R‐97‐134a.  November 1997.

11. United States Environmental Protection Agency, Office of Research and Development.  Exposure and

Human Health Reassessment of 2,3,7,8‐Tetrachlorodibenzeno‐p‐Dioxin (TCCD) and Related Compounds.  

Part I:  Estimating Exposure to Dioxin‐Like Compounds.  Volume 2:  Sources of Dioxin‐Like Compounds in

the United States.  EPA/600/P‐00/001Ab.  Washington D.C.  March 2001.

   
178 

8.20 Open Burning:  Land Clearing Debris

The Missouri DNR accepted EPA’s estimates of emissions for this source category, but added Hazardous

Air Pollutant data to EPA’s Criteria Air Pollutant data.  The documentation below was developed by EPA.  

a. Source Category Description 

Open burning of land clearing debris is the purposeful burning of debris, such as trees, shrubs, and brush, from the 

clearing of land for the construction of new buildings and highways. Criteria air pollutant (CAP) and hazardous air 

pollutant (HAP) emission estimates from open burning of land clearing debris are a function of the amount of 

material or fuel subject to burning per year. 

For this source category, the following SCC was assigned: 

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4 

2610000500 Waste Disposal, 

Treatment, and Recovery Open Burning All Categories 

Land Clearing Debris 

(use 28-10-005-000 

for Logging Debris 

Burning) 

b. Activity Data 

The amount of material burned was estimated using the county-level total number of acres disturbed by residential, 

non-residential, and road construction. County-level weighted loading factors were applied to the total number of 

construction acres to convert acres to tons of available fuel. 

Acres Disturbed from Residential Construction 

The US Census Bureau has 2010 data for Housing Starts - New Privately Owned Housing Units Started1 which 

provides regional level housing starts based on the groupings of 1 unit, 2-4 units, 5 or more units. A consultation 

with the Census Bureau in 2002 gave a breakdown of approximately 1/3 of the housing starts being for 2 unit 

structures, and 2/3 being for 3 and 4 unit structures. The 2-4 unit category was divided into 2-units, and 3-4 units 

based on this ratio. To determine the number of structures for each grouping, the 1 unit category was divided by 1, 

the 2 unit category was divided by 2, and the 3-4 unit category was divided by 3.5. The 5 or more unit category may 

be made up of more than one structure. New Privately Owned Housing Units Authorized Unadjusted Units2

 gives a 

conversion factor to determine the ratio of structures to units in the 5 or more unit category. For example if a county 

has one 40 unit apartment building, the ratio would be 40/1. If there are 5 different 8 unit buildings in the same 

project, the ratio would be 40/5. Structures started by category are then calculated at a regional level. The table 

Annual Housing Units Authorized by Building Permit3

 has 2010 data at the county level to allocate regional housing 

starts to the county level. This results in county level housing starts by number of units. The following surface areas 

were assumed disturbed for each unit type: 

Surface Acres Disturbed per Unit Type 

1-Unit 1/4 acre/structure

2-Unit 1/3 acre/structure

Apartment 1/2 acre/structure 

 The 3-4 unit and 5 or more unit categories were considered to be apartments. Multiplication of housing starts to 

surface acres disturbed results in total number of acres disturbed for each unit category. 

Acres Disturbed from Non-Residential Construction 

Annual Value of Construction Put in Place in the U.S4 has the 2011 National Value of Non-residential construction. 

The national value of non-residential construction put in place (in millions of dollars) was allocated to counties 
179 

using county-level non-residential construction (NAICS Code 2362) employment data obtained from County 

Business Patterns5

 (CBP). Because some county employment data was withheld due to privacy concerns, the 

following procedure was adopted: 

4. State totals for the known county level employees were subtracted from the number of employees reported 

in the state level version of CBP. This results in the total number of withheld employees in the state. 

5. A starting estimate of the midpoint of the range code was used (so for instance in the 1-19 employees 

range, an estimate of 10 employees would be used) and a state total of the withheld counties was computed. 

6. A ratio of estimated employees (Step 2) to withheld employees (Step 1) was then used to adjust the county 

level estimates up or down so the state total of adjusted guesses should match state total of withheld 

employees (Step 1) 

In 1999 a figure of 2 acres/$106

 was developed. The Bureau of Labor Statistics Producer Price Index6 lists costs of 

the construction industry from 1999-11 

 2011 acres per $106

 = 1999 acres per $106 x (1999 PPI / 2011 PPI) 

 = 2 acres/$106

 (132.9 / 229.3) 

 = 1.159 acres per $106 

Acres Disturbed by Road Construction 

The Federal Highway Administration provides data on spending by state in several different categories of road 

construction and maintenance in Highway Statistics, Section IV - Highway Finance, Table SF-12A, State Highway 

Agency Capital Outlay7 for 2008. (Note that this table has not been available in subsequent versions of Highway 

Statistics. Thus, 2008 is the latest data currently available.) For this SCC, the following sets of data (or columns) 

are used: New Construction, Relocation, Added Capacity, Major Widening, and Minor Widening. Each of these 

data sets are also differentiated according to the following six roadway classifications: 

1. Interstate, urban 

2. Interstate, rural 

3. Other arterial, urban 

4. Other arterial, rural 

5. Collectors, urban 

6. Collectors, rural 

The State expenditure data are then converted to new miles of road constructed using $/mile conversions obtained 

from the North Carolina Department of Transportation (NCDOT) in 2000. A conversion of $4 million/mile was 

applied to the interstate expenditures. For expenditures on other arterial and collectors, a conversion factor of $1.9 

million/mile was applied, which corresponds to all other projects. 

The new miles of road constructed are used to estimate the acreage disturbed due to road construction. The total 

area disturbed in each state was calculated by converting the new miles of road constructed to acres using an acres 

disturbed/mile conversion factor for each road type as given in the table below: 

Spending per Mile and Acres Disturbed per Mile by Highway Type 

Road Type Thousand Dollars per mile Acres Disturbed per mile 

Urban Areas, Interstate 4000 15.2

Rural Areas, Interstate 4000 15.2

Urban Areas, Other Arterials 1900 15.2

Rural Areas, Other Arterials 1900 12.7

Urban Areas, Collectors 1900 9.8

Rural Areas, Collectors 1900 7.9
180 

County-level building permits data are used to allocate the state-level acres disturbed by road construction to the 

county.8

 A ratio of the number of building starts in each county to the total number of building starts in each state 

was applied to the state-level acres disturbed to estimate the total number of acres disturbed by road construction in 

each county. 

Converting Acres Disturbed to Tons of Land Clearing Debris Burned 

Version 2 of the Biogenic Emissions Land cover Database (BELD2) within EPA’s Biogenic Emission Inventory 

System (BEIS) was used to identify the acres of hardwoods, softwoods, and grasses in each county. The table below 

presents the average fuel loading factors by vegetation type. The average loading factors for slash hardwood and 

slash softwood were adjusted by a factor of 1.5 to account for the mass of tree that is below the soil surface that 

would be subject to burning once the land is cleared.9

 Weighted average county-level loading factors were 

calculated by multiplying the average loading factors by the percent contribution of each type of vegetation class to 

the total land area for each county. 

Fuel Loading Factors by Vegetation Type

Vegetation Type 

Unadjusted Average 

Fuel Loading Factor 

(Ton/acre) 

Adjusted Average Fuel 

Loading Factor 

(Ton/acre) 

Hardwood 66 99 

Softwood 38 57 

Grass 4.5 Not Applicable 

The total acres disturbed by all construction types was calculated by summing the acres disturbed from residential, 

non-residential, and road construction. The county-level total acres disturbed were then multiplied by the weighted 

average loading factor to derive tons of land clearing debris. 

c. Controls 

Controls for land clearing debris burning are generally in the form of a ban on open burning of waste in a given 

municipality or county. Counties that were more than 80% urban were assumed not to practice any open burning. 

Therefore, criteria pollutant and HAP emissions from open burning of land clearing debris are zero in these counties. 

In addition, the State of Colorado implemented a state-wide ban on open burning. Emissions from open burning of 

land clearing debris in all Colorado counties were assumed to be zero. 

d. Emission Factors 

Emission factors are reported in the table below. Emission factors for CAPs were developed by the U.S. 

Environmental Protection Agency (EPA) in consultation with the Eastern Regional Technical Advisory Committee 

and based primarily on the AP-42 report.10,11 The PM2.5 to PM10 emission factor ratio for brush burning (0.7709) was 

multiplied by the PM10 emission factors for land clearing debris burning to develop PM2.5 emission factors. 

Emission factors for HAPs are from an EPA Control Technology Center report12 and emission factors for 17 dioxin 

congeners were obtained from an EPA dioxin report.13 The dioxin emission factors were multiplied by 0.002 to 

convert from mg/kg to lb/ton. 

Emission Factors for Open Burning of Land Clearing Debris (SCC 2610000500)

Pollutant Pollutant Code Emission Factor (lb/ton) Emission Factor Reference 

VOC VOC 11.6 Reference 10 

NOX NOX 5 Reference 10 

CO CO 169 Reference 10 

PM10-FIL PM10-FIL 17 Reference 10 
181 

PM2.5-FIL PM2.5-FIL 13.1 PM10-FIL multiplied by 0.7709 

PM10-PRI PM10-PRI 17 Reference 10 

PM2.5-PRI PM2.5-PRI 13.1 PM10-PRI multiplied by 0.7709

1,2,3,4,6,7,8-HpCDD 35822469 3.33E-07 Reference 13 

1,2,3,4,6,7,8-HpCDF 67562394 5.08E-08 Reference 13 

1,2,3,4,7,8,9-HpCDF 55673897 6.12E-09 Reference 13 

1,2,3,4,7,8-HxCDD 39227286 1.14E-08 Reference 13 

1,2,3,4,7,8-HxCDF 70648269 3.34E-08 Reference 13 

1,2,3,6,7,8-HxCDD 57653857 2.14E-08 Reference 13 

1,2,3,6,7,8-HxCDF 57117449 1.43E-08 Reference 13 

1,2,3,7,8,9-HxCDD 19408743 3.47E-08 Reference 13 

1,2,3,7,8,9-HxCDF 72918219 2.23E-09 Reference 13 

1,2,3,7,8-PeCDD 40321764 7.66E-09 Reference 13 

1,2,3,7,8-PeCDF 57117416 1.27E-08 Reference 13 

2,3,4,6,7,8-HxCDF 60851345 1.96E-08 Reference 13 

2,3,4,7,8-PeCDF 57117314 2.02E-08 Reference 13 

2,3,7,8-TCDD 1746016 2.30E-09 Reference 13 

2,3,7,8-TCDF 51207319 1.40E-08 Reference 13 

Cumene 98828 1.33E-02 Reference 12 

Dibenzofuran 132649 6.75E-03 Reference 12 

Ethyl Benzene 100414 4.80E-02 Reference 12 

OCDD 3268879 1.33E-06 Reference 13 

OCDF 39001020 2.05E-08 Reference 13 

Phenol 108952 1.15E-01 Reference 12 

Styrene 100425 1.02E-01 Reference 12 

e. Emissions 

County-level criteria pollutant and HAP emissions were calculated by multiplying the total mass of land clearing 

debris burned per year by an emission factor. 

f. Example Calculations 

VOC emissions in Autauga County, Alabama from open burning of land clearing debris: 

Rural fraction of Autauga County population = 0.42, so no emission controls 

Acres disturbed by residential, non-residential, and road construction in Autauga County = 84.83 

Weighted average fuel loading factor for Autauga County = 65.48 tons/acre 

Mass of land clearing debris burned = 84.83 acres * 65.48 tons/acre = 5,555 tons 

VOC emission factor = 11.6 lbs/ton 

Factor to convert from lbs to tons = 1/2000 

VOC emissions = tons of land clearing debris burned * VOC emission factor 

VOC emissions from land clearing debris burning = 5,555 tons * 11.6 lbs/ton * 1 ton/2000 lbs 

VOC emissions from land clearing debris burning in Autauga County in 2010 = 32 tons 

g. QA/QC 
182 

1. Surrogate methods seem reasonable for determining activity level for land clearing for residential, nonresidential, and road construction. 

2. Reference 10, “state_comparison ERTAC SS_version7_3 Oct 20 2009” cannot be found. The closest 

document that can be found is “state_comparison_ERTAC_SS_version7.2_23nov2009.” The values in the 

two documents for emissions from open burning of land-clearing debris appear to be the same. 

3. The values for the non-residential category in “Value of Private Construction Put in Place - Not Seasonally 

Adjusted” do not match the values shown in the reference at 

http://www.census.gov/const/C30/priv2011.pdf. This same discrepancy was found in the non-residential 

construction- fugitive dust category. The corrected values are used to update the calculation of the number 

of acres cleared and affected by open burning for land clearing. 

4. The estimate of acres disturbed from non-residential construction uses an assumed value from 1999 of 2 

acres/$106

, which is adjusted to 2011. The source of the 2 acres/$106 is not given and cannot be verified. 

h. References 

1. U.S. Census Bureau, “New Privately Owned Housing Units Started for 2010 ( Not seasonally adjusted),” 

available at http://www.census.gov/const/startsua.pdf

2. U.S. Census Bureau, “Table 2au. New Privately Owned Housing Units Authorized Unadjusted Units for 

Regions, Divisions, and States, Annual 2010” available at 

http://www.census.gov/const/C40/Table2/tb2u2010.txt

3. Annual Housing Units Authorized by Building Permits CO2010A, purchased from US Department of 

Census 

4. U.S. Census Bureau, “Annual Value of Construction Put in Place,” available at 

http://www.census.gov/const/www/ototpage.html

5. U.S. Census Bureau, “County Business Patterns,” available at http://www.census.gov/econ/cbp/index.html

6. Bureau of Labor Statistics, Producer Price Index, Table BMNR, available at http://www.bls.gov/data/ 

7. Federal Highway Administration, 2008 Highway Spending, available at 

http://www.fhwa.dot.gov/policyinformation/statistics/2008/sf12a.cfm

8. 2008 Building Permits data from US Census “BPS01”, 

http://www.census.gov/support/USACdataDownloads.html

9. Ward, D.E., C.C. Hardy, D.V. Sandberg, and T.E. Reinhardt. “Mitigation of Prescribed Fire Atmospheric 

Pollution through Increased Utilization of Hardwoods, Piled Residues, and Long-Needled Conifers.” Final 

Report. USDA Forest Service, Pacific Northwest Research Station, Fire and Air Resource Management. 

1989. 

10. Huntley, Roy, U.S. Environmental Protection Agency, “state_comparison ERTAC SS_version7_3 Oct 20 

2009 [electronic file],” November 5, 2009. 

11. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. Compilation of Air 

Pollutant Emission Factors, AP-42, Fifth Edition, Volume I: Stationary Point and Area Sources, Section 

2.5 Open Burning. Research Triangle Park, NC. October 1992. 

12. U.S. Environmental Protection Agency, “Evaluation of Emissions from the Open Burning of Household 

Waste in Barrels, EPA-600/R-97-134a,” Control Technology Center. November 1997. 

13. Gullet, B.K. and T. Abderrahmne, “PCDD/F Emissions from Forest Fire Simulations,” Atmospheric 

Environment, Vol. 37, No. 6, pp. 803-813. February 2003. 
183 

 Emission Factors for Open Burning of Land Clearing Debris (SCC 2610000500)

Pollutant Pollutant Code Emission Factor

(lb/ton) 

Emission 

Factor 

Reference 

VOC VOC 11.6 Reference 10 

NOX NOX 5 Reference 10 

CO CO 169 Reference 10 

PM10-FIL PM10-FIL 17 Reference 10 

PM2.5-FIL 

PM2.5-FIL 

13.1 PM10-FIL 

multiplied by 

0.7709 

PM10-PRI PM10-PRI 17 Reference 10 

PM2.5-PRI 

PM2.5-PRI 

13.1 PM10-PRI 

multiplied by 

0.7709 

1,2,3,4,6,7,8-HpCDD 35822469 3.33E-07 Reference 13 

1,2,3,4,6,7,8-HpCDF 67562394 5.08E-08 Reference 13 

1,2,3,4,7,8,9-HpCDF 55673897 6.12E-09 Reference 13 

1,2,3,4,7,8-HxCDD 39227286 1.14E-08 Reference 13 

1,2,3,4,7,8-HxCDF 70648269 3.34E-08 Reference 13 

1,2,3,6,7,8-HxCDD 57653857 2.14E-08 Reference 13 

1,2,3,6,7,8-HxCDF 57117449 1.43E-08 Reference 13 

1,2,3,7,8,9-HxCDD 19408743 3.47E-08 Reference 13 

1,2,3,7,8,9-HxCDF 72918219 2.23E-09 Reference 13 

1,2,3,7,8-PeCDD 40321764 7.66E-09 Reference 13 

1,2,3,7,8-PeCDF 57117416 1.27E-08 Reference 13 

2,3,4,6,7,8-HxCDF 60851345 1.96E-08 Reference 13 

2,3,4,7,8-PeCDF 57117314 2.02E-08 Reference 13 

2,3,7,8-TCDD 1746016 2.30E-09 Reference 13 

2,3,7,8-TCDF 51207319 1.40E-08 Reference 13 

Cumene 98828 1.33E-02 Reference 12 

Dibenzofuran 132649 6.75E-03 Reference 12 

Ethyl Benzene 100414 4.80E-02 Reference 12 

OCDD 3268879 1.33E-06 Reference 13 

OCDF 39001020 2.05E-08 Reference 13 

Phenol 108952 1.15E-01 Reference 12 

Styrene 100425 1.02E-01 Reference 12 

   
184 

8.21 Open Burning: Yard Waste

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  The documentation

below was developed by EPA.  

a. Source Category Description

Open burning of yard waste is the purposeful burning of leaf and brush species in outdoor areas. Criteria air

pollutant (CAP) and hazardous air pollutant (HAP) emission estimates for leaf and brush waste burning are a

function of the amount of waste burned per year.   

For this source category, the following SCCs were assigned:

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

2610000100

Waste Disposal,

Treatment, and

Recovery

Open Burning All Categories Yard Waste – Leaf

Species Unspecified

2610000400

Waste Disposal,

Treatment, and

Recovery

Open Burning All Categories Yard Waste – Brush

Species Unspecified

b. Activity Data

The amount of leaf and brush waste burned was estimated using data from EPA’s report Municipal Solid Waste

Generation, Recycling, and Disposal in the United States: Facts and Figures for 2010.1,2  The report presents the

total mass of waste generated from the residential and commercial sectors, including yard waste, in the United

States by type of waste for the calendar year 2010.  According to the EPA report, residential waste generation

accounts for 55‐65 percent of the total waste from the residential and commercial sectors.3 For the calculation of

per capita yard waste subject to burning, the median value of 60 percent was assumed.  This information was used

to calculate a daily estimate of the per capita yard waste of 0.36 lbs/person/day.  Of the total amount of yard

waste generated, the yard waste composition was assumed to be 25 percent leaves, 25 percent brush, and 50

percent grass by weight.4

   

Open burning of grass clippings is not typically practiced by homeowners, and as such only estimates for leaf

burning and brush burning were developed.  Approximately 25 to 32 percent of all waste that is subject to open

burning is actually burned.4

  A median value of 28 percent is assumed to be burned in all counties in the United

States.
185 

The per capita estimate was then multiplied by the 2010 population in each county that is expected to burn waste.  

Since open burning is generally not practiced in urban areas, only the rural population of each county was assumed

to practice open burning.  The ratio of urban to rural population was obtained from 2010 U.S. Census data.5

  This

ratio was then multiplied by the 2010 U.S. Census Bureau estimate of the population in each county to obtain the

county‐level rural population for 2010.6

The percentage of forested acres from Version 2 of BELD2 within BEIS was used to adjust for variations in

vegetation.  The percentage of forested acres per county (including rural forest and urban forest) was then

determined.  To better account for the native vegetation that would likely be occurring in the residential yards of

farming States, agricultural land acreage was subtracted before calculating the percentage of forested acres.  The

table below presents the ranges that were used to make adjustments to the amount of yard waste that is assumed

to be generated per county. All municipios in Puerto Rico and counties in the U.S. Virgin Islands, Hawaii, and Alaska

were assumed to have greater than 50 percent forested acres.

Adjustment for Percentage of Forested Acres

Percent Forested Acres

per County

Adjustment for

Yard Waste Generated

< 10% 0% generated

>= 10%, and < 50%   50% generated

>= 50% 100% generated

c. Controls

Controls for yard waste burning are generally in the form of a ban on open burning of waste in a given municipality

or county.  Counties that were more than 80% urban were assumed not to practice any open burning. Therefore,

criteria pollutant and HAP emissions from residential yard waste burning are zero in these counties. In addition,

the State of Colorado implemented a state‐wide ban on open burning.  Emissions from open burning of residential

yard waste in all Colorado counties were assumed to be zero.

d. Emission Factors

Emission factors are specific to yard waste type and are reported in the corresponding tables below. Emission

factors for CAPs were developed by the U.S. Environmental Protection Agency (EPA) in consultation with the

Eastern Regional Technical Advisory Committee.7

For leaf burning, emission factors for PM2.5 were calculated by

multiplying the PM10 leaf burning emission factors by the PM2.5 to PM10 emission factor ratio for brush burning

(0.7709).  Emission factors for HAPs are from an EPA Control Technology Center report.8

  Forest fire simulation

emission factors were used to estimate emissions for 17 dioxin congeners.9
186 

e. Emissions

County‐level criteria pollutant and HAP emissions were calculated by multiplying the total amount of yard waste

(either leaf or brush) burned per year by an emission factor.  Emissions for leaves and residential brush were

calculated separately, since emission factors vary by yard waste type.   

f. Example Calculations

VOC emissions in Autauga County, Alabama from open burning of leaf waste:

Population of Autauga County in 2010 = 54,571

Rural fraction of Autauga County population = 0.42

Per capita waste yard waste generated (lb/person/day) = 0.3557

Leaf fraction of waste = 0.25

Fraction of rural population that burns yard waste = 0.28

Adjustment factor based on % forested acres = 1

Number of days in a year = 365

Factor to convert from lbs to tons = 1/2000

2010 leaf burning activity in Autauga County = 54,571 * 0.42 * 0.3557 * 0.25 * 0.28 * 1 * 365 * 1/2000

2010 leaf burning activity in Autauga County = 104.15 tons

VOC emissions = tons of leaves burned * VOC emission factor

VOC emission factor = 28 lb/ton

VOC emissions from leaf burning in Autauga County in 2010 = 104.15 tons * 28 lbs/ton * 1 ton/2000 lbs

VOC emissions from leaf burning in Autauga County in 2010 = 1.46 tons

g. QA/QC

1. Methodology: Appears to be adequate and accurate.  

a. Paragraph b. 1 ‐  all of the referenced material confirmed  and matches, except for the last

sentence about the composition of yard waste consisting of 25% leaves, 25% brush, and 50%

grass – this info is referenced in a book, which cannot be obtained electronically(same as 2008).

One change from 2008 is the addition of sentences 3 and 4, which assumes 60% of all residential

and commercial waste is yard waste subject to burning. Still seems high, but this was not

factored at all in 2008. This additional factor results in reducing the total VOC emissions by

approximately 40%.   

b. Paragraph b. 2 ‐  Removed grass clipping burning factor since no one burns their grass clippings

(same as 2008).  
187 

c. Paragraph b. 3 – Removed urban population factor since urban areas generally do not allow open

burning. Paragraph c. ‐ Counties that are more than 80% urban are assumed to have NO

residential open burning.  

d. Paragraph b. 4 – Agricultural/non‐forested acres was removed from equation – some places just

don’t have many trees.  

e. Paragraph d. – PM2.5 emission factor change is explained. The 2008 emission factor was 22. It is

now 16.96.  

f. References – a little different than in 2008 – nothing significant.  

g. Tables of emission factors for pollutants – everything here is the same as 2008 except:  

i. Methyl Ethyl Ketone was removed from the current list/table

ii. The emission factor for PM2.5 FIL and PRI changed from 22 in 2008 to 16.96 in 2011.  

2. Data and Calcs: I checked the math for the counties of Adair, Franklin, Gasconade, Jefferson, Lincoln, and

Montgomery for the pollutants of PM10 primary, NOx, and VOC. I didn’t find any mistakes – only

discrepancies from inconsistent use of significant figures (EPA uses 2‐4 sig figs – I always used 2 and the

end result always came out very close – only varied by a hundredth or thousandth).  

3. Overall: Appears everything is accurate in this document and the associated data. I compared this 2011

document to DNR’s 2008 version and everything matches except for the items added, which are in red

above. I have a marked up hard copy of this document compared to the 2008 version in case you would

like to visually see the differences.  

h.  References

1. U.S. Environmental Protection Agency, Municipal Solid Waste Generation, Recycling, and Disposal in the

United States: Facts and Figures for 2010, "Table 1. Materials Generated in the Municipal Waste Stream,

1960 to 2010," December 2011, available at

http://www.epa.gov/epawaste/nonhaz/municipal/pubs/2010_MSW_Tables_and_Figures_508.pdf

(accessed April 2012).

2. U.S. Environmental Protection Agency, Municipal Solid Waste Generation, Recycling, and Disposal in the United

States: Facts and Figures for 2010, "Table 2. Materials Recovered in the Municipal Waste Stream, 1960 to

2010," December 2011, available at

http://www.epa.gov/epawaste/nonhaz/municipal/pubs/2010_MSW_Tables_and_Figures_508.pdf (accessed

April 2012).

3. U.S. Environmental Protection Agency, Municipal Solid Waste Generation, Recycling, and Disposal in the

United States: Facts and Figures for 2010—Fact Sheet," p. 4,December 2011, available at

http://www.epa.gov/epawaste/nonhaz/municipal/pubs/msw_2010_rev_factsheet.pdf (accessed April

2012).

4. Two Rivers Regional Council of Public Officials and Patrick Engineering, Inc.  “Emission Characteristics of Burn

Barrels,” prepared for the U.S. Environmental Protection Agency, Region V.  June 1994.

5. U.S. Census Bureau, Decennial Censuses, 2010 Census: SF1, Table P2

6. U.S. Census Bureau.  Annual Estimates of the Resident Population for the United States, Regions, States, and

Puerto Rico: April 1, 2010 to July 1, 2011 (NST‐EST2011‐01), available at

http://www.census.gov/popest/data/national/totals/2011/index.html (accessed April 2012).

7. Huntley, Roy, U.S. Environmental Protection Agency, “state_comparison  ERTAC SS_version7_3 Oct 20 2009

[electronic file],” November 5, 2009.

8. U.S. Environmental Protection Agency, Evaluation of Emissions from the Open Burning of Household Waste in

Barrels, EPA‐600/R‐97‐134a, Control Technology Center.  November 1997.
188 

9. Gullet, B.K. and T. Abderrahmne, “PCDD/F Emissions from Forest Fire Simulations,” Atmospheric Environment,

Vol. 37, No. 6, pp. 803‐813.  February 2003.

   
189 

Emission Factors for Open Burning of Leaf Species (SCC 2610000100)

Pollutant Pollutant Code Emission Factor(lb/ton) Emission Factor Reference

1,2,3,4,6,7,8‐heptachlorodibenzofuran 67562394 5.08E‐08 Reference 9

1,2,3,4,6,7,8‐heptachlorodibenzo‐p‐dioxin 35822469 3.32E‐07 Reference 9

1,2,3,4,7,8,9‐heptachlorodibenzofuran 55673897 6.12E‐09 Reference 9

1,2,3,4,7,8‐hexachlorodibenzofuran 70648269 3.34E‐08 Reference 9

1,2,3,4,7,8‐hexachlorodibenzo‐p‐dioxin 39227286 1.136E‐08 Reference 9

1,2,3,6,7,8‐hexachlorodibenzofuran 57117449 1.428E‐08 Reference 9

1,2,3,6,7,8‐hexachlorodibenzo‐p‐dioxin 57653857 2.14E‐08 Reference 9

1,2,3,7,8,9‐hexachlorodibenzofuran 72918219 2.22E‐09 Reference 9

1,2,3,7,8,9‐hexachlorodibenzo‐p‐dioxin 19408743 3.46E‐08 Reference 9

1,2,3,7,8‐pentachlorodibenzofuran 57117416 1.268E‐06 Reference 9

1,2,3,7,8‐pentachlorodibenzo‐p‐dioxin 40321764 7.66E‐09 Reference 9

2,3,4,6,7,8‐hexachlorodibenzofuran 60851345 1.962E‐08 Reference 9

2,3,4,7,8‐pentachlorodibenzofuran 57117314 2.02E‐08 Reference 9

2,3,7,8‐tetrachlorodibenzofuran 51207319 1.396E‐08 Reference 9

2,3,7,8‐tetrachlorodibenzo‐p‐dioxin 1746016 2.3E‐09 Reference 9

CO CO 112 Reference 7

Cumene 98828 0.01325 Reference 8

Ethyl Benzene 100414 0.048 Reference 8

Nitrogen Oxides NOX 6.2 Reference 7

Octachlorodibenzofuran 39001020 2.06E‐08 Reference 9

Octachlorodibenzo‐p‐dioxin 3268879 1.328E‐06 Reference 9

Phenol 108952 0.115 Reference 8

PM10‐FIL PM10‐FIL 22 Reference 7

PM10‐PRI PM10‐PRI 22 Reference 7

PM2.5‐FIL PM2.5‐FIL 16.96 0.7709 * PM10

PM2.5‐PRI PM2.5‐PRI 16.96 0.7709 * PM10

Styrene 100425 0.1015 Reference 8

Sulfur Dioxide SO2 0.76 Reference 7

VOC VOC 28 Reference 7
190 

Emission Factors for Open Burning of Brush Species (SCC 2610000400)

Pollutant Pollutant Code Emission Factor

(lb/ton)

Emission Factor

Reference

CO CO 140 Reference 7

Nitrogen Oxides NOX 5 Reference 7

PM10‐PRI PM10‐PRI 19.73 Reference 7

PM10‐FIL PM10‐FIL 19.73 Reference 7

PM2.5‐PRI PM2.5‐PRI 15.21 Reference 7

PM2.5‐FIL PM2.5‐FIL 15.21 Reference 7

Sulfur Dioxide SO2 1.66 Reference 7

VOC VOC 19 Reference 7

1,2,3,4,6,7,8‐heptachlorodibenzofuran 35822469 3.32E‐07 Reference 9

1,2,3,4,6,7,8‐heptachlorodibenzo‐p‐dioxin 67562394 5.08E‐08 Reference 9

1,2,3,4,7,8,9‐heptachlorodibenzofuran 55673897 6.12E‐09 Reference 9

1,2,3,4,7,8‐hexachlorodibenzofuran 70648269 3.34E‐08 Reference 9

1,2,3,4,7,8‐hexachlorodibenzo‐p‐dioxin 39227286 1.136E‐08 Reference 9

1,2,3,6,7,8‐hexachlorodibenzofuran 57117449 1.428E‐08 Reference 9

1,2,3,6,7,8‐hexachlorodibenzo‐p‐dioxin 57653857 2.14E‐08 Reference 9

1,2,3,7,8,9‐hexachlorodibenzofuran 72918219 2.22E‐09 Reference 9

1,2,3,7,8,9‐hexachlorodibenzo‐p‐dioxin 19408743 3.46E‐08 Reference 9

1,2,3,7,8‐pentachlorodibenzofuran 57117416 1.268E‐06 Reference 9

1,2,3,7,8‐pentachlorodibenzo‐p‐dioxin 40321764 7.66E‐09 Reference 9

2,3,4,6,7,8‐hexachlorodibenzofuran 60851345 1.962E‐08 Reference 9

2,3,4,7,8‐pentachlorodibenzofuran 57117314 2.02E‐08 Reference 9

2,3,7,8‐tetrachlorodibenzofuran 51207319 1.396E‐08 Reference 9

2,3,7,8‐tetrachlorodibenzo‐p‐dioxin 1746016 2.3E‐09 Reference 9

Cumene 98828 0.01325 Reference 8

Ethyl Benzene 100414 0.048 Reference 8

Octachlorodibenzofuran 39001020 2.06E‐08 Reference 9

Octachlorodibenzo‐p‐dioxin 3268879 1.328E‐06 Reference 9

Phenol 108952 0.115 Reference 8

Styrene 100425 0.1015 Reference 8

  

   
191 

8.22 Portable Fuel Containers, Residential and Commercial

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  The documentation

below was developed by EPA.  

8.22.1 Portable Fuel Containers (PFC) emission inventories

As part of the MSAT rule, emissions for portable fuel containers (PFC) would be processed in EMS‐HAP,

ASPEN, and subsequent HAPEM exposure modeling.  In order to create the emissions inventories for the

MSAT HAPs, two main steps were taken.  First, state level VOC PFC emissions were allocated to counties

and to several SCC codes.  Secondly, after allocation of the VOC emissions, HAP specific emissions were

developed.  This section describes the processes in both steps.

8.22.1.1 VOC allocation

VOC total PFC reference (uncontrolled) emissions were available for 1990, 2005, 2010, 2015, 2020, and

2030 by state.  In addition to the reference inventories, there were control emissions for 2010, 2015,

2020, and 2030.  In addition to the years listed, a 1999 reference inventory was needed.  The 1999

inventory would be created based on linear interpolation between the 1990 and 2005 inventories.   

For both the reference and control inventories, the state VOC emissions needed to be allocated to

counties and to SCC codes related to PFC emissions.  The following steps were used to allocate the VOC

emissions:

 For each year, the reference inventories were read into SAS®.  For 2010, 2015, 2020, and 2030,

the control inventories were read into SAS®

.

 The state level VOC emissions for each year and emissions scenario, reference or control, were

allocated to residential and commercial components for six categories:  1) vapor displacement

while refilling containers at the pump, 2) spillage while refilling at the pump, 3) spillage during

transport, 4) vapor displacement while refueling equipment, 5) spillage while refueling

equipment, and 6) permeation and evaporation.  Total state level PFC emissions were allocated
192 

to the categories by using national level residential and commercial emissions  for each of the

categories using the following equations:





 





  s Com

s Eresidential XXXX YY E

Re

Re , ,                    (9)





 





  s Com

Com Ecommercial XXXX YY E

Re , ,                (10)

where E was the emissions of the category being split, XXXX was year, YY was state, and Res and

Com were the emissions shown in the corresponding table below.

 After allocating the VOC emissions to the six categories, the commercial and residential

permeation and evaporation categories were split into commercial permeation, commercial

evaporation, residential permeation, and residential evaporation by

EAAA,XXXX ,YY , perm  EAAA,XXXX ,YY , perm&evap  0.3387              (11)

(1 0.3387) EAAA,XXXX ,YY ,evap  EAAA,XXXX ,YY , perm&evap               (12)

The fraction 0.3387 represents the fraction of combined permeation and evaporative emissions

attributable to permeation, based on data from the California Air Resources Board.

 Once the state VOC emissions were allocated to the residential and commercial components of

the categories, they were assigned SCC codes for later processing in EMS‐HAP.  These codes are

shown in the corresponding table below.

.

 After creating the SCC level state emissions for the years and emission scenarios, a 1999

reference inventory was created by interpolating from the 1990 to 2005 emissions.  The

interpolation was done for each state and SCC combination and the equation was:
193 































    

15

9 2005, , 1990, ,

1999, , 1990, ,

YY SCC YY SCC

YY SCC YY SCC

E E

E E            (13)

where E1999,YY,SCC, E1990,YYY,SCC, and E2005,YY,SCCwere the 1999, 1990, and 2005 emissions for state YY

and SCC shown in the corresponding table below.

 After creating the 1999 state VOC inventory, the state emissions were allocated to the counties

by using the ratio of county to state fuel consumption.  State emissions were multiplied by the

county specific ratio to yield a county specific VOC emissions number for each SCC.  This

equation is shown as Equation 14.  















  

YY

YYYYY

XXXX YYYYY AAA SCC XXXX YY AAA SCC Consumption

Consumption E , , , E , , ,            (14)

where EXXXX,YYYYY,AAA,SCCwere the emissions for year XXXX, county with FIPS code YYYYY, emission

scenario AAA (reference or control) and SCC shown in the corresponding table below,

EXXXX,YY,AAA,SCC were the state level emissions for year XXXX, state YY, emission scenario AAA, and

SCC in the corresponding table below, ConsumptionYYYY was the county fuel consumption and

ConsumptionYY was the state fuel consumption.

 As for the nonroad emissions, Broomfield County emissions were allocated to surrounding

counties.

Figure 9 shows the flow of steps for allocation of VOC emissions.
194 

Figure: Steps in allocation of state VOC PFC emissions to counties. 

PFC categories with national level residential and commercial emissions 

Category Residential

Emissions

Commercial

Emissions

Vapor displacement while refilling at the pump 4,328 8,341

Spillage displacement while refilling at the pump 382 735

Spillage during transport 13,519 18,442

Vapor displacement while refueling equipment 4,328 8,341

Spillage while refueling equipment 21,340 41,747

Permeation and evaporation 187,757 5,997

SCC codes of PFC categories 

SCC code Description

2501011011 Storage and Transport; Petroleum and Petroleum Product Storage; Residential Portable Gas Cans;

Permeation

2501011012 Storage and Transport; Petroleum and Petroleum Product Storage; Residential Portable Gas Cans;

Evaporation

2501011013 Storage and Transport; Petroleum and Petroleum Product Storage; Residential Portable Gas Cans;

Spillage During Transport

2501011014 Storage and Transport; Petroleum and Petroleum Product Storage; Residential Portable Gas Cans;

Refilling at the Pump ‐ Vapor Displacement

2501011015 Storage and Transport; Petroleum and Petroleum Product Storage; Residential Portable Gas Cans;

Refilling at the Pump ‐ Spillage

State VOC PFC emissions

Split into commercial and residential 

emissions and split permeation+evaporation 

emissions into permeation emissions and 

evaporation emissions and assign SCC 

codes to emissions

1

State VOC PFC residential and 

commercial emissions

County and state fuel consumption

Allocate PFC emissions to county by 

using the ratio of county to state fuel 

consumption

Allocated county VOC PFC 

emissions

3

2

Create 1999 VOC emissions from 

1990 and 2005.

Allocated 1999 county VOC PFC 

emissions by SCC

Allocated county VOC PFC 

emissions for other years
195 

2501011016 Storage and Transport; Petroleum and Petroleum Product Storage; Residential Portable Gas Cans;

Refueling Equipment ‐ Vapor Displacement

2501011017 Storage and Transport; Petroleum and Petroleum Product Storage; Residential Portable Gas Cans;

Refueling Equipment ‐ Spillage

2501012011 Storage and Transport; Petroleum and Petroleum Product Storage; Commercial Portable Gas Cans;

Permeation

2501012012 Storage and Transport; Petroleum and Petroleum Product Storage; Commercial Portable Gas Cans;

Evaporation

2501012013 Storage and Transport; Petroleum and Petroleum Product Storage; Commercial Portable Gas Cans;

Spillage During Transport

2501012014 Storage and Transport; Petroleum and Petroleum Product Storage; Commercial Portable Gas Cans;

Refilling at the Pump ‐ Vapor Displacement

2501012015 Storage and Transport; Petroleum and Petroleum Product Storage; Commercial Portable Gas Cans;

Refilling at the Pump ‐ Spillage

2501012016 Storage and Transport; Petroleum and Petroleum Product Storage; Commercial Portable Gas Cans;

Refueling Equipment ‐ Vapor Displacement

2501012017 Storage and Transport; Petroleum and Petroleum Product Storage; Commercial Portable Gas Cans;

Refueling Equipment ‐ Spillage

8.22.1.2 Creation of HAP PFC inventories

Once the state VOC PFC emissions were allocated to counties and SCC codes, PFC emissions for MSAT

HAPs could be developed.  Two methods were used to create the emissions, one for benzene, and the

second for other HAPs.  For benzene, the county level light duty gasoline vehicle (LDGV) refueling

emissions for benzene and VOC were used to create the PFC emissions.  At the county level, the

benzene refueling emissions were divided by the VOC refueling emissions, to yield a ratio that would be

multiplied with the PFC VOC emissions.  Benzene fuel control refueling emissions would be used for

refueling control emissions while no fuel controls would be used for 1999 and all the future year

reference inventories.  Several combinations of PFC and benzene fuel control refueling ratios would be

used.  These combinations were composed of the PFC emissions with no controls, and with controls, and

with benzene refueling emissions with and without controls.  The corresponding table below lists the

combinations and years for which they were used.

PFC and benzene fuel control inventory scenarios 

PFC emissions Benzene refueling emissions Years

No controls No controls 1999, 2010, 2015, 2020, 2030

Controls Controls 2015, 2020, 2030

No controls Controls 2015, 2020, 2030

Controls No controls 2010, 2015, 2020, 2030
196 

To calculate the benzene emissions for each PFC SCC in each county the following formulas were used.  

For all SCC emissions except for permeation (residential and commercial) the benzene emissions were

calculated as:

0.36

, , ,

, , ,

, , , , , , 















  

refuel XXXX YYYYY BBB

refuel XXXX YYYYY BBB

AAA XXXX YYYYY SCC AAA XXXX YYYYY SCC VOC

Benzene

Benzene VOC        (15)

For permeation emissions, the equation was

0.36 1.77

, , ,

, , ,

, , , , , ,   













  

refuel XXXX YYYYY BBB

refuel XXXX YYYYY BBB

AAA XXXX YYYYY SCC AAA XXXX YYYYY SCC VOC

Benzene

Benzene VOC       (16)

where XXXX was the year, YYYYY was the FIPS code of the county, and SCC was an SCC code shown in

the corresponding table.  AAA represents no controls or controls for PFC emissions, and BBB represents

whether refueling emissions are control or uncontrolled.  Note that 1999 and 2010 uncontrolled

benzene refueling emissions were calculated from 2015 as done in the onroad emissions processing.

In the equations the factor 0.36 represents an adjustment based on the nationwide percentage of

benzene in gasoline vapor from gasoline distribution with an RVP of 10 psi at 60 ̊F (Hester, 2006).  The

percentage is 0.27%, in contrast to 0.74% benzene in vehicle refueling emissions from highway vehicles.  

The ratio or factor of 0.36 was applied to the refueling emissions.  A second ratio was used for

permeation emissions since recent research suggests that the ratio of benzene from permeation is

higher than for evaporation, vapor displacement or spillage.  A recent study (Haskew et al., 2004)

suggests that the ratio of benzene from permeation to total VOC from permeation is about 1.7727 times

higher than the ratio associated with evaporation.   
197 

For all other HAPs, the PFC emissions were created by multiplying the PFC VOC emissions by the county

level ratio of HAP LDGV evaporative emissions by the VOC LDGV evaporative emissions for the county

or:















  

LDGV XXXX YYYYY

LDGV XXXX YYYYY

AAA XXXX YYYYY SCC AAA XXXX YYYYY SCC VOC

HAP

HAP VOC

, ,

, ,

, , , , , ,              (17)

where the subscripts are as denoted previously.  Using the LDGV evaporative emissions means only

HAPs in the onroad inventory with LDGV evaporative emissions would have PFC emissions.  For all other

HAPs, the same formula was used for all SCC codes.  Naphthalene was also multiplied by a factor of

0.0054 to reduce the emissions.  The corresponding tables below list the emissions summaries for the

no controls inventories the emissions summaries for the controlled inventories, respectively.  Steps used

in creating the HAP inventories are shown in the figure below.

Figure: Steps in creating HAP PFC emissions

Allocated county VOC PFC 

emissions

NMIM base onroad emissions LDGV evaporative 

emissions

HAPs VOC

Benzene to VOC refueling 

ratios by FIPS

Split LDGV emissions into VOC and 

non-benzene HAP evaporative 

emissions

Subset to VOC and non-benzene 

HAP LDGV evaporative emissions 

and sum by FIPS/CAS

Merge by FIPS and 

calculate ratio of HAP 

emissions to VOC 

emissions

HAP ratios

1 2

3

Merge by FIPS and 

multiply VOC PFC 

emissions by ratio and 

0.0054 if HAP is 

naphthalene

4

non-benzene HAP PFC emisssions

Merge by FIPS and 

multiply VOC PFC 

emissions by refuelign

ratio and other appropriate 

factors

5

Benzene PFC emisssions

Concatenate and sort by 

FIPS/SCC/CAS

HAP PFC emssions

6
198 

PFC emissions with and without controls for units without benzene fuel controls 

PFC type HAP

Year

1999 2010 2015 2020 2030

PFC: no

controls

PFC: no

controls

PFC:

with

controls

PFC: no

controls

PFC:

with

controls

PFC: no

controls

PFC:

with

controls

PFC: no

controls

PFC:

with

controls

Commercial

PFC:

Evaporation

Benzene 9.30x100 9.03x100 8.62x100 9.55x100 7.72x10‐1 1.02x101 8.24x10‐1 1.15x101 9.33x10‐1

All HAPs 4.61x102 3.92x102 3.71x102 4.13x102 3.93x101 4.37x102 4.14x101 4.92x102 4.65x101

Commercial

PFC:

Permeation

Benzene 8.43x100 8.18x100 7.82x100 8.66x100 7.00x10‐1 9.25x100 7.47x10‐1 1.05x101 8.46x10‐1

All HAPs 2.40x102 2.04x102 1.94x102 2.15x102 2.04x101 2.28x102 2.15x101 2.57x102 2.42x101

Commercial

PFC: Refilling

at the Pump:

Spillage

Benzene 1.61x100 1.80x100 1.80x100 1.96x100 1.96x100 2.12x100 2.12x100 2.45x100 2.45x100

All HAPs 8.42x101 8.73x101 8.73x101 9.44x101 9.44x101 1.01x102 1.01x102 1.16x102 1.16x102

Commercial

PFC: Refilling

at the Pump:

Vapor

Displacement

Benzene 1.83x101 2.05x101 2.05x101 2.23x101 2.23x101 2.41x101 2.41x101 2.79x101 2.79x101

All HAPs 9.57x102 9.90x102 9.90x102 1.07x103 1.07x103 1.14x103 1.14x103 1.31x103 1.31x103

Commercial

PFC:

Refueling

Equipment:

Spillage

Benzene 1.00x102 8.95x101 5.30x101 9.66x101 5.72x101 1.05x102 6.20x101 1.21x102 7.16x101

All HAPs 5.17x103 4.09x103 2.58x103 4.40x103 2.78x103 4.72x103 2.97x103 5.41x103 3.41x103

Commercial

PFC:

Refueling

Equipment:

Vapor

Displacement

Benzene 1.83x101 2.05x101 2.05x101 2.23x101 2.23x101 2.41x101 2.41x101 2.79x101 2.79x101

All HAPs 9.57x102 9.90x102 9.90x102 1.07x103 1.07x103 1.14x103 1.14x103 1.31x103 1.31x103

Commercial

PFC: Spillage

During

Transport

Benzene 4.10x101 4.44x101 4.35x101 4.81x101 4.29x101 5.20x101 4.64x101 5.99x101 5.34x101

All HAPs 2.12x103 2.11x103 2.07x103 2.28x103 2.06x103 2.43x103 2.20x103 2.78x103 2.52x103

Residential

PFC:

Evaporation

Benzene 2.91x102 2.83x102 2.70x102 2.99x102 2.42x101 3.19x102 2.58x101 3.62x102 2.92x101

All HAPs 1.44x104 1.23x104 1.16x104 1.29x104 1.23x103 1.37x104 1.30x103 1.54x104 1.46x103

Residential

PFC: Benzene 2.64x102 2.56x102 2.45x102 2.71x102 2.19x101 2.90x102 2.34x101 3.28x102 2.65x101
199 

PFC type HAP

Year

1999 2010 2015 2020 2030

PFC: no

controls

PFC: no

controls

PFC:

with

controls

PFC: no

controls

PFC:

with

controls

PFC: no

controls

PFC:

with

controls

PFC: no

controls

PFC:

with

controls

Permeation

All HAPs 7.50x103 6.39x103 6.06x103 6.75x103 6.40x102 7.14x103 6.75x102 8.04x103 7.58x102

Residential

PFC: Refilling

at the Pump:

Spillage

Benzene 8.37x10‐1 9.37x10‐1 9.37x10‐1 1.02x100 1.02x100 1.10x100 1.10x100 1.27x100 1.27x100

All HAPs 4.38x101 4.54x101 4.54x101 4.91x101 4.91x101 5.25x101 5.25x101 6.02x101 6.02x101

Residential

PFC: Refilling

at the Pump:

Vapor

Displacement

Benzene 9.51x100 1.07x101 1.07x101 1.16x101 1.16x101 1.25x101 1.25x101 1.45x101 1.45x101

All HAPs 4.97x102 5.14x102 5.14x102 5.55x102 5.55x102 5.94x102 5.94x102 6.82x102 6.82x102

Residential

PFC:

Refueling

Equipment:

Spillage

Benzene 5.11x101 4.57x101 2.71x101 4.94x101 2.93x101 5.35x101 3.17x101 6.18x101 3.66x101

All HAPs 2.64x103 2.09x103 1.32x103 2.25x103 1.42x103 2.41x103 1.52x103 2.77x103 1.74x103

Residential

PFC:

Refueling

Equipment:

Vapor

Displacement

Benzene 9.51x100 1.07x101 1.07x101 1.16x101 1.16x101 1.25x101 1.25x101 1.45x101 1.45x101

All HAPs 4.97x102 5.14x102 5.14x102 5.55x102 5.55x102 5.94x102 5.94x102 6.82x102 6.82x102

Residential

PFC: Spillage

During

Transport

Benzene 3.00x101 3.26x101 3.19x101 3.53x101 3.15x101 3.81x101 3.40x101 4.39x101 3.92x101

All HAPs 1.56x103 1.55x103 1.52x103 1.67x103 1.51x103 1.78x103 1.62x103 2.04x103 1.85x103
200 

PFC emissions with and without controls for units with benzene fuel controls 

PFC type HAP

Year

2015 2020 2030

PFC: no

controls

PFC: with

controls

PFC: no

controls

PFC: with

controls

PFC: no

controls

PFC: with

controls

Commercial PFC: Evaporation

Benzene 5.79x100 5.05x10‐1 6.19x100 5.39x10‐1 7.00x100 6.10x10‐1

All HAPs 4.10x102 3.91x101 4.33x102 4.12x101 4.88x102 4.62x101

Commercial PFC: Permeation

Benzene 5.25x100 4.58x10‐1 5.61x100 4.89x10‐1 6.35x100 5.53x10‐1

All HAPs 2.12x102 2.02x101 2.24x102 2.13x101 2.53x102 2.39x101

Commercial PFC: Refilling at the

Pump: Spillage

Benzene 1.25x100 1.25x100 1.35x100 1.35x100 1.56x100 1.56x100

All HAPs 9.37x101 9.37x101 1.00x102 1.00x102 1.15x102 1.15x102

Commercial PFC: Refilling at the

Pump: Vapor Displacement

Benzene 1.42x101 1.42x101 1.54x101 1.54x101 1.77x101 1.77x101

All HAPs 1.06x103 1.06x103 1.14x103 1.14x103 1.30x103 1.30x103

Commercial PFC: Refueling

Equipment: Spillage

Benzene 6.02x101 3.66x101 6.52x101 3.97x101 7.53x101 4.58x101

All HAPs 4.36x103 2.76x103 4.68x103 2.95x103 5.37x103 3.38x103

Commercial PFC: Refueling

Equipment: Vapor Displacement

Benzene 1.42x101 1.42x101 1.54x101 1.54x101 1.77x101 1.77x101

All HAPs 1.06x103 1.06x103 1.14x103 1.14x103 1.30x103 1.30x103

Commercial PFC: Spillage During

Transport

Benzene 3.05x101 2.74x101 3.30x101 2.96x101 3.80x101 3.41x101

All HAPs 2.26x103 2.05x103 2.41x103 2.19x103 2.76x103 2.50x103

Residential PFC: Evaporation

Benzene 1.81x102 1.58x101 1.94x102 1.69x101 2.19x102 1.91x101

All HAPs 1.28x104 1.22x103 1.36x104 1.29x103 1.53x104 1.45x103

Residential PFC: Permeation

Benzene 1.64x102 1.43x101 1.76x102 1.53x101 1.99x102 1.73x101

All HAPs 6.64x103 6.33x102 7.02x103 6.67x102 7.91x103 7.49x102

Residential PFC: Refilling at the

Pump: Spillage

Benzene 6.50x10‐1 6.50x10‐1 7.03x10‐1 7.03x10‐1 8.13x10‐1 8.13x10‐1

All HAPs 4.87x101 4.87x101 5.21x101 5.21x101 5.97x101 5.97x101

Residential PFC: Refilling at the

Pump: Vapor Displacement

Benzene 7.36x100 7.36x100 7.97x100 7.97x100 9.20x100 9.20x100

All HAPs 5.51x102 5.51x102 5.90x102 5.90x102 6.76x102 6.76x102

Residential PFC: Refueling

Equipment: Spillage

Benzene 3.08x101 1.87x101 3.33x101 2.03x101 3.85x101 2.34x101

All HAPs 2.23x103 1.41x103 2.39x103 1.51x103 2.74x103 1.73x103

Residential PFC: Refueling

Equipment: Vapor Displacement

Benzene 7.36x100 7.36x100 7.97x100 7.97x100 9.20x100 9.20x100

All HAPs 5.51x102 5.51x102 5.90x102 5.90x102 6.76x102 6.76x102

Residential PFC: Spillage During

Transport

Benzene 2.24x101 2.01x101 2.42x101 2.17x101 2.78x101 2.50x101

All HAPs 1.66x103 1.50x103 1.77x103 1.60x103 2.02x103 1.83x103

   
201 

8.23 Residential wood combustion

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  The documentation

below was developed by EPA.  Subsection d contains Missouri’s audit of EPA’s estimate.

a. Source Category Description 

Residential wood combustion includes the burning of wood and wax firelogs in home heating appliances. 

Specifically excluded from this category are residential leaf and brush burning from yard or land clearing activities 

(see 2610000100 and 2610000400). Appliances are broken down by type (fireplaces, woodstoves, furnaces, and 

outdoor hydronic heaters), and estimates are based on typical usage profile (main heat, supplemental, pleasure 

burning). 

The following source classification code (SCCs) are used for this category: 

List of nonpoint SCC codes 

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4 

2104008100 Stationary Source Fuel 

Combustion Residential Wood Fireplace: general 

2104008210 Stationary Source Fuel 

Combustion Residential Wood Woodstove: fireplace inserts; 

non-EPA certified 

2104008220 Stationary Source Fuel 

Combustion Residential Wood Woodstove: fireplace inserts; EPA certified; non-catalytic 

2104008230 Stationary Source Fuel 

Combustion Residential Wood Woodstove: fireplace inserts; 

EPA certified; catalytic 

2104008310 Stationary Source Fuel 

Combustion Residential Wood Woodstove: freestanding, 

non-EPA certified 

2104008320 Stationary Source Fuel 

Combustion Residential Wood Woodstove: freestanding, 

EPA certified, non-catalytic 

2104008330 Stationary Source Fuel 

Combustion Residential Wood Woodstove: freestanding, EPA certified, catalytic 

2104008400 Stationary Source Fuel 

Combustion Residential Wood Woodstove: pellet-fired, general 

2104008510 Stationary Source Fuel 

Combustion Residential Wood Furnace: Indoor, cordwoodfired, non-EPA certified 

2104008610 Stationary Source Fuel 

Combustion Residential Wood Hydronic heater: outdoor 

2104008700 Stationary Source Fuel 

Combustion Residential Wood Outdoor wood burning 

device, NEC 

2104009000 Stationary Source Fuel 

Combustion Residential Firelog Total: All Combustor Types 

b. Estimation Method 

EPA has created a tool for states to use to estimate residential wood combustion emissions called the Residential 

Wood Tool (RWC). It is a Microsoft Access database containing the tables and queries needed by states to update 

emission estimates. The estimation method is based on the following equation: 

(Number of appliances) * (Emission factor) * (Cords of wood burned per appliance) * (Wood Density) = Emissions 

c. Activity Data 

The activity data in the estimation equation includes the number of appliances, and cords of wood burned. 
202 

The number of appliances is estimated from US Census American Housing Survey Metropolitan Survey data 

estimating the number of occupied households in each county, the type of heating appliances, and their usage. 

These surveys were mainly done in the late 1990s to mid 2000s, with some state-specific survey data from the late 

2000s to update their appliance types. The “appliance profile” table in the tool summarizes the percentage of 

housing units with that appliance type that burn wood. Missouri’s appliance profiles are 2, 26, and 51. 

Burn profiles are used to estimate the amount of wood burned per appliance type. Much of this data are national 

averages by climate region, with a few geographic specific surveys as well. West Virginia, Wisconsin, Vermont, 

and Minnesota have done surveys to update their burn profiles. For national defaults, the source of data is cited as 

“Burn rates are an average of what was discovered in the literature regarding burn rates. For more detail, see file 

entitled "Burn rate data.xls". Report years are from 1992 to 2002”. This excel file is not made available with the 

RWC tool, and it has not been reviewed by Missouri. 

Emission factors are discussed in section c. 

Density of wood is estimated for each county based on the 2005 Timber Products Output (TPO) Fuel wood 

consumption. The reference within the tool states, “Density by county computed by taking volume of wood 

reported by species in the TPO, then multiplying by a species density factor provided by the US Forest service. Total 

mass for a county is then divided by total volume for a county to get average density for a county. 

Counties not reporting to the TPO were filled in using regional averages.” Missouri densities are between 1ton/cord 

and 1.5 ton/cord, with a statewide average of 1.39 ton/cord which is the highest in the country (tied with 

Connecticut). The University of Missouri Extension publication “Wood Fuel For Heating”1

 cites a dry, seasoned 

weight of hardwood of 3,600 lb/cord, which is 1.8 ton/cord. Their estimate would be for ideal wood types, so the 

more typical 1.39 ton/cord average is acceptable. 

c. Emission Factors 

Criteria air pollutant (CAP) emission factors used in the tool are listed by SCC below with a brief reference to their 

origin. Hazardous air pollutant (HAP) emissions are included in the RWC tool, but are not included here due to 

length. The tool also estimates the greenhouse gases (GHG) carbon dioxide and methane, but these emission factors 

are not included here. Final Missouri calculated emissions for CAP, HAP, and GHG are summarized in section e. 

SCC

Pollutant

Code SCC Level 4 pollutant

Emission

Factor numerator denominator data_source

2104008100 NH3 Fireplace: general Ammonia 1.8 lb ton MARAMA

2104008210 NH3

Woodstove: fireplace

inserts; non‐EPA certified Ammonia 1.7 lb ton MARAMA

2104008220 NH3

Woodstove: fireplace

inserts; EPA certified;

non‐catalytic Ammonia 0.9 lb ton MARAMA

2104008230 NH3

Woodstove: fireplace

inserts; EPA certified;

catalytic Ammonia 0.9 lb ton MARAMA

2104008310 NH3

Woodstove: freestanding,

non‐EPA certified Ammonia 1.7 lb ton MARAMA

2104008320 NH3

Woodstove: freestanding,

EPA certified, non‐

catalytic Ammonia 0.9 lb ton MARAMA

2104008330 NH3

Woodstove: freestanding,

EPA certified, catalytic Ammonia 0.9 lb ton MARAMA

2104008400 NH3

Woodstove: pellet‐fired,

general Ammonia 0.3 lb ton MARAMA

2104008510 NH3

Furnace: Indoor,

cordwood‐fired, non‐EPA

certified Ammonia 1.8 lb ton MARAMA
203 

SCC

Pollutant

Code SCC Level 4 pollutant

Emission

Factor numerator denominator data_source

2104008610 NH3 Hydronic heater: outdoor Ammonia 1.8 lb ton From Woodstoves.

2104008700 NH3

Outdoor wood burning

device, NEC Ammonia 1.8 lb ton MARAMA

2104008100 CO Fireplace: general Carbon Monoxide 149 lb ton MARAMA

2104008210 CO

Woodstove: fireplace

inserts; non‐EPA certified Carbon Monoxide 230.8 lb ton 2002 NEI

2104008220 CO

Woodstove: fireplace

inserts; EPA certified;

non‐catalytic Carbon Monoxide 140.8 lb ton 2002 NEI

2104008230 CO

Woodstove: fireplace

inserts; EPA certified;

catalytic Carbon Monoxide 104.4 lb ton 2002 NEI

2104008310 CO

Woodstove: freestanding,

non‐EPA certified Carbon Monoxide 230.8 lb ton 2002 NEI

2104008320 CO

Woodstove: freestanding,

EPA certified, non‐

catalytic Carbon Monoxide 140.8 lb ton 2002 NEI

2104008330 CO

Woodstove: freestanding,

EPA certified, catalytic Carbon Monoxide 104.4 lb ton 2002 NEI

2104008400 CO

Woodstove: pellet‐fired,

general Carbon Monoxide 15.9 lb ton MARAMA

2104008510 CO

Furnace: Indoor,

cordwood‐fired, non‐EPA

certified Carbon Monoxide 184 lb ton MARAMA

2104008610 CO Hydronic heater: outdoor Carbon Monoxide 360 lb ton From EPA report , 2012, Gullet et al.

2104008700 CO

Outdoor wood burning

device, NEC Carbon Monoxide 149 lb ton MARAMA

2104009000 CO

Residential Firelog Total:

All Combustor Types Carbon Monoxide 125.08 lb ton

Content and emission characteristics of Artificial Wax

Firelogs, Environment Canada

2104008100 NOX Fireplace: general Nitrogen Oxides 2.6 lb ton 2002 NEI

2104008210 NOX

Woodstove: fireplace

inserts; non‐EPA certified Nitrogen Oxides 2.8 lb ton 2002 NEI

2104008220 NOX

Woodstove: fireplace

inserts; EPA certified;

non‐catalytic Nitrogen Oxides 2.28 lb ton MARAMA

2104008230 NOX

Woodstove: fireplace

inserts; EPA certified;

catalytic Nitrogen Oxides 2 lb ton 2002 NEI

2104008310 NOX

Woodstove: freestanding,

non‐EPA certified Nitrogen Oxides 2.8 lb ton 2002 NEI

2104008320 NOX

Woodstove: freestanding,

EPA certified, non‐

catalytic Nitrogen Oxides 2.28 lb ton MARAMA

2104008330 NOX

Woodstove: freestanding,

EPA certified, catalytic Nitrogen Oxides 2 lb ton 2002 NEI

2104008400 NOX

Woodstove: pellet‐fired,

general Nitrogen Oxides 3.8 lb ton MARAMA

2104008510 NOX

Furnace: Indoor,

cordwood‐fired, non‐EPA

certified Nitrogen Oxides 1.8 lb ton MARAMA

2104008610 NOX Hydronic heater: outdoor Nitrogen Oxides 1.8 lb ton From Woodstoves.
204 

SCC

Pollutant

Code SCC Level 4 pollutant

Emission

Factor numerator denominator data_source

2104008700 NOX

Outdoor wood burning

device, NEC Nitrogen Oxides 2.6 lb ton 2002 NEI

2104009000 NOX

Residential Firelog Total:

All Combustor Types Nitrogen Oxides 7.684 lb ton

Content and emission characteristics of Artificial Wax

Firelogs, Environment Canada

2104008100 PM10‐PRI Fireplace: general Primary PM10 23.6 lb ton 2002 NEI

2104008210 PM10‐PRI

Woodstove: fireplace

inserts; non‐EPA certified Primary PM10 30.6 lb ton 2002 NEI

2104008220 PM10‐PRI

Woodstove: fireplace

inserts; EPA certified;

non‐catalytic Primary PM10 19.6 lb ton 2002 NEI

2104008230 PM10‐PRI

Woodstove: fireplace

inserts; EPA certified;

catalytic Primary PM10 20.4 lb ton 2002 NEI

2104008310 PM10‐PRI

Woodstove: freestanding,

non‐EPA certified Primary PM10 30.6 lb ton 2002 NEI

2104008320 PM10‐PRI

Woodstove: freestanding,

EPA certified, non‐

catalytic Primary PM10 19.6 lb ton 2002 NEI

2104008330 PM10‐PRI

Woodstove: freestanding,

EPA certified, catalytic Primary PM10 20.4 lb ton 2002 NEI

2104008400 PM10‐PRI

Woodstove: pellet‐fired,

general Primary PM10 3.06 lb ton MARAMA

2104008510 PM10‐PRI

Furnace: Indoor,

cordwood‐fired, non‐EPA

certified Primary PM10 27.6 lb ton MARAMA

2104008610 PM10‐PRI Hydronic heater: outdoor Primary PM10 64 lb ton From EPA report , 2012, Gullet et al.

2104008700 PM10‐PRI

Outdoor wood burning

device, NEC Primary PM10 23.6 lb ton 2002 NEI

2104009000 PM10‐PRI

Residential Firelog Total:

All Combustor Types Primary PM10 29.32 lb ton

Content and emission characteristics of Artificial Wax

Firelogs, Environment Canada

2104008100

PM2.5‐

PRI Fireplace: general Primary PM2.5 23.6 lb ton 2002 NEI

2104008210

PM2.5‐

PRI

Woodstove: fireplace

inserts; non‐EPA certified Primary PM2.5 30.6 lb ton 2002 NEI

2104008220

PM2.5‐

PRI

Woodstove: fireplace

inserts; EPA certified;

non‐catalytic Primary PM2.5 19.6 lb ton 2002 NEI

2104008230

PM2.5‐

PRI

Woodstove: fireplace

inserts; EPA certified;

catalytic Primary PM2.5 20.4 lb ton 2002 NEI

2104008310

PM2.5‐

PRI

Woodstove: freestanding,

non‐EPA certified Primary PM2.5 30.6 lb ton 2002 NEI

2104008320

PM2.5‐

PRI

Woodstove: freestanding,

EPA certified, non‐

catalytic Primary PM2.5 19.6 lb ton 2002 NEI

2104008330

PM2.5‐

PRI

Woodstove: freestanding,

EPA certified, catalytic Primary PM2.5 20.4 lb ton 2002 NEI

2104008400

PM2.5‐

PRI

Woodstove: pellet‐fired,

general Primary PM2.5 3.06 lb ton MARAMA

2104008510

PM2.5‐

PRI

Furnace: Indoor,

cordwood‐fired, non‐EPA

certified Primary PM2.5 27.6 lb ton MARAMA

2104008610

PM2.5‐

PRI Hydronic heater: outdoor Primary PM2.5 64 lb ton From EPA report , 2012, Gullet et al.
205 

SCC

Pollutant

Code SCC Level 4 pollutant

Emission

Factor numerator denominator data_source

2104008700

PM2.5‐

PRI

Outdoor wood burning

device, NEC Primary PM2.5 23.6 lb ton 2002 NEI

2104009000

PM2.5‐

PRI

Residential Firelog Total:

All Combustor Types Primary PM2.5 28.4 lb ton

Content and emission characteristics of Artificial Wax

Firelogs, Environment Canada

2104008100 SO2 Fireplace: general Sulfur Dioxide 0.4 lb ton 2002 NEI

2104008210 SO2

Woodstove: fireplace

inserts; non‐EPA certified Sulfur Dioxide 0.4 lb ton 2002 NEI

2104008220 SO2

Woodstove: fireplace

inserts; EPA certified;

non‐catalytic Sulfur Dioxide 0.4 lb ton 2002 NEI

2104008230 SO2

Woodstove: fireplace

inserts; EPA certified;

catalytic Sulfur Dioxide 0.4 lb ton 2002 NEI

2104008310 SO2

Woodstove: freestanding,

non‐EPA certified Sulfur Dioxide 0.4 lb ton 2002 NEI

2104008320 SO2

Woodstove: freestanding,

EPA certified, non‐

catalytic Sulfur Dioxide 0.4 lb ton 2002 NEI

2104008330 SO2

Woodstove: freestanding,

EPA certified, catalytic Sulfur Dioxide 0.4 lb ton 2002 NEI

2104008400 SO2

Woodstove: pellet‐fired,

general Sulfur Dioxide 0.32 lb ton MARAMA

2104008510 SO2

Furnace: Indoor,

cordwood‐fired, non‐EPA

certified Sulfur Dioxide 2.03 lb ton MARAMA

2104008610 SO2 Hydronic heater: outdoor Sulfur Dioxide 2.03 lb ton From Woodstoves.

2104008700 SO2

Outdoor wood burning

device, NEC Sulfur Dioxide 0.4 lb ton 2002 NEI

2104008100 VOC Fireplace: general

Volatile Organic

Compounds 18.9 lb ton MARAMA

2104008210 VOC

Woodstove: fireplace

inserts; non‐EPA certified

Volatile Organic

Compounds 53 lb ton 2002 NEI

2104008220 VOC

Woodstove: fireplace

inserts; EPA certified;

non‐catalytic

Volatile Organic

Compounds 12 lb ton 2002 NEI

2104008230 VOC

Woodstove: fireplace

inserts; EPA certified;

catalytic

Volatile Organic

Compounds 15 lb ton 2002 NEI

2104008310 VOC

Woodstove: freestanding,

non‐EPA certified

Volatile Organic

Compounds 53 lb ton 2002 NEI

2104008320 VOC

Woodstove: freestanding,

EPA certified, non‐

catalytic

Volatile Organic

Compounds 12 lb ton 2002 NEI

2104008330 VOC

Woodstove: freestanding,

EPA certified, catalytic

Volatile Organic

Compounds 15 lb ton 2002 NEI

2104008400 VOC

Woodstove: pellet‐fired,

general

Volatile Organic

Compounds 0.041 lb ton MARAMA

2104008510 VOC

Furnace: Indoor,

cordwood‐fired, non‐EPA

certified

Volatile Organic

Compounds 11.7 lb ton MARAMA

2104008610 VOC Hydronic heater: outdoor

Volatile Organic

Compounds 67.4 lb ton From EPA report , 2012, Gullet et al.

2104008700 VOC

Outdoor wood burning

device, NEC

Volatile Organic

Compounds 18.9 lb ton MARAMA
206 

SCC

Pollutant

Code SCC Level 4 pollutant

Emission

Factor numerator denominator data_source

2104009000 VOC

Residential Firelog Total:

All Combustor Types

Volatile Organic

Compounds 39.56 lb ton

Content and emission characteristics of Artificial Wax

Firelogs, Environment Canada

d. Quality Assurance 

The first review was of the number of occupied housing units file EPA used by default. The file contained one extra 

county for Missouri that is a duplicate – Ste. Genevieve county is listed twice with FIPS 29186 and 29193.The 

calculated emissions table has values for both counties, but they are not identical. The density by county table has 

two different densities for the duplicate county. Assuming the density is correct for the correct county identifier 

29186, the tool is run with the duplicate county 29193 removed from the county population and density by county 

tables. 

Missouri’s burn rate profile is listed as “3A”. That profile contains all SCCs, the burn type (main, secondary, 

pleasure burning), and the cords of wood burned per year. The list of all burn rates for profile 3A are below. 

SCC SCC Description Burn Type

Annual burn

rate Burn Unit

2104008100 Fireplace: general Main 2 Cords

2104008210 Woodstove: fireplace inserts; non‐EPA certified Main 3 Cords

2104008220 Woodstove: fireplace inserts; EPA certified; non‐catalytic Main 2.37 Cords

2104008230 Woodstove: fireplace inserts; EPA certified; catalytic Main 2.37 Cords

2104008310 Woodstove: freestanding, non‐EPA certified Main 3 Cords

2104008320 Woodstove: freestanding, EPA certified, non‐catalytic Main 2.37 Cords

2104008330 Woodstove: freestanding, EPA certified, catalytic Main 2.37 Cords

2104008400 Woodstove: pellet‐fired, general main 3 Ton

2104008510 Furnace: Indoor, cordwood‐fired, non‐EPA certified Main 4 Cords

2104008610 Hydronic heater: outdoor Main 5 Cords

2104009000 Residential Firelog Total: All Combustor Types Main 0 Ton

2104008100 Fireplace: general Secondary 0.8 Cords

2104008210 Woodstove: fireplace inserts; non‐EPA certified Secondary 1.5 Cords

2104008220 Woodstove: fireplace inserts; EPA certified; non‐catalytic Secondary 1.185 Cords

2104008230 Woodstove: fireplace inserts; EPA certified; catalytic Secondary 1.185 Cords

2104008310 Woodstove: freestanding, non‐EPA certified Secondary 1.5 Cords

2104008320 Woodstove: freestanding, EPA certified, non‐catalytic Secondary 1.185 Cords

2104008330 Woodstove: freestanding, EPA certified, catalytic Secondary 1.185 Cords
207 

SCC SCC Description Burn Type

Annual burn

rate Burn Unit

2104008400 Woodstove: pellet‐fired, general secondary 1 Ton

2104009000 Residential Firelog Total: All Combustor Types Secondary 0.32 Ton

2104008100 Fireplace: general Pleasure 0.3 Cords

2104008210 Woodstove: fireplace inserts; non‐EPA certified Pleasure 0.5 Cords

2104008220 Woodstove: fireplace inserts; EPA certified; non‐catalytic Pleasure 0.395 Cords

2104008230 Woodstove: fireplace inserts; EPA certified; catalytic Pleasure 0.395 Cords

2104008310 Woodstove: freestanding, non‐EPA certified Pleasure 0.5 Cords

2104008320 Woodstove: freestanding, EPA certified, non‐catalytic Pleasure 0.395 Cords

2104008330 Woodstove: freestanding, EPA certified, catalytic Pleasure 0.395 Cords

2104008400 Woodstove: pellet‐fired, general pleasure 0.3 Ton

2104008610 Hydronic heater: outdoor Pleasure 0 Cords

2104008700 Outdoor wood burning device, NEC Pleasure 0.213 Cords

2104009000 Residential Firelog Total: All Combustor Types Pleasure 0.14 Ton

For main heating sources, the estimate is that between 2 and 5 cords of wood per year could be used to heat a home. 

While this quantity of wood seems very low, and anecdotal evidence would show 5+ cords of wood per year for 

main heating for any appliance type, there is no vetted data source at this time to base a revised burn rate on. Future 

improvements to the estimate of emissions will include a Missouri-specific residential wood survey to update the 

burn rates, appliance population, and wood density. 

The emission factor table was examined to look for outlier or unreasonable factors. The factor that stands out for 

closer examination is the SO2 emission factor for indoor furnaces and outdoor wood boilers (hydronic heaters). The 

factor for these two appliance types is 2.03 lb/ton, while all other appliance types except pellet stoves have a factor 

of 0.4 lb/ton. Since SO2 is a product of the fuel being burned, the factor should be the same across appliance types 

when using the same fuel type. The data source cited for the 2.03 lb/ton factor was unable to be located based on the 

non-specific reference of “MARAMA”, so the factor is changed to match all other wood burning appliances. The 

list of SO2 emission factors (in lbs/ton) are provided below. 

SCC

Pollutant

Code SCC Level 4

Emission

Factor Data Source

2104008100 SO2 Fireplace: general 0.4 2002 NEI

2104008210 SO2 Woodstove: fireplace inserts; non‐EPA certified 0.4 2002 NEI

2104008220 SO2 Woodstove: fireplace inserts; EPA certified; non‐catalytic 0.4 2002 NEI

2104008230 SO2 Woodstove: fireplace inserts; EPA certified; catalytic 0.4 2002 NEI

2104008310 SO2 Woodstove: freestanding, non‐EPA certified 0.4 2002 NEI

2104008320 SO2 Woodstove: freestanding, EPA certified, non‐catalytic 0.4 2002 NEI
208 

2104008330 SO2 Woodstove: freestanding, EPA certified, catalytic 0.4 2002 NEI

2104008400 SO2 Woodstove: pellet‐fired, general 0.32 MARAMA

2104008510 SO2 Furnace: Indoor, cordwood‐fired, non‐EPA certified 2.03 MARAMA

2104008610 SO2 Hydronic heater: outdoor 2.03 From Woodstoves.

e. Emissions 

Criteria pollutant emissions are listed by SCC below. 

SCC SCC Description CO NH3 NOX PM10‐PRI PM2.5‐PRI SO2 VOC

2104008100

Fireplace:

general

  

27,656.78

  

334.11

  

482.60

  

4,380.54

   

4,380.54  

   

74.25        3,508.14

2104008210

Woodstove:

fireplace inserts;

non‐EPA

certified

  

20,347.31

  

149.87

  

246.85

  

2,697.69

   

2,697.69  

   

35.26        4,672.48

2104008220

Woodstove:

fireplace inserts;

EPA certified;

non‐catalytic

  

3,958.89

  

25.31

  

64.11

  

551.10

   

551.10  

   

11.25           337.41

2104008230

Woodstove:

fireplace inserts;

EPA certified;

catalytic

  

978.55

  

8.44

  

18.75

  

191.21

   

191.21  

   

3.75           140.60

2104008310

Woodstove:

freestanding,

non‐EPA

certified

  

18,632.92

  

137.24

  

226.05

  

2,470.40

   

2,470.40  

   

32.29        4,278.79

2104008320

Woodstove:

freestanding,

EPA certified,

non‐catalytic

  

3,627.03

  

23.18

  

58.73

  

504.90

   

504.90  

   

10.30           309.12

2104008330

Woodstove:

freestanding,

EPA certified,

catalytic

  

896.23

  

7.73

  

17.17

  

175.13

   

175.13  

   

3.43           128.77

2104008400

Woodstove:

pellet‐fired,

general

  

222.16

  

4.19

  

53.10

  

42.76

   

42.76  

   

4.47                0.57

2104008510

Furnace: Indoor,

cordwood‐fired,

non‐EPA

certified

  

2,445.49

  

23.98

  

24.53

  

367.62

   

367.62  

   

27.04           157.17

2104008610

Hydronic heater:

outdoor

  

6,061.87

  

30.31

  

31.01

  

1,077.67

   

1,077.67  

   

34.18        1,134.92

2104008700

Outdoor wood

burning device,

NEC

  

88.31

  

1.07

  

1.54

  

13.99

   

13.99  

   

0.24              11.20

2104009000

Total: All

Combustor

  

595.64 

  

36.59

  

139.62

   

135.24           188.39
209 

Types

  

Statewide Total

         

85,511.19  

           

745.42  

      

1,261.01  

  

12,612.61

   

12,608.23  

          

236.47      14,867.55  

The statewide GHG and HAP total for all residential wood SCCs is provided below for reference. The table is not 

broken into the separate SCCs due to length. Emissions are reported in tons per year. 

Pollutant

Missouri Total

(tons per year)

Carbon Dioxide            48,949.62  

Methane            16,281.10  

Formaldehyde                  740.97  

Benzene                  622.34  

Acetaldehyde                  368.75  

Phenol                  178.90  

Toluene                  132.63  

Cresols (Includes o, m, & p)/Cresylic Acids                  132.10  

1,3‐Butadiene                  108.92  

Naphthalene                    95.28  

Acrolein                    42.48  

o‐Xylene                    37.46  

Acenaphthylene                    23.65  

Phenanthrene                    11.27  

Fluorene                      2.98  

Pyrene                      2.80  

Fluoranthene                      2.40  

Benz[a]Anthracene                      2.32  

Anthracene                      1.75  

Chrysene                      1.58  

Benzo[e]Pyrene                      1.34  

Acenaphthene                      1.33  

Benzo[a]Pyrene                    0.954  

Benzo[g,h,i,]Perylene                    0.876  

Benzo[b]Fluoranthene                    0.759  

Benzo(g,h,i)Fluoranthene                    0.664  

Biphenyl                    0.479  

Indeno[1,2,3‐c,d]Pyrene                    0.475  

Nitrous Oxide                    0.317  

Benzo[k]Fluoranthene                    0.231  
210 

Pollutant

Missouri Total

(tons per year)

Dibenzo[a,h]Anthracene                    0.109  

7,12‐Dimethylbenz[a]Anthracene                    0.087  

Perylene                    0.044  

Manganese                    0.036  

Cadmium                    0.005  

Nickel                    0.003  

Mercury                    0.002  

Dioxins/Furans as 2,3,7,8‐TCDD TEQs ‐ WHO2005 1.09E‐06

2,3,7,8‐Tetrachlorodibenzofuran 5.34E‐07

Octachlorodibenzo‐p‐Dioxin 2.84E‐07

2,3,4,7,8‐Pentachlorodibenzofuran 2.75E‐07

1,2,3,7,8‐Pentachlorodibenzofuran 1.95E‐07

1,2,3,4,7,8‐Hexachlorodibenzofuran 1.52E‐07

1,2,3,4,6,7,8‐Heptachlorodibenzo‐p‐Dioxin 1.35E‐07

1,2,3,4,6,7,8‐Heptachlorodibenzofuran 1.28E‐07

1,2,3,7,8‐Pentachlorodibenzo‐p‐Dioxin 1.10E‐07

1,2,3,4,7,8‐Hexachlorodibenzo‐p‐Dioxin 1.07E‐07

1,2,3,6,7,8‐Hexachlorodibenzo‐p‐Dioxin 1.07E‐07

1,2,3,7,8,9‐Hexachlorodibenzo‐p‐Dioxin 1.07E‐07

1,2,3,4,7,8,9‐Heptachlorodibenzofuran 9.99E‐08

2,3,7,8‐Tetrachlorodibenzo‐p‐Dioxin 9.73E‐08

1,2,3,6,7,8‐Hexachlorodibenzofuran 9.39E‐08

1,2,3,7,8,9‐Hexachlorodibenzofuran 8.47E‐08

Octachlorodibenzofuran 7.11E‐08

2,3,4,6,7,8‐Hexachlorodibenzofuran 7.04E‐08

e. References 

1. University of Missouri Extension “Wood Fuel for Heating” 

http://extension.missouri.edu/explorepdf/agguides/forestry/g05450.pdf 

   
211 

8.24 Solvent:  Architectural Coatings

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.

8.25 Solvent:  Auto Refinishing/Auto Aftermarket

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.

8.26 Solvent:  Consumer and Commercial Household Products

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.

8.27 Solvent:  Consumer and Commercial Personal Care, Cosmetic, and Toiletries

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.

8.28 Solvent:  Consumer and Commercial Miscellaneous Products

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.

8.29 Solvent:  Consumer and Commercial Adhesives and Sealants

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.

8.30 Solvent:  Consumer and Commercial Auto Aftermarket

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.
212 

8.31 Solvent:  Consumer and Commercial Coatings and Related Products

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.

8.32 Solvent:  Consumer and Commercial FIFRA Regulated Products

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.

8.33 Solvent:  Degreasing

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.

8.34 Solvent:  Dry Cleaning

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.

8.35 Solvent:  Graphic Arts

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.

8.36 Solvent:  Industrial Maintenance Coatings

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.

8.37 Solvent:  Other Special Purpose Coatings

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.
213 

8.38 Surface Coating:  Aircraft

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.

8.39 Surface Coating:  Electronic and other Electric Coatings

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.

8.40 Surface Coating:  Factory Finished Wood

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.

   
214 

8.41 Surface Coating:  Large Appliances

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.

Missouri DNR compared the NAICS 3352* (Household Appliances) against the list of ~500 point sources

to be submitted to the EIS.  No point source facilities were identified using the NAICS code.   

County Business Patterns only identifies three facilities in three counties in Missouri with under 10

employees each.  EPA’s estimation method assigns 3 employees to each county and uses the VOC and

HAP emission factors to estimate emissions.  

County Number of Employees

Assigned

057‐ Dade 3

095‐ Jackson 3

099‐ Jefferson 3

Searching the wider universe of facilities who have ever submitted an EIQ to Missouri (regardless of PTE

or point facility status) reveals no air permitted sources.  Three facilities have been added to the facility

list with NAICS of 3352*, but none of them have permits or are required to complete an emissions

report.  The largest employer, Tacony Manufacturing, assembles vacuums, but does not produce

emissions.  This larger search provides no indication that EPA’s estimation method is incorrect.

   
215 

8.42 Surface Coating:  Machinery and Equipment

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.

   
216 

8.43 Surface Coating:  Marine

The Missouri DNR accepted EPA’s estimates of emissions for this source category but subtracted point

source emissions from EPA’s totals.   No documentation was provided by EPA.

The NAICS  3366* and 488390* were compared against the list of ~500 point sources to be submitted to

the EIS.  Three point source facilities were identified using these NAICS codes.  The following point

sources with their number of employees are listed below:

County Plant ID Plant Name NAICS Product Description

Number of

Employees

HENRY            0031 TRACKER MARINE                          336612 FIBERGLASS BOATS         195

LACLEDE          0006

BRUNSWICK FRESHWATER

GROUP                336612 BOATS, ALUMINUM        322

LACLEDE          0046 TRACKER MARINE                          336612 ALUMINUM BOATS         497

LACLEDE          0038 G3 BOATS                                  336612 BOAT MFG                        230

PEMISCOT        0030

TRINITY MARINE PRODUCTS

INC               336611 BARGES                             630

The following number of employees was subtracted from those counties:

County FIPS

County

Name

EPA Estimate of

all Point and

Nonpoint

Employees

Point Source

Employees

Subtracted

Employees

Remaining in

Nonpoint Estimate

Missouri

Adjusted Final

Number of

Nonpoint

Employees

083 HENRY            278 195 83 0

105 LACLEDE          1,081 1,049 32 0

155 PEMISCOT       556 630 0 0

Where there were remaining employees in the county, the County Business Patterns data was reviewed

to see if the assumptions EPA used to “adjust” the number of withheld employees are reasonable, or if

they inflate the number of employees higher than what the facility reports to the state.  

For Henry County, 2010 CBP reports only one employer in the county with between 250 and 499

employees.  The specific number of employees reported to Missouri for the single point source facility is

195 in 2011.  It is reasonable to assume that EPA’s method of assigning a specific value to the number of

employees is inflating the employment tally in this county, and there should be no remaining nonpoint

employees in Henry County, so the remaining nonpoint employees are removed.
217 

For Laclede County, the 2010 CBP releases an actual number of employees of 1,081, with an

undetermined number of facilities.  Missouri point sources account for 1,049 of these employees based

on their 2011 report.  It is reasonable to assume that the difference in years could account for the fewer

than 5% discrepancy in the number of employees.  The remaining 32 nonpoint employees are zeroed

out for this county and category.

After subtraction, the remaining counties where county business patterns identifies large numbers of

employees that are not in the point source category are examined.

FIPS

County

Name

EPA

Estimated

Number of

Employees

Missouri

Estimated

Number of

Employees

167 Polk 278 0

510 St. Louis City 149 149

In Polk County, there was a point source facility named “Tracker Marine – Bolivar Plant”.  The facility

reported over 200 employees before they shut down in July of 2009 per an air inspection.  This facility

should not have appeared in the 2010 County Business Patterns, where the report states that only one

employer with between 250 and 499 employees existed.  As there are no other employers in this NAICS

in the county, EPA’s estimated number of employees (the adjusted county employee number), the

county is zeroed out.

In St. Louis City, there are no other facilities Missouri is aware of in the NAICS of 3366* and 488390*.  

Missouri permits sources above certain de minimis thresholds as described in 10 CSR 10‐6.060 and 10

CSR 10‐6.065, therefore it is possible for facilities with smaller PTE to be unpermitted and unknown by

the state.  County business patterns state that there are three employer with NAICS 336611 (Ship

building and repair) with between 100 and 249 employees total.  CBP also cites that 3 employers in

NAICS 488390 (Other support activities for water transportation) have total employment of 20 to 99

employees.  The EPA method to adjust estimated ranges of employees to a specific number returns 149

employees in St. Louis City for marine surface coating.  Since Missouri has no more specific information

on permitted facilities engaged in marine operations in the county, Missouri will accept EPA’s estimate

of 149 employees engaged in these activities in the county.

One county with a smaller remaining number of nonpoint employees is Camden County, 29029.  EPA

estimates 44 nonpoint employees in the county, and with the given emission factors, estimates 5 tons of

VOC in this county.  Missouri has a source in NAICS 3366*with a Basic operating permit in the county,

Charger Inc.  They provide periodic full EIQs, and have certified that for 2011, their emissions are within

the range of 5 to 15 tons VOC.  In the case of Camden County, EPA’s nonpoint estimate and Missouri‐

specific data are reasonably close.

This larger search provides no indication that EPA’s estimation method is incorrect, so point source

subtraction is the only adjustment needed.
218 

8.44 Surface Coating – Metal Can Coating

EPA provided an Access database with national metal can coating nonpoint emissions, and the Missouri

DNR reviewed the file before making necessary adjustments.

EPA estimates emissions for VOC and three HAPs.   

Pollutant Code

Pollutant

Name Emission

Factor

Emission

Factor

Numerator

Emission Factor

Denominator

VOC Volatile Organic

Compounds

3035 LB EACH

67561 Methanol 406.69 LB EACH

108883 Toluene 813.38 LB EACH

107211 Ethylene Glycol 886.22 LB EACH

EPA’s estimation method relies on a count of the number of employees in each county in the industry.  

The US Census County Business Patterns gives this information by NAICS, but withholds certain

employment numbers when a county only has one employer to avoid releasing confidential data.  EPA

has a methodology to take withheld county employment, given as a range of employees, to estimate a

specific number of employees.  Many other surface coating categories have an associated excel

spreadsheet from EPA that demonstrates how the allocation of withheld employees is completed, but

this work is not shown for this category.  Missouri took the Access database and extracted Missouri’s

employment estimate by county.

State

And

County

FIPS

Code

County Name SCC Number of

Employees

29021 Buchanan 2401040000 135.77

29031 Cape

Girardeau 2401040000 7.75

29037 Cass 2401040000 7.75

29077 Greene 2401040000 46.55

29095 Jackson 2401040000 135.77

29099 Jefferson 2401040000 135.77

29107 Lafayette 2401040000 46.55

29109 Lawrence 2401040000 46.55

29155 Pemiscot 2401040000 7.75

29157 Perry 2401040000 46.55

29159 Pettis 2401040000 581.88

29189 St. Louis 2401040000 46.55
219 

29205 Shelby 2401040000 7.75

The point sources being submitted to EPA were checked for NAICS 33243*.   

County

FIPS

County

Name

Plant

ID Plant Name NAICS

NAICS

Description

Product

Description

Number of

Employees

29021 BUCHANAN         0064

SILGAN CONTAINERS

CORP                    332431

Metal Can

Manufacturing CANS MTL                    205

29077 GREENE           0008

BRISTOL

MANUFACTURING

CORP                332439

Other Metal

Container

Manufacturing

STEEL DRUM

CLEANING &

REFURBISHMENT      120

29099 JEFFERSON        0044

METAL CONTAINER

CORPORATION               332431

Metal Can

Manufacturing CANS BEER                   174

29159 PETTIS           0012

WATERLOO

INDUSTRIES INC                332439

Other Metal

Container

Manufacturing METAL BOXES             650

29189 ST. LOUIS CO.    0226 GREIF‐FENTON                  332439

Other Metal

Container

Manufacturing

55 GALLON

BARRELS                       43

Removing the reported number of employees for point sources from Buchanan, Greene, Jefferson,

Pettis and St. Louis Counties leaves the following numbers of employees:

State And County

FIPS Code

County

Name SCC Number ofEmployees

29021 Buchanan 2401040000 0

29031 Cape

Girardeau 2401040000 7.75851393188855

29037 Cass 2401040000 7.75851393188855

29077 Greene 2401040000 0

29095 Jackson 2401040000 135.77399380805

29099 Jefferson 2401040000 0

29107 Lafayette 2401040000 46.5510835913313

29109 Lawrence 2401040000 46.5510835913313

29155 Pemiscot 2401040000 7.75851393188855

29157 Perry 2401040000 46.5510835913313

29159 Pettis 2401040000 0

29189 St. Louis 2401040000 0

29205 Shelby 2401040000 7.75851393188855

The county with the largest number of nonpoint employees is Jackson (29095) at 135 employees.  

Review of the US Census website (since EPA didn’t provide how the final number was estimated) shows

that there is one employer with between 100 and 249 employees in the county.  Missouri has a previous
220 

point source facility named Ball Metal Beverage Container Company in Jackson County (EIS Facility ID

7356411), with 147 employees, but the facility closed in September of 2009.  The CBP should not

continue to show this county with this number of employees, so the county nonpoint number of

employees is being zeroed out.

Lawrence County shows 46 nonpoint employees, and CBP shows one employer with 20 to 99

employees.  Missouri has a nonpoint facility named Silgan Container Company in Lawrence County,

which reported 70 employees in 2011.  They were a point source in 2008 (EIS Facility ID 7281811), but

have since amended their permits and as of 2009, their potential emissions do not meet the AERR

requirements to be a point source.  As this facility is now included in the nonpoint category, its Missouri‐

submitted emissions are compared to EPA’s nonpoint estimate for the county.  EPA estimates at 3,035

pounds VOC per employee, the single Lawrence County facility emits over 70 tons of VOC per year.  

Silgan has reported to Missouri emissions of 4.23 tons VOC.  Missouri will be replacing EPA’s estimate

with higher quality, bottom‐up directly reported emission data from the facility.  For VOC, emissions will

be the facility total as reported.  The facility was below the reporting threshold for HAP data, and as

such, no HAP data will be submitted for this 4 ton VOC source.

Perry County shows 46 nonpoint employees, and CBP shows one employer with 20 to 99 employees.

Missouri has a nonpoint facility named H and G Marine Service in Perry County (EIS Facility ID 7285511)

which reports 12 employees as of 2010.  It currently has the NAICS of 332313, Plate Work

Manufacturing, and has permit limits that keep it under the AERR definition of point source, but until

2010 it’s NAICS was 332439, Other Metal Container Manufacturing, and its emissions were large enough

to be submitted as a point source under AERR’s Type B threshold.  As the facility is now included in the

nonpoint category, its Missouri‐submitted emissions are compared to EPA’s nonpoint estimate for the

county.  EPA estimates, at 3,035 pounds VOC per employee, the single Perry County facility emits over

70 tons of VOC per year.  H and G Marine have reported to Missouri for 2010 that their VOC emissions

are 20.9 tons, and that their 2011 emissions are 5 tons plus or minus that value.  To provide higher‐

quality, bottom‐up inventory data for Perry County, Missouri will replace EPA’s estimate with facility‐

reported emissions for both VOC and HAPs.

Cape Girardeau County has 7 nonpoint employees based on the EPA and CBP estimation method.  CBP

shows one facility with between 0 and 19 employees in the county, and that facility corresponds to the

point source facility named Mid‐South Products, Inc with 13 employees in 2011 (the NAICS is listed as

332322 according to Missouri).  Since all emissions for this county will appear in the point source

inventory, the nonpoint number of employees will be zeroed out.

Lafayette, Cass, Pemiscot, and Shelby counties were investigated to see if a very similar NAICS code

point or nonpoint facility could be determined through Missouri records, but no such facilities were

identified.  These counties will have emission estimates identical to EPA’s estimates.

The final emission estimates being reported to EPA for nonpoint surface coating of metal cans are:
221 

County

FIPS County Name Number ofEmployees

Pollutant

Code

Total

Emissions

Emissions Unit

of Measure

29021 Buchanan 0 VOC 0 LB

29021 Buchanan 0 107211 0 LB

29021 Buchanan 0 67561 0 LB

29021 Buchanan 0 108883 0 LB

29031 Cape Girardeau 0 VOC 0 LB

29031 Cape Girardeau 0 107211 0 LB

29031 Cape Girardeau 0 67561 0 LB

29031 Cape Girardeau 0 108883 0 LB

29037 Cass 7.75 VOC 23547.08978 LB

29037 Cass 7.75 107211 6875.750217 LB

29037 Cass 7.75 67561 3155.310031 LB

29037 Cass 7.75 108883 6310.620062 LB

29077 Greene 0 VOC 0 LB

29077 Greene 0 107211 0 LB

29077 Greene 0 67561 0 LB

29077 Greene 0 108883 0 LB

29095 Jackson 0 VOC 0 LB

29095 Jackson 0 107211 0 LB

29095 Jackson 0 67561 0 LB

29095 Jackson 0 108883 0 LB

29099 Jefferson 0 VOC 0 LB

29099 Jefferson 0 107211 0 LB

29099 Jefferson 0 67561 0 LB

29099 Jefferson 0 108883 0 LB

29107 Lafayette 46.55 VOC 141282.5387 LB

29107 Lafayette 46.55 107211 41254.5013 LB

29107 Lafayette 46.55 67561 18931.86019 LB

29107 Lafayette 46.55 108883 37863.72037 LB

29109 Lawrence 0 VOC 4.23 TON

29155 Pemiscot 7.75 VOC 23547.08978 LB

29155 Pemiscot 7.75 107211 6875.750217 LB

29155 Pemiscot 7.75 67561 3155.310031 LB

29155 Pemiscot 7.75 108883 6310.620062 LB

29157 Perry 0 VOC 20.09 TON

29157 Perry 0 100414 569.11 LB

29157 Perry 0 1330207 4344.89 LB

29157 Perry 0 108101 15467.25 LB

29157 Perry 0 108883 9766.5 LB
222 

County

FIPS County Name Number ofEmployees

Pollutant

Code

Total

Emissions

Emissions Unit

of Measure

29159 Pettis 0 VOC 0 LB

29159 Pettis 0 107211 0 LB

29159 Pettis 0 67561 0 LB

29159 Pettis 0 108883 0 LB

29189 St. Louis 0 VOC 0 LB

29189 St. Louis 0 107211 0 LB

29189 St. Louis 0 67561 0 LB

29189 St. Louis 0 108883 0 LB

29205 Shelby 7.75 VOC 23547.08978 LB

29205 Shelby 7.75 107211 6875.750217 LB

29205 Shelby 7.75 67561 3155.310031 LB

29205 Shelby 7.75 108883 6310.620062 LB

   
223 

8.45 Surface Coating:  Metal Furniture

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No

documentation was provided by EPA.

   
224 

8.46 Surface Coating:  Miscellaneous Manufacturing

The Missouri DNR developed the following estimate of emissions and documentation for this source

category.

1. Category Description:

The category of miscellaneous manufacturing is covered by the SCC 2401090000.

SCC

SCC Level

One

SCC Level

Two SCC Level Three SCC Level Four

2401090000

Solvent

Utilization

Surface

Coating Miscellaneous Manufacturing Total: All Solvent Types

2. Estimation Method:

EPA’s estimate is based on the US Census County Business Patterns database for 2010 that reports the

number of employees by NAICS in each county.  Some county employment data is withheld where

release could be considered confidential data (especially where there is only one or two employers in

the county).  EPA uses an estimation method to take a range of employees and assign a specific number

to each county with withheld data.

For Miscellaneous Manufacturing, EPA assigns employees in NAICS 339** and 3369* to this category.  

For Missouri, the adjusted employment in these NAICS is 9,108 employees.

3. Emission Factors

EPA proposes emission factors based on the number of employees in each county (pounds of pollutant

released per employee per year).  The only CAP with an emission factor is VOC, and nine HAPs are

estimated.  There is no documentation provided on the source of data for these emission factors.

CAS# Chemical Name

Emission

Factor

95476 o‐Xylene 0.531418

100414 Ethyl Benzene 0.583173

108383 m‐Xylene 1.20886

108101 Methyl Isobutyl Ketone 3.661701

106423 p‐Xylene 0.538812

540885 Tert‐butyl Acetate 2.308664

108883 Toluene 11.55441

110543 Hexane 21.84266

121448 Triethylamine 0.043438

VOC VOC 92.42051
225 

4. Controls

No controls are assumed for this category.

5. Emissions

EPA provides an estimate of statewide emissions for this SCC, and leaves it to the state to subtract out

point source employees that overlap this NAICS.  Missouri’s point sources are listed below:

Count

y FIPS

County

Name

Plant

ID

Plant

Name NAICS

NAICS

Description

Product

Description

Number of

Employees

165 PLATTE        2415

HARLEY

DAVIDSON

MOTOR

COMPANY     336991

Motorcycle,

Bicycle, and

Parts

Manufacturing MOTORCYCLES     900

510

ST. LOUIS

CITY   1460

ALLIED

HEALTH

CARE

PRODUCTS    339112

Surgical and

Medical

Instrument

Manufacturing

MEDICAL GAS

SYSTEMS/

MEDICAL

PRODUCTS      520

The remaining categories with high assumed nonpoint employment are:

County

FIPS

County

name

Number of

Employees

Remaining

189 St. Louis 2611.46

095 Jackson 956.4601

183

St.

Charles 588.7716

009 Barry 290.6557

187

St.

Francois 290.6557

077 Greene 282

099 Jefferson 258

047 Clay 221

071 Franklin 170

021 Buchanan 164

097 Jasper 135.6393

181 Ripley 135.6393
226 

St. Louis County has the highest number of nonpoint employees after considering point source

subtraction.  CBP states that over 2,600 employees work in NAICS 339** at over 120 employers.  There

are several facilities in Missouri’s database of permitted emission sources with this NAICS in St. Louis

County, but it is impossible to account for the sheer number of facilities and so any meaningful

accounting association with nonpoint direct facility‐reported emissions is not possible.  The same can be

said of all other counties that were examined – a large number of miscellaneous manufacturers make up

the total, and individual facility contribution cannot be removed or itemized.

Total statewide emissions after point source subtraction for the miscellaneous manufacturing category

are listed below.

Pollutant

Pollutant

Code

Emissions (tons

per year)

Volatile

Organic

Compounds   VOC 420.9

Hexane 110543 99.48

Toluene 108883 52.62

Methyl

Isobutyl

Ketone 108101 16.68

Tert‐butyl

Acetate 540885 10.51

m‐Xylene 108383 5.51

Ethyl Benzene 100414 2.66

p‐Xylene 106423 2.45

o‐Xylene 95476 2.42

Triethylamine 121448 0.2

   
227 

8.47 Surface Coating:  Motor Vehicle

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.

   
228 

8.48 Surface Coating:  Paper, foil, and film

The Missouri DNR developed the following estimate of emissions and documentation for this source

category.

Description:

Paper, foil and film surface coating emissions are covered by the following nonpoint SCC:

SCC SCC Level One

SCC Level

Two

SCC Level

Three SCC Level Four

2401030000 Solvent Utilization

Surface

Coating Paper: SIC 26 Total: All Solvent Types

Activity:

EPA estimates activity by the number of reported employees in the US Census County Business Patterns

database for NAICS 322221*, 322222*, 322223*, 322225* and 322226*.  The employment table for

Missouri counties is below:

FIPS State

and

County

Code fipstate fipscty naics empflag emp Ranges Midpoint

29047 29 047 322221 B 0 20‐99 60

29047 29 047 322222 B 0 20‐99 60

29077 29 077 322222 A 0 0‐19 10

29077 29 077 322223 A 0 0‐19 10

29139 29 139 322226 A 0 0‐19 10

29165 29 165 322222 B 0 20‐99 60

29183 29 183 322222 C 0 100‐249 175

29189 29 189 322221     17 0 0

29189 29 189 322222     38 0 0

29510 29 510 322223 C 0 100‐249 175

29510 29 510 322226 A 0 0‐19 10

Emission Factors:

EPA’s spreadsheet that calculates activity and emissions for VOC contains a list of HAP emission factors

that is different in values and number of HAPs compared to the Access database with national emissions

of CAP and HAP already completed.
229 

   Spreadsheet Database

Pollutant Code EF EF

107211 3.3075    

171 10.1577    

78933 26.46    

1330207 16.17   

71556 5.88    

108883 19.11 76.13718

108101 61.005 24.12858

100414     3.84279

106423     3.55047

108383     7.96572

110543     143.93106

121448     0.28623

540885     15.21282

95476     3.50175

VOC 609.3887738 609

Missouri will use the HAP emission factors from the database when doing point source adjustments as

these are the emissions EPA intends to use for gap filling where states submit no data.

Point Source Subtraction

Point source employment in NAICS 322221*, 322222*, 322223*, 322225* and 322226* returns a single

source:

Count FIPS County Name Plant ID Plant Name

NAICS Number of

Employees

29510 ST. LOUIS CITY   0118 JW ALUMINUM                  322225 250

County Business Patterns identifies two employers in the 249‐499 number of employee range.  One of

the employers is in the range of 100‐249 (JW Aluminum fits this category and is a point source), and

another facility is within the range of 0‐19 employees.  A nonpoint facility with air permits is National

Graphics (aka IJ Technologies) with NAICS 322222.  They’ve reported 10 employees as of 2006, and CBP

agrees they’re still in this range.  Their reported VOC emissions as a nonpoint source directly reporting

to the state are 0.24 tons VOC in 2011.  Subtracting the number of point source employees from EPA’s

estimated total for the county leaves (333‐250) 83 employees as nonpoint.  This estimate is not

reasonable given the single nonpoint source direct report, so Missouri will substitute the bottom‐up

data from National Graphics as higher quality data compared to EPA’s estimate.  This county will not

have HAP data as they are below the HAP reporting threshold.

Nonpoint comparisons:
230 

The remaining counties with EPA‐estimated nonpoint employees and emissions are compared to the

emissions database for Missouri containing other permitted sources that do not meet EPA’s AERR

definition of Type A or B point source.   

County

FIPS

County

Name

Number of

Remaining

Nonpoint

Employees

29183 St. Charles 118

29047 Clay 78

29189 St. Louis 55

29165 Platte 41

29139 Montgomery 29

29077 Greene 24

In St. Charles County, two facilities show up on the list:  EHV Weidmann Industries has a rotogravure

printer for sheet printing of electrically conductive papers, and RX Systems prints paper materials for the

pharmaceutical industry.  Both facilities do not meet the AERR definition of point source, and have

reported emissions to Missouri of less than 5 tons VOC.  Neither of these facilities have reported their

number of employees to Missouri, and CBP shows seven facilities comprise the total nonpoint

employment in this county.  Without complete employer and facility data, there is no justification to

change EPA’s emission estimate for this county.

In Clay County, CBP lists one employer with between 20 and 99 employees in NAICS 32221.  Missouri’s

data shows one nonpoint facility, Pioneer Container Corporation with 74 employees.  Their last reported

emissions for 1996 were 3.91 tons of VOC.  EPA’s estimate puts them at 23 tons of VOC, which seems

unreasonable given their current permit type.  Missouri will use the bottom‐up facility reported VOC

emissions in place of EPA’s estimate for this nonpoint county estimate.  This county does not have HAP

emissions as they are below the HAP reporting threshold.

In St. Louis County, there are no sources with this NAICS according to Missouri’s data.  EPA’s estimate is

accepted.

In Platte County, there are no sources with this NAICS according to Missouri’s data.  EPA’s estimate is

accepted.

In Montgomery County, there are no sources with this NAICS according to Missouri’s data.  EPA’s

estimate is accepted.
231 

In Greene County, there are multiple employers according to CBP, and only one out of business facility in

Missouri’s data.  There is not enough Missouri‐specific information to verify EPA’s estimate, and it is

accepted as‐is.

Emissions

Emissions of VOC and HAPs are summarized by county below in pounds per year.  All counties not listed

have zero emissions for this SCC.

County

FIPS

County

Name

Ethyl

Benzene

p‐

Xylene

Methyl

Isobutyl

Ketone

m‐

Xylene Toluene Hexane Triethylamine

Tert‐butyl

Acetate

o‐

Xylene VOC

29047 Clay    7,820.00

29077 Greene

   

92.23  

   

85.21  

  

579.09

  

191.18

  

1,827.29

  

3,454.35                  6.87        365.11  

  

84.04   14,707.00

29139 Montgomery

   

111.44  

   

102.96  

  

699.73

  

231.01

  

2,207.98

  

4,174.00                  8.30        441.17  

  

101.55   17,529.00

29165 Platte

   

157.55  

   

145.57  

  

989.27

  

326.59

  

3,121.62

  

5,901.17                11.74        623.73  

  

143.57   24,695.00

29183 St. Charles

   

453.45  

   

418.96  

  

2,847.17

  

939.95

  

8,984.19

  

16,983.87                33.78     1,795.11  

  

413.21   72,028.00

29189 St. Louis  

   

211.35  

   

195.28  

  

1,327.07

  

438.11

  

4,187.54

  

7,916.21                15.74        836.71  

  

192.60   33,516.00

29510 St. Louis City        480.00

   
232 

8.49 Surface Coating:  Railroad

The Missouri DNR developed the following estimate of emissions and documentation for this source

category.

1. Category Description

Surface coating of railroad equipment and rolling stock is covered by the following nonpoint SCC

SCC SCC Level One SCC Level Two

SCC Level

Three SCC Level Four

2401085000

Solvent

Utilization

Surface

Coating

Railroad: SIC

374 Total: All Solvent Types

2. Emission Factors

EPA’s spreadsheet and the Access database contain differing numbers of HAP pollutants and different

emission factors.   

Access DB Spreadsheet

Pollutant Code

Emission

Factor

Emission

Factor

100414 3.12832 None

108883 41.44816 5.772

110543 73.8608 None

1330207 12.03488 4.884

VOC 208 208

74556 none 1.776

78933 none 7.992

171 none 3.068

107211 none 0.999

The Access database emission factors are used for Missouri’s estimate as EPA intends to submit this data

to the EIS as a national default.

3. Point Source Subtraction

For point sources with NAICS 3365*, the following point source in Jefferson County has more reported

employees than the EPA CDB estimation method for the single employer in the county.  For Jefferson

County, there are no nonpoint emissions for railroad surface coating.
233 

County County

Name

Plant

Number Plant Name Site Name NAICS NAICS Description ProductDescription

Number of

Employees

095 JACKSON 2035 WABTEC

KANSAS CITY

SERVICE CENTER

WABTEC

KANSAS CITY

SERVICE

CENTER

336510 RAILROAD ROLLING

STOCK

MANUFACTURING

RAILCAR

PARTS RMFGF

228

099 JEFFERSON 0011 UNION PACIFIC

RAILROAD CO

DESOTO CAR

SHOP

336510 RAILROAD ROLLING

STOCK

MANUFACTURING

RAILCARS 316

For Jackson County, a nonpoint permitted facility named Wabtec Kansas City Service Center has

reported 228 employees to Missouri, with 3.4 tons of VOC emissions.  The CBP database shows only one

employer in the county with a range from 100‐249 employees.  Since there are no unaccounted for

employees in the county, and the nonpoint estimation method is significantly higher than this (12 tons

VOC), the more accurate, bottom‐up reported emissions are used in place of EPA’s estimate.

The final emissions submitted for this category (all other Missouri counties are submitted with zero

emissions):

State And

County

FIPS Code

County

Name

Emissions Unit

of Measure

Code

Ethyl

Benzene Hexane Toluene

Volatile

Organic

Compounds

Xylenes

(Mixed

Isomers)

29031

Cape

Girardeau LB   188 4432 2487 12498 722

29043 Christian LB   188 4432 2487 12498 722

29069 Dunklin LB   188 4432 2487 12498 722

29095 Jackson LB   0 0 0 6800 0

29099 Jefferson LB   0 0 0 0 0

   
234 

8.50 Surface Coating:  Traffic Markings

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.

8.51 Surface Coating:  Wood Furniture

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.

   
235 

8.52 Landfills

a. Source Category Description 

Emissions from landfills include criteria and HAP pollutants, along with GHG pollutants not covered by this 

inventory. Landfills with large capacity and methane generation potential are subject to Part 70 operating permit 

requirements, and are therefore included in the point source part of the inventory. The list of point source landfills is 

in the table below. 

County Name County

Code

Plant

Identifier Plant Name Site Name OperatingPermit Type SIC NAICS

BOONE 019 0091 COLUMBIA

SANITARY LANDFILL

COLUMBIA P70 4953 562212

BUCHANAN 021 0105 ST. JOSEPH

LANDFILL

50TH ROAD SE P70 4953 562212

BUTLER 023 0058 BUTLER COUNTY

LANDFILL

BUTLER COUNTY

SANITARY LANDFILL

P70 4953 562212

COLE 051 0058 JEFFERSON CITY

LANDFILL LLC

JEFFERSON CITY P70 4953 562212

GREENE 077 0161 SPRINGFIELD

SANITARY LANDFILL

WILLARD P70 4953 562212

JACKSON 095 0267 COURTNEY RIDGE

LANDFILL, LLC

COURTNEY RIDGE

LANDFILL

P70 4953 562212

JACKSON 095 0273 RUMBLE RECYCLING

AND DISPOSAL

SERVICES

SANITARY LANDFILL

RUMBLE 1 & 2

P70 4953 562212

JACKSON 095 2101 SOUTHEAST

LANDFILL, LLC

KANSAS CITY

LANDFILL

P70 4953 562212

JACKSON 095 0272 LEE'S SUMMIT

SANITARY LANDFILL

LEE'S SUMMIT

SANITARY LANDFILL

P70 4953 562212

BARTON 011 0039 PRAIRIE VIEW

REGIONAL WASTE

FACILITY

LAMAR P70 4953 562212

LEWIS 111 0025 BFI BACKRIDGE

LANDFILL

LAGRANGE P70 4953 562212

WRIGHT 229 0022 BLACK OAK

RECYCLING &

DISPOSAL FACILITY

DIV WASTE

CORPORATION OF

MISSOURI INC

P70 4953 562212

MACON 121 0027 VEOLIA ES MAPLE

HILL LANDFILL, INC

MACON P70 4953 562212

PETTIS 159 0055 CENTRAL MISSOURI

SANITARY LANDFILL

CENTRAL MISSOURI

SANITARY LANDFILL

P70 4953 562212

PIKE 163 0040 EAGLE RIDGE

LANDFILL

BOWLING GREEN P70 4953 562212

ST. LOUIS CO. 189 0281 BFI MISSOURI PASS MARYLAND P70 4953 562212
236 

County Name County

Code

Plant

Identifier Plant Name Site Name OperatingPermit Type SIC NAICS

LANDFILL HEIGHTS

ST. LOUIS CO. 189 0308 IESI MO CHAMP

LANDFILL

ST. LOUIS COUNTY P70 4953 562212

ST. LOUIS CO. 189 0310 ADVANCED

DISPOSAL SERVICES

OAK RIDGE

LANDFILL

P70 4953 562212

ST. LOUIS CO. 189 0312 BRIDGETON

LANDFILL, LLC

BRIDGETON P70 4953 562212

STODDARD 207 0062 LEMONS SANITARY

LANDFILL

DEXTER P70 4953 562212

WASHINGTON 221 0031 IESI CORPORATION TIMBER RIDGE

LANDFILL

P70 4953 562212

JOHNSON 101 0046 SHOW‐ME

REGIONAL LANDFILL

SHOW‐ME

REGIONAL LANDFILL

P70 4953 562212

For this source category, the following SCC was assigned: 

Source 

Classification 

Code 

SCC Level One SCC Level Two SCC Level Three SCC Level Four 

2320000000 

Waste Disposal, 

Treatment, and 

Recovery 

Landfills All Categories Total 

b. Activity Data 

The small landfills in Missouri are not permitted, and therefore aren’t subject to reporting requirements

that would allow bottom‐up inventory development with state‐specific data.  EPA has not provided a

nonpoint estimate starting point for states for 2011.  EPA’s 2008 NEI v2 documentation states on page 7:   

“Landfills have not been estimated by EPA for the 2008 NEI, as had been done in earlier NEI years. Some

States do report some pollutants for some of their larger landfills, and these have been included in the

2008 NEI. This is expected to be largely an issue for some toxics. The scope of the underestimate is

uncertain, due to an expectation that many landfills have been adding gas collection systems as a result

of various control programs and the value of the collected gas as a fuel. “

As such, Missouri is choosing not to provide a nonpoint emission estimate for landfills and will let the

point source landfills stand on their own.
237 

f. References 

1. 2008 NEI Version 2 Technical Support Documentation (draft), updated 6/2012.  Accessed 10‐25‐

2012 at http://www.epa.gov/ttn/chief/net/2008neiv2/2008_neiv2_tsd_draft.pdf

   
238 

8.53 Publically Owned Treatment Works

The Missouri DNR accepted EPA’s estimates of emissions for this source category.   EPA is pulling this

emission estimate forward as‐is from 2008 to 2011 with no updates.  Missouri sees no problems with

this method, and has no point source subtraction to complete for this category.  The documentation

below was developed by EPA.   

Source Category Description

Publicly Owned Treatment Works (POTW) means a treatment works that is owned by a state,

municipality, city, town, special sewer district, or other publicly owned and financed entity as opposed

to a privately (industrial) owned treatment facility. The definition includes intercepting sewers, outfall

sewers, sewage collection systems, pumping, power, and other equipment.  The wastewater treated by

these POTWs is generated by industrial, commercial, and domestic sources.1

  

The general approach to calculating emissions for POTWs is to estimate the 2008 national POTW flow

rate using methods described below and then multiply the estimated flow rate by the emission factors

for VOCs, ammonia, and 53 HAPs. The emissions are allocated to the county level using methods

described below.  

Activity Data  

A nationwide projected flow rate in 2010 of 39,780 million gallons per day (MMGD) was available from

an EPA report.2 Of this, POTWs account for 98.5 percent of the flow rate or 39,180 MMGD, with

privately owned treatment works accounting for the rest. The EPA Clean Watersheds Needs Survey

reports the existing flow rate in 2004 for POTWs as 34,370 MMGD.3

  The interpolated 2008 nationwide

flow rate (using a linear regression) was calculated at 37,580 MMGD, or 13,754,280 million gallons

annually. The nationwide flow rate includes Puerto Rico and the U.S. Virgin Islands.

Emission Factors

The ammonia emission factor was obtained from a report to EPA4, while the VOC emission factor was

based on a TriTAC study.5 Emission factors for the 53 HAPs were derived using 1996 area source

emissions estimates that were provided by ESD6 and the 1996 nationwide flow rate.7 These HAP

emission factors were then multiplied by the 2008 to 2002 VOC emission factor ratio (0.85/9.9) to obtain

the final HAP emission factors applied in the 2008 inventory. The emission factors, pollutant codes, and

pollutant descriptions are reported in the table below.  
239 

Criteria and HAP Emission Factors for Publicly Owned Treatment Works (SCC 2630020000): Not

Adjusted for Point Source Emissions

Pollutant Description

NIF 3.0 Pollutant

Codes

Emission Factor

(lb/MMGAL)

Emission Factor

Reference(s)

1,1,2,2‐TETRACHLOROETHANE 79345 1.75E‐06 6, 7

1,1,2‐TRICHLOROETHANE 79005 1.17E‐06 6, 7

1,2,4‐TRICHLOROBENZENE 120821 8.67E‐05 6, 7

1,3‐BUTADIENE 106990 2.51E‐05 6, 7

1,4‐DICHLOROBENZENE 106467 2.16E‐04 6, 7

1‐CHLORO‐2,3‐EPOXYPROPANE 106898 4.52E‐06 6, 7

2,4‐DINITROTOLUENE 121142 4.81E‐05 6, 7

2‐NITROPROPANE 79469 2.92E‐07 6, 7

ACETALDEHYDE 75070 3.10E‐04 6, 7

ACETONITRILE 75058 3.45E‐04 6, 7

ACROLEIN 107028 3.84E‐04 6, 7

ACRYLONITRILE 107131 3.86E‐04 6, 7

ALLYL CHLORIDE 107051 1.94E‐05 6, 7

AMMONIA NH3 1.69E‐01 4

BENZENE 71432 6.73E‐03 6, 7

BENZYL CHLORIDE 100447 8.17E‐06 6, 7

BIPHENYL 92524 7.52E‐05 6, 7

CARBON DISULFIDE 75150 4.32E‐03 6, 7

CARBON TETRACHLORIDE 56235 1.12E‐03 6, 7

CHLOROBENZENE 108907 4.83E‐04 6, 7

CHLOROFORM 67663 6.44E‐03 6, 7

CHLOROPRENE 126998 2.38E‐05 6, 7

CRESOLS (INCLUDES O, M, & P)/CRESYLIC ACIDS 331 1.61E‐06 6, 7

DIMETHYL SULFATE 77781 1.31E‐06 6, 7

ETHYL ACRYLATE 140885 1.75E‐06 6, 7

ETHYL BENZENE 100414 7.66E‐03 6, 7

ETHYLENE OXIDE 75218 2.22E‐04 6, 7

FORMALDEHYDE 50000 1.97E‐05 6, 7

GLYCOL ETHERS 171 1.15E‐02 6, 7

HEXACHLOROBUTADIENE 87683 7.29E‐07 6, 7

HEXACHLOROCYCLOPENTADIENE 77474 5.83E‐07 6, 7

METHANOL 67561 1.14E‐02 6, 7

METHYL CHLOROFORM 71556 5.63E‐04 6, 7

METHYL ETHYL KETONE 78933 2.84E‐03 6, 7

METHYL ISOBUTYL KETONE 108101 2.69E‐03 6, 7

METHYL METHACRYLATE 80626 3.11E‐04 6, 7

METHYL TERT‐BUTYL ETHER 1634044 6.37E‐05 6, 7

METHYLENE CHLORIDE 75092 9.10E‐03 6, 7

N,N‐DIMETHYLANILINE 121697 3.22E‐04 6, 7

NAPHTHALENE 91203 1.31E‐03 6, 7
240 

Pollutant Description

NIF 3.0 Pollutant

Codes

Emission Factor

(lb/MMGAL)

Emission Factor

Reference(s)

NITROBENZENE 98953 6.56E‐06 6, 7

O‐TOLUIDINE 95534 1.75E‐06 6, 7

P‐DIOXANE 123911 1.79E‐05 6, 7

PROPIONALDEHYDE 123386 3.50E‐06 6, 7

PROPYLENE DICHLORIDE 78875 1.15E‐05 6, 7

PROPYLENE OXIDE 75569 7.32E‐04 6, 7

STYRENE 100425 2.73E‐03 6, 7

TETRACHLOROETHYLENE 127184 4.27E‐03 6, 7

TOLUENE 108883 1.23E‐02 6, 7

TRICHLOROETHYLENE 79016 3.06E‐04 6, 7

VINYL ACETATE 108054 7.66E‐05 6, 7

VINYL CHLORIDE 75014 6.71E‐06 6, 7

VINYLIDENE CHLORIDE 75354 4.23E‐04 6, 7

VOLATILE ORGANIC COMPOUNDS VOC 8.50E‐01 5

XYLENES (MIXTURE OF O, M, AND P ISOMERS) 1330207 5.98E‐02 6, 7

lb/MMGAL = pounds per million gallons

Emissions

Emissions were allocated to the county‐level by the county proportion of the U.S. population.8  

It is important to note that the emission estimates for this category represent total emissions.  It may be

necessary to determine whether there are point source emissions in SCCs 50100701 through 50100781

and 50100791 through 50182599 that need to be subtracted to yield the nonpoint source emission

estimates for this category.

Sample Calculations:

The 1996 flow rate per day was 32,175 MMGD.  (1996 was a leap year.)  Annually, this computes to:

32,175 MMGD treated * 366 days = 11,776,050 million gallons treated

Benzene emissions in 1996 for area source POTWs were estimated to be 461.44 tons per year.  The

derived benzene emission factor is calculated as follows:
241 

Benzene emission factor = ((461.44 tons * 2000 lb/ton) / (11,776,050 million gallons treated)) *

(0.85/9.9)

Benzene emission factor = 0.0067287 lb/million gallons treated

Benzene emissions for 2008 for area source POTWs are calculated as follows:

2008 Benzene emissions = (37,580 MMGD * 366 days) * (0.0067287 lb/million gallons treated)

2008 Benzene emissions = 92,548 pounds / 2,000 pounds = 46.27 tons/year

Total national 2008 benzene emissions from area source POTWs are allocated to county‐level by the

county proportion of the U.S. population. The total U.S. population in 2008 is 308,123,578. Benzene

emissions for Autauga County, Alabama (2008 population of 50,364) are calculated as follows:

2008 emissions = 46.27 tons/year * 50,364/308,123,578 = 0.0076 tons/year

References

1. U.S. Environmental Protection Agency,  64FR57572, National Emission Standards for Publicly

Owned Treatment Works, Final Rule,  40 CFR Part 63,  26 October 1999.

2. U.S. Environmental Protection Agency, “Wastewater Flow Projections for POTWs and Privately

and Federally Owned Treatment Works in 2000, 2005, and 2010,” Table A‐8 in Biosolids

Generation, Use, and Disposal in the United States, EPA530‐R‐99‐009, September 1999.   

3. U.S. Environmental Protection Agency, Clean Watersheds Needs Survey, Ask WATERS Online

Database Query Tool, at

http://iaspub.epa.gov/waters10/query_tool.criteria?srept_no=165&branding=15, accessed 19

May 2009.

4. Stephen M. Roe, Melissa D. Spivey, Holly C. Lindquist, Kirstin B. Thesing, and Randy P. Strait, E.H.

Pechan & Associates, Inc., Estimating Ammonia Emissions from Anthropogenic Nonagricultural

Sources – Draft Final Report, prepared for U.S. Environmental Protection Agency, Emission

Inventory Improvement Program, April 2004.

5. Prakasam Tata, Jay Witherspoon, Cecil Lue‐Hing (eds.), VOC Emissions from Wastewater

Treatment Plants: Characterization, Control, and Compliance, Lewis Publishers, 2003, p. 261.

6. Memorandum from Bob Lucas, U.S Environmental Protection Agency to Greg Nizich, U.S.

Environmental Protection Agency,  “Review of Baseline Emissions Inventory,”  16 October 1998.

7. U.S. Environmental Protection Agency, “Facilities Database (Needs Survey) ‐ Frequently Asked

Questions,” at http://www.epa.gov/owm/mtb/cwns/1996rtc/faqwfd.htm, accessed 22 May

2009.
242 

8. U.S. Census Bureau, “Population Estimates,” at http://www.census.gov/popest/estimates.html,

released 14 May 2009 with population estimates as of 1 July 2008. Note: The U.S. Census

Bureau estimate does not include the U.S. Virgin Islands, so the Census Bureau estimate was

supplemented with Virgin Island population data from U.S. Department of Commerce, National

Oceanic and Atmospheric Administration, Demographic Baseline Report of U.S. Territories and

Counties Adjacent to Coral Reef Habitats, June 2008, at

http://coris.noaa.gov/activities/coral_demographics, accessed 9 June 2009.

  

   
243 

8.54 Cremation:  Human and Animal

The Missouri DNR developed the following estimate of emissions and documentation for this source

category.

a. Source Category Description

Human and animal cremation is the process of disposing of carcasses in a high temperature incineration chamber.

Criteria air pollutant (CAP) and hazardous air pollutant (HAP) emission estimates for cremation are reported as the

mass of material incinerated combined with an emission factor for each pollutant.   

For this source category, the following SCC was assigned:

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

2810060100

Miscellaneous Area

Sources

Other Combustion Cremation Humans

2810060200

Miscellaneous Area

Sources

Other Combustion Cremation Animals

b. Activity Data

Missouri chose between two methods to develop emissions for this category:  use emission inventory data

collected from specific, stationary crematory sites, or use surrogate activity data with emission assumptions.

The Emission Inventory Improvement Program4 (EIIP) Volume 3, Chapter 1 describes area source (now known as

nonpoint source) emission estimation methods states can choose from.  To obtain the most accurate inventory,

the most specific data collected and quality assured is preferable to surrogate activity data that is allocated to the

geographic region of interest.  For the human or animal crematory category, these facilities have reported

emissions directly to the state of Missouri as described in section c.  Using quality assured facility‐reported data

ensures that the inventory is developed in a bottom‐up fashion, as opposed to a top‐down method where activity

data from a much larger geographic region is used to estimate emissions and allocated down to the county level.

The bottom‐up approach for Missouri relies on facility submitted emission reports required by 10 CSR 10‐6.110.  

Crematory facilities are not required to submit detailed emission reports annually due to their permit type and
244 

potential to emit – they can roll forward a representative year’s emissions as long as the total emissions change

less than 5 tons and they have no new permitted equipment operating in the year.  For the majority of these

facilities, emissions vary less than 2 tons per year due to their steady nature of operation and consistent emission

rates.  It is reasonable to assume a past emission report is representative of the 2011 year for this category.

c. Controls

Emissions from crematory operations may include a very small amount of several chemicals.  Controls are seldom

used for this process.  Afterburners are the most frequently used for the sites which have controlled emissions.  Of

the 90 crematory sites in Missouri, 14 use control equipment.

d. Emission Factors

The statewide average for the emission factor of the criteria pollutants are listed in the following table:

Pollutant Emission Factor (lbs/ton cremated)

PM10 3.152

SOx 2.296

NOx 4.296

VOC 3.482

CO 2.783

PM2.5 1.973

An examination of the range of values for the emission factors was done to determine the effect of changing the

high and low end values of the emission factor.  The webFIRE factor was used for the sites which used factors

significantly different than the webFIRE factor.  The emissions would change minimally (about 0.02 tons or 40

pounds per pollutant), so the emission factors have a negligible effect on the total emissions.

Criteria pollutants are included in Missouri’s data as not all facilities reported HAP data due to the reporting

threshold of 20 or 200 lbs per year, depending on the HAP pollutant.  EPA has provided estimates of HAPs for this

category, and they may choose to use them where Missouri does not provide data.  
245 

e. Crematory Sites

When the list was initially pulled from the Missouri Emission Inventory database the sites were queried by

SIC/NAICS.  Incinerators which were in grocery stores that burned cardboard boxes were on the initial list.  

Currently, all those incinerators are shut down but the grocery stores are still active and exist in the database.  To

eliminate facilities which do not cremate the second criteria was added to the query – SCCs which are specific to

cremation.  Hospitals which cremate remains would not be included on the list because of the SIC/NAICS they have

even though they use the SCCs which are specific to cremation.  The list which was generated is 90 active facilities.

The sites in Missouri were selected based on a combination of the NAICS/SIC and the SCC used on the emission

inventory questionnaires.  The following tables show which codes were selected and their descriptions.

Crematory NAICS

NAICS NAICS description SIC SIC description

562213 Solid Waste Combustors and 

Incinerators

4953 Refuse Systems (solid waste combustors and 

incinerators)

812210 FUNERAL HOMES AND 

FUNERAL SERVICES

7261 FUNERAL SERVICES AND CREMATORIES 

(FUNERAL HOMES AND SERVICES)

812220 CEMETERIES AND 

CREMATORIES

7261 FUNERAL SERVICES AND CREMATORIES 

(CREMATORIES)

812910 PET CARE (EXCEPT 

VETERINARY) SERVICES

0752 ANIMAL SPECIALTY SERVICES, EXCEPT 

VETERINARY (PET CARE SERVICES, EXCEPT 

VETERINARY)

Crematory SCC

SCC code

Level 1

Description

Level 2 Description

Level 3

Description

Level 4 Description

31502101 Industrial

Processes

Photographic Equipment/Health

Care/Laboratories

Health Care ‐

Crematoriums

Crematory Stack
246 

Crematory SCC

SCC code

Level 1

Description

Level 2 Description

Level 3

Description

Level 4 Description

31502102 Industrial

Processes

Photographic Equipment/Health

Care/Laboratories

Health Care ‐

Crematoriums

Crematory Stack ‐ Human and Animal

Crematories

50100505 Waste Disposal Solid Waste Disposal ‐ 

Government

Other

Incineration

Medical Waste Incinerator, unspecified

type, Infectious wastes only

50200101 Waste Disposal Solid Waste Disposal ‐ 

Commercial/Institutional

Incineration Multiple Chamber

50200501 Waste Disposal Solid Waste Disposal ‐ 

Commercial/Institutional

Incineration:

Special Purpose

Med Waste Controlled Air Incin‐aka

Starved air, 2‐stg, or Modular comb

50200504 Waste Disposal Solid Waste Disposal ‐ 

Commercial/Institutional

Incineration:

Special Purpose

Medical Waste Incinerator, unspecified

type (use 502005‐01, ‐02, ‐03)

50200505 Waste Disposal Solid Waste Disposal ‐ 

Commercial/Institutional

Incineration:

Special Purpose

Medical Waste Incinerator, unspecified

type, Infectious wastes only

The table below shows which counties have these sites as well the count of each.  One site on the list (in Pettis

County) had a facility which processed both human and animal remains at their location.

County County Name Number of sites Animal Crematories Human Crematories

29001 ADAIR 1 0 1

29003 ANDREW 0 0 0

29005 ATCHISON 0 0 0

29007 AUDRAIN 0 0 0

29009 BARRY 1 0 1

29011 BARTON 0 0 0

29013 BATES 0 0 0

29015 BENTON 2 0 2

29017 BOLLINGER 0 0 0

29019 BOONE 6 2 4

29021 BUCHANAN 2 0 2

29023 BUTLER 1 0 1

29025 CALDWELL 0 0 0

29027 CALLAWAY 1 0 1

29029 CAMDEN 1 0 1

29031 CAPE GIRARDEAU 3 2 1

29033 CARROLL 0 0 0

29035 CARTER 0 0 0

29037 CASS 0 0 0

29039 CEDAR 0 0 0

29041 CHARITON 0 0 0
247 

County County Name Number of sites Animal Crematories Human Crematories

29043 CHRISTIAN 0 0 0

29045 CLARK 0 0 0

29047 CLAY 2 2 0

29049 CLINTON 1 1 0

29051 COLE 2 2 0

29053 COOPER 1 1 0

29055 CRAWFORD 0 0 0

29057 DADE 0 0 0

29059 DALLAS 0 0 0

29061 DAVIESS 0 0 0

29063 DE KALB 0 0 0

29065 DENT 0 0 0

29067 DOUGLAS 0 0 0

29069 DUNKLIN 0 0 0

29071 FRANKLIN 1 0 1

29073 GASCONADE 0 0 0

29075 GENTRY 0 0 0

29077 GREENE 3 0 3

29079 GRUNDY 0 0 0

29081 HARRISON 0 0 0

29083 HENRY 0 0 0

29085 HICKORY 0 0 0

29087 HOLT 0 0 0

29089 HOWARD 0 0 0

29091 HOWELL 1 0 1

29093 IRON 0 0 0

29095 JACKSON 10 4 6

29097 JASPER 7 3 4

29099 JEFFERSON 2 1 1

29101 JOHNSON 2 1 1

29103 KNOX 0 0 0

29105 LACLEDE 1 1 0

29107 LAFAYETTE 0 0 0

29109 LAWRENCE 0 0 0

29111 LEWIS 0 0 0

29113 LINCOLN 0 0 0

29115 LINN 0 0 0

29117 LIVINGSTON 1 1 0

29119 MCDONALD 0 0 0
248 

County County Name Number of sites Animal Crematories Human Crematories

29121 MACON 0 0 0

29123 MADISON 0 0 0

29125 MARIES 1 1 0

29127 MARION 0 0 0

29129 MERCER 0 0 0

29131 MILLER 0 0 0

29133 MISSISSIPPI 0 0 0

29135 MONITEAU 0 0 0

29137 MONROE 0 0 0

29139 MONTGOMERY 0 0 0

29141 MORGAN 0 0 0

29143 NEW MADRID 0 0 0

29145 NEWTON 0 0 0

29147 NODAWAY 0 0 0

29149 OREGON 1 1 0

29151 OSAGE 0 0 0

29153 OZARK 0 0 0

29155 PEMISCOT 1 1 0

29157 PERRY 0 0 0

29159 PETTIS 1 1 1

29161 PHELPS 4 3 1

29163 PIKE 0 0 0

29165 PLATTE 2 1 1

29167 POLK 1 1 0

29169 PULASKI 2 1 1

29171 PUTNAM 0 0 0

29173 RALLS 0 0 0

29175 RANDOLPH 0 0 0

29177 RAY 0 0 0

29179 REYNOLDS 0 0 0

29181 RIPLEY 0 0 0

29183 ST. CHARLES 6 2 4

29185 ST. CLAIR 0 0 0

29186 STE. GENEVIEVE 0 0 0

29187 ST. FRANCOIS 3 0 3

29189 ST. LOUIS CO. 10 1 9

29195 SALINE 0 0 0

29197 SCHUYLER 0 0 0

29199 SCOTLAND 0 0 0
249 

County County Name Number of sites Animal Crematories Human Crematories

29201 SCOTT 0 0 0

29203 SHANNON 0 0 0

29205 SHELBY 0 0 0

29207 STODDARD 1 0 1

29209 STONE 1 0 1

29211 SULLIVAN 0 0 0

29213 TANEY 0 0 0

29215 TEXAS 0 0 0

29217 VERNON 0 0 0

29219 WARREN 0 0 0

29221 WASHINGTON 0 0 0

29223 WAYNE 0 0 0

29225 WEBSTER 1 1 0

29227 WORTH 0 0 0

29229 WRIGHT 0 0 0

29510 ST. LOUIS CITY 3 2 1

Total Statewide 90 37 54

f. Emissions from Human Cremation

The following table lists county‐total emissions by pollutant.  Emissions are listed in tons per year.  Counties

without human crematories are not included in this table.

County County Name

Number of Human

Crematory Facilities CO NOx PM10 PM2.5 SOx VOC

29001 ADAIR            1 0.0008 0.0056 0 0 0 0.0002

29009 BARRY            1 0.0052 0.0063 0.0054 0.0036 0.0038 0.0005

29015 BENTON           2 0.0171 1.7375 0.1141 0 0.265 0.0146

29019 BOONE            4 0.1516 0.1376 0.1176 0.0868 0.0872 0.0252

29021 BUCHANAN         2 0.3336 0.1575 0.2541 0.108 0.1212 0.2999

29023 BUTLER           1 0 0 0 0 0 0

29027 CALLAWAY         1 0 0 0.0123 0 0 0

29029 CAMDEN           1 0 0 0 0 0 0

29031 CAPE GIRARDEAU   1 0.0002 0 0.0003 0 0.0007 0

29071 FRANKLIN         1 0.0001 0.0123 0.0002 0 0.0012 0.0001

29077 GREENE           3 0.0057 0.1767 0.0617 0.0348 0.0513 0.0024

29091 HOWELL           1 0 0.0003 0.03 0 0.0001 0

29095 JACKSON          6 0.1152 0.457 0.9048 0.6919 0.5172 0.6599

29097 JASPER           4 0.0417 0.2651 0.0817 0.006 0.06 0.1914

29099 JEFFERSON        1 0.0199 0.024 0.0205 0 0.0146 0.002

29101 JOHNSON          1 0.0017 0.0374 0.0622 0.0212 0.0778 0.0059
250 

County County Name

Number of Human

Crematory Facilities CO NOx PM10 PM2.5 SOx VOC

29159 PETTIS           1 0.0583 0.0175 0.0151 0 0.0151 0.0175

29161 PHELPS           1 0.0148 0.0178 0.0152 0 0.0109 0.0015

29165 PLATTE           1 0.1008 0.1217 0.2024 0 0.0855 0.3488

29169 PULASKI          1 0.0116 0.0447 0.0771 0 0.0027 0.0671

29183 ST. CHARLES      4 0.2025 0.2446 0.2389 0.0001 0.1485 0.2066

29187 ST. FRANCOIS     3 0.0162 0.0268 0.033 0 0.0148 0.0563

29189 ST. LOUIS CO.    9 0.173 0.2089 0.178 0 0.127 0.0171

29207 STODDARD         1 0 0 0.0006 0 0 0

29209 STONE            1 0 0 0 0 0 0

29510 ST. LOUIS CITY   1 0.1062 0.1281 0.1682 0 0.0781 0.0107

Statewide Total Human Cremation 1.3762 3.8274 2.5934 0.9524 1.6827 1.9277
251 

g. Emissions from Animal Cremation

The following table lists county‐total emissions by pollutant.  Counties without animal crematories are not included

in this table.  Emissions are in tons per year.

County County Name

Number of Animal

Crematory Facilities CO NOx PM10 PM2.5 SOx VOC

29019 BOONE            2 0.2794 0.043 0.0708 0.0555 0.0311 0.1093

29031 CAPE GIRARDEAU   2 0.0532 0.095 0.118 0.023 0.1561 0.1803

29047 CLAY             2 0.1342 0.1619 0.2693 0.22 0.1137 0.4641

29049 CLINTON          1 0.0147 0.0178 0.0296 0.025 0.0125 0.051

29051 COLE             2 0.1369 0.0412 0.0645 0 0.0343 0.041

29053 COOPER           1 0.0002 0.0037 0.0006 0.0006 0.0007 0.0037

29095 JACKSON          4 2.0289 1.157 0.9072 0 0.9641 0.8858

29097 JASPER           3 0.1481 0.1725 0.0781 0 0.1389 0.2393

29099 JEFFERSON        1 0.3726 1.599 0.9173 0 1.3325 1.599

29101 JOHNSON          1 0.0039 0.0048 0.0062 0.0027 0.0029 0

29105 LACLEDE          1 0.0929 0.1121 0.1864 0 0.0787 0.3213

29117 LIVINGSTON       1 0.0029 0.0035 0.0059 0 0.0025 0.0102

29125 MARIES           1 0.0047 0.0056 0.0093 0 0.0039 0.0161

29149 OREGON           1 0.0022 0.0027 0.0023 0.0015 0.0016 0.0002

29155 PEMISCOT         1 0.001 0.0048 0.0015 0 0 0.0048

29159 PETTIS           1 0.0015 0.0189 0.0147 0 0.0147 0.0189

29161 PHELPS           3 0.0277 0.0335 0.0724 0 0.0233 0.0907

29165 PLATTE           1 0.0293 0.4295 0.0796 0 0.2343 0.1063

29167 POLK             1 0.0038 0.0046 0.0076 0 0.0032 0.0132

29169 PULASKI          1 0.0135 0.0163 0.0271 0 0.0099 0.0468

29183 ST. CHARLES      2 0.1841 0.2259 0.3716 0 0.1568 0.6402

29189 ST. LOUIS CO.    1 0.043 0.052 0.0443 0 0.0317 0.0043

29225 WEBSTER          1 0.0214 0.0258 0.0429 0 0.0181 0.074

29510 ST. LOUIS CITY   2 0.049 0.9529 0.4919 0 1.4762 1.941

Statewide Total Animal Cremation 3.6491 5.184 3.8191 0.3283 4.8417 6.8615
252 

h. QA/QC

1. Number of facilities checked –outliers examined

One of the first sites examined was Logan College (29189‐1114).  The NOx emissions from this site are

over 4 tons.  A closer look at the data revealed that natural gas combustion in space heaters contributed

virtually all their NOx emissions.  This revelation led to the use of specific SCCs to obtain the cremation

emissions in our tables.  Site emissions include data which would overstate the cremation emission data.  

Therefore the process emissions were used via the SCC at specific sites which have the selected NAICS.  

Once the selection criteria were established, the data was reliable.   

The emissions for each site are usually small so the sites which have large numbers stand out.  Ten sites

with the largest quantity of emissions were selected for a quality check.  Emission factors, past years

throughput and emission variances were quality checked. They were acceptable.   

Further quality checks revealed two facilities used an unusually large throughput for their incinerator.  

They were submitting in the incorrect units (pounds or hours) of throughput when the questionnaire

requires the throughput quantity in tons.  They were corrected.

2. Compared to EPA estimate (statewide total table)

In the table below, the animal and human cremation emissions are combined.  There are discrepancies

between the emissions taken from the EPA website and the data from the Missouri EIQs.

Pollutant

EPA Estimate

Of Cremation  

(Emissions in Tons)

Missouri EIQ

Cremation Data

(Emissions in Tons)

PM10 1.34 6.41

SOx 3.14 6.52

NOx 20.38 9.01

VOC .07 8.79

CO .1 5.03

PM2.5 1.34 1.28

EPA’s emission estimate uses top‐down information on mortality, population distribution, and emission

factors that Missouri has not reviewed.  Missouri’s estimate comes from a bottom‐up method, and uses

published and vetted emission factors from AP‐42 in most all cases.  Missouri chooses to use state‐specific

inventory data for this category.

   
253 

8.55 Asphalt Paving:  Cutback

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  The documentation

below was developed by EPA.

a. Source Category Description

Asphalt paving is the process of applying asphalt concrete to seal or repair the surface of roads, parking

lots, driveways, walkways, or airport runways. Asphalt concrete is a composite material comprised of a

binder and a mineral aggregate. The binder, referred to as asphalt cement, is a byproduct of petroleum

refining and contains the semi‐solid residual material left after the more volatile chemical fractions have

been distilled off.1  

Asphalt cements thinned with petroleum distillates are known as cutback asphalts. The primary uses of

cutback asphalt include tack and seal operations, priming roadbeds, and paving operations for pavements

up to several inches thick. Cut‐back asphalt is produced by thinning the binder in a diluent containing 25

to 45 percent petroleum distillates by volume prior to mixing with the aggregate. This reduces the

viscosity of the asphalt making it easier to work with the mixture.

Emissions from cutback asphalt result from the evaporation of VOCs and HAPS after the mixture is laid

down. Of all asphalt types, cutback asphalt has the highest diluent content and, as a result, emits the

highest levels of VOCs per ton used. The timeframe and quantity of VOC and HAP emissions depend on

the type and the quantity of organic solvent used as a diluent.

For this source category, the following SCC was assigned:

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

2461021000 Solvent Utilization Miscellaneous Non‐

industrial: Commercial

Cutback Asphalt Total: All Solvent

Types

The general approach to calculating emissions from cutback asphalt paving is to multiply the estimated

county‐level cutback asphalt usage by emission factors for VOCs and HAPs.

b. Activity Data

State‐level cutback asphalt usage in 2008 was obtained from the Asphalt Institute’s 2008 Asphalt Usage

Survey.

2

  (the EPA used the same activity values for the 2011 as they did for the 2008 NEI due to limited
254 

resources.) State‐level data were allocated to county‐level according to the fraction of paved road

vehicle miles traveled (VMT) in each county.  

Total annual VMT estimates by State and roadway class were obtained from the Federal Highway

Administration’s (FHWA) annual Highway Statistics report.3    Paved road VMT was calculated by

subtracting the State/roadway class unpaved road VMT from total State/roadway class VMT. State‐level

paved road VMT was spatially allocated to counties according to the fraction of total VMT in each

county for the specific roadway class as shown by the following equation:

VMTx,total= ∑VMTST,y*VMTx,y /VMTST,y

where: VMTx,total = VMT (million miles) in county x on all paved roadways

VMTST,y = paved road VMT for the entire State for roadway class y  

VMTx,y = total VMT (million miles) in county x and roadway class y  

VMTST,y = total VMT (million miles) in entire State for roadway class y

The county‐level total VMT by roadway class used in this calculation was previously developed by E.H.

Pechan and Associates, Inc. to support the onroad national emissions inventory.4   

c. Emission Factors

Emission factors for cutback asphalt usage were obtained from the Technical Report Series produced by

the U.S. EPA’s Emission Inventory Improvement Program and are reported in the corresponding table

below.1

d. Emissions

Emissions were calculated by multiplying the county‐level asphalt usage (barrels) by the emission factors

listed in the corresponding table below and then dividing by 2000 to convert pounds to tons.

Emissionsx,y = (Asphalt Usagex * EFy) / 2000

where:    Emissionsx,y = emissions (tons) of pollutant y in county x

    Asphalt Usagex = cutback asphalt (barrels) used in county x

    EFy = emission factor for pollutant y
255 

To convert tons of asphalt reported in the 2008 Asphalt Usage Survey to barrels, it was assumed that the

density of asphalt is similar to that of water, 8.34 lbs/gal, and that one barrel equals 42 gallons.

Barrels of Asphalt = (tons of asphalt * 2000 lbs / 8.34 lbs/gal) / 42 gal/barrel

Note that one barrel of asphalt weights approximately 350 pounds.

e. Sample Calculation

VOC emissions from cutback asphalt usage in Autauga County, Alabama:

From the 2008 Asphalt Usage Survey, the state of Alabama used 1,728 tons of cutback asphalt in 2008.

The fraction of paved road VMT traveled in Autauga County is 497 million miles divided by 53,633 million

miles which equals 0.0093.

Asphalt UsageAutauga = ((1,728 tons * 2000 lbs / 8.34 lbs/gal) / 42 gal/barrel) * 0.0093

Asphalt UsageAutauga = 91.41 barrels

VOC EmissionsAutauga = (91.41 barrels * 88 lbs/barrel) / 2000 lbs/ton

VOC EmissionsAutauga = 4.022 tons

Criteria and HAP Emission Factors for Cutback Asphalt Paving

Pollutant Description Pollutant Code Emission Factor

(LBS/BARREL)

Emission Factor

Reference

VOLATILE ORGANIC COMPOUNDS VOC 88.00 1

ETHYL BENZENE 100414 2.02 1

TOLUENE 108883 5.63 1

XYLENES (MIXTURE OF O, M, AND P 1330207 10.74 1

f. References

1. U.S. Environmental Protection Agency, Emissions Inventory Improvement Program, Technical

Report Series, Volume III – Area Sources, Chapter 17, “Asphalt Paving,” prepared by Eastern

Research Group, Inc. for EPA, Research Triangle Park, NC, 2001. Available at

http://www.epa.gov/ttn/chief/eiip/techreport/volume03/index.html.  

2. Asphalt Institute, 2008 Asphalt Usage Survey for the United States and Canada,

http://www.asphaltinstitute.org/.  

3. U.S. Department of Transportation, Federal Highway Administration, Highway Statistics 2007,
256 

Office of Highway Policy Information, Washington, DC, 2008. Available at

http://www.fhwa.dot.gov/policyinformation/statistics/2007/.

4. E.H. Pechan & Associates, Inc. “Documentation for the Onroad National Emission Inventory (NEI)

for Base Years 1970 ‐ 2002,” report prepared for U.S. Environmental Protection Agency, Office of

Air Quality Planning and Standards, Research Triangle Park, NC. January 2004.

   
257 

8.56 Asphalt Paving: Emulsified

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  The documentation

below was developed by EPA.

a. Source Category Description

Asphalt paving is the process of applying asphalt concrete to seal or repair the surface of roads, parking

lots, driveways, walkways, or airport runways. Asphalt concrete is a composite material comprised of a

binder and a mineral aggregate. The binder, referred to as asphalt cement, is a byproduct of petroleum

refining and contains the semi‐solid residual material left after the more volatile chemical fractions have

been distilled off.1  

Asphalt cements thinned with water and an emulsifying agent are known as emulsified asphalts. This

thinning reduces the viscosity of the asphalt making it easier to work with the mixture. The primary uses

of emulsified asphalt include tack and seal operations, priming roadbeds, and paving operations for

pavements up to several inches thick.

Emulsified asphalt may contain up to 12 percent organic solvents by volume.1 Emissions from emulsified

asphalt result from the evaporation of VOCs after the mixture is laid down. Compared to cutback asphalt,

emulsified asphalt has lower VOCs emissions per ton used.  

For this source category, the following SCC was assigned:

SCC SCC Level 1 SCC Level 2 SCC Level 3 SCC Level 4

2461022000 Solvent Utilization Miscellaneous Non‐

industrial: Commercial

Emulsified Asphalt Total: All Solvent

Types

The general approach to calculating emissions from emulsified asphalt paving is to multiply the

estimated county‐level emulsified asphalt usage by emission factors for VOCs.

b. Activity Data

State‐level emulsified asphalt usage in 2008 was obtained from the Asphalt Institute’s 2008 Asphalt

Usage Survey.

2 (the EPA used the same activity values for the 2011 as they did for the 2008 NEI due to
258 

limited resources.) State‐level data were allocated to county‐level according to the fraction of paved

road vehicle miles traveled (VMT) in each county.  

Total annual VMT estimates by State and roadway class were obtained from the Federal Highway

Administration’s (FHWA) annual Highway Statistics report.3    Paved road VMT was calculated by

subtracting the State/roadway class unpaved road VMT from total State/roadway class VMT. State‐level

paved road VMT was spatially allocated to counties according to the fraction of total VMT in each

county for the specific roadway class as shown by the following equation:

VMTx,total= ∑VMTST,y*VMTx,y /VMTST,y

where: VMTx,total = VMT (million miles) in county x on all paved roadways

VMTST,y = paved road VMT for the entire State for roadway class y  

VMTx,y = total VMT (million miles) in county x and roadway class y  

VMTST,y = total VMT (million miles) in entire State for roadway class y

The county‐level total VMT by roadway class used in this calculation was previously developed by E.H.

Pechan and Associates, Inc. to support the onroad national emissions inventory.4   

c. Emission Factors

Emission factors for emulsified asphalt usage were obtained from the Technical Report Series produced

by the U.S. EPA’s Emission Inventory Improvement Program and are reported in the corresponding table

below.1

d. Emissions

Emissions were calculated by multiplying the county‐level asphalt usage (barrels) by the emission factors

listed in the corresponding table below and then dividing by 2000 to convert pounds to tons.

Emissionsx,y = (Asphalt Usagex * EFy) / 2000

where:    Emissionsx,y = emissions (tons) of pollutant y in county x

    Asphalt Usagex = emulsified asphalt (barrels) used in county x

    EFy = emission factor for pollutant y
259 

To convert tons of asphalt reported in the 2008 Asphalt Usage Survey to barrels, it was assumed that the

density of asphalt is similar to that of water, 8.34 lbs/gal, and that one barrel equals 42 gallons.

Barrels of Asphalt = (tons of asphalt * 2000 lbs / 8.34 lbs/gal) / 42 gal/barrel

Note that one barrel of asphalt weights approximately 350 pounds.

e. Sample Calculation

VOC emissions from emulsified asphalt usage in Autauga County, Alabama:

From the 2008 Asphalt Usage Survey, the state of Alabama used 18,988 tons of emulsified asphalt in

2008. The fraction of paved road VMT traveled in Autauga County is 497 million miles divided by 53,633

million miles which equals 0.0093.

Asphalt UsageAutauga = ((18,988 tons * 2000 lbs / 8.34 lbs/gal) / 42 gal/barrel) * 0.0093

Asphalt UsageAutauga = 1,004 barrels

VOC EmissionsAutauga = (1,004 barrels * 9.2 lbs/barrel) / 2000 lbs/ton

VOC EmissionsAutauga = 4.62 tons

Criteria Emission Factors for Emulsified Asphalt Paving

Pollutant Description Pollutant Code Emission Factor

(LBS/BARREL)

Emission Factor

Reference

VOLATILE ORGANIC COMPOUNDS VOC 9.2 1

f. References

5. U.S. Environmental Protection Agency, Emissions Inventory Improvement Program, Technical

Report Series, Volume III – Area Sources, Chapter 17, “Asphalt Paving,” prepared by Eastern

Research Group, Inc. for EPA, Research Triangle Park, NC, 2001. Available at

http://www.epa.gov/ttn/chief/eiip/techreport/volume03/index.html.  

6. Asphalt Institute, 2008 Asphalt Usage Survey for the United States and Canada,

http://www.asphaltinstitute.org/.  

7. U.S. Department of Transportation, Federal Highway Administration, Highway Statistics 2007,
260 

Office of Highway Policy Information, Washington, DC, 2008. Available at

http://www.fhwa.dot.gov/policyinformation/statistics/2007/.

8. E.H. Pechan & Associates, Inc. “Documentation for the Onroad National Emission Inventory (NEI)

for Base Years 1970 ‐ 2002,” report prepared for U.S. Environmental Protection Agency, Office of

Air Quality Planning and Standards, Research Triangle Park, NC. January 2004.

   
261 

8.57 Miscellaneous Mercury:  Lamp Breakage, Health, Dental

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  EPA pulled these

estimates forward from previous inventories like the 1999 and 2002 NEI’s.

  

   
262 

8.58 Oil and Gas Production

CenSARA contracted with Environ to survey oil and gas producers to improve emission estimates for

nonpoint oil and gas production.  Environ subcontracted with Transsystems to create the emission

calculation tool and EIS staging tables for states to use in 2011.  The tool is updatable for future years

and improved data sources.

The tool is fully described in the Environ report “2011 Oil and Gas Emission Inventory Enhancement

Project for CenSARA States”, Dec 21, 2012, attached as Appendix B‐4.  It roughly covers: sixteen CAP,

HAP and GHG pollutants for all 115 Missouri counties for 16 SCCs.  Missouri only has oil and gas activity

for five counties, and their emissions of CAP are listed below:

State And County

FIPS Code

County

Name CO NOx PM10‐PRI PM2.5‐PRI SO2 VOC

29005 Atchison 5.536111 3.922423 0.084068 0.084068 0.000827 9.183114

29037 Cass 10.38051 7.3546 0.157627 0.157627 0.001551 21.04987

29095 Jackson 3.460204 2.45154 0.052542 0.052542 0.000517 7.472651

29177 Ray 0.691992 0.490299 0.010508 0.010508 0.000103 0.867738

29217 Vernon 3.391025 2.488806 0.065422 0.065422 1.565628 18.85303

Statewide Total 23.45984 16.70767 0.370168 0.370168 1.568627 57.42641

Missouri has no point source contribution to this category, and the contractor‐provided emissions are

accepted.

Missouri did remove values from the “ControlApproach”, “ControlPollutant”, and “ControlMeasure”

table as these tables were causing an XML schema problem that could not be corrected.  Missouri does

not believe that this removal materially affects the emission report.

   
263 

Table 4 displays the 2011 nonpoint emissions by county for the entire state. Table 5 displays the 

statewide nonpoint emissions by SCC. 

Table 4 Nonpoint Source Emissions by County (tons per year) 

FIPS   County Name   Lead CO   NH3   NOX   PM10

Primary  

PM2.5

Primary   SO2   VOC  

29001    Adair   0.00 525 372 57 4,642 693 4 422

29003    Andrew   0.00 336 457 28 4,804 684 2 451

29005    Atchison   0.00 141 896 18 4,588 768 1 474

29007    Audrain   0.00 451 1,590 61 9,225 1,594 4 664

29009    Barry   0.00 980 5,093 127 8,857 1,110 12 614

29011    Barton   0.00 250 1,711 31 5,731 950 2 389

29013    Bates   0.00 395 1,876 37 7,362 1,141 2 506

29015    Benton   0.00 481 1,168 34 5,960 769 3 398

29017    Bollinger   0.00 323 255 22 5,177 710 2 208

29019    Boone   0.00 2,419 537 313 12,053 1,742 15 2,427

29021    Buchanan   0.00 1,278 561 290 5,493 894 21 1,445

29023    Butler   0.00 1,055 1,309 101 9,865 1,437 10 902

29025    Caldwell   0.00 249 547 20 5,228 792 2 241

29027    Callaway   0.00 1,026 1,048 99 10,890 1,483 16 945

29029    Camden   0.00 1,241 285 78 10,874 1,346 6 786

29031    Cape Girardeau   0.00 1,944 916 194 10,724 1,593 11 1,370

29033    Carroll   0.00 186 972 24 7,575 1,361 1 385

29035    Carter   0.00 187 73 13 2,095 259 1 141

29037    Cass   0.00 1,960 1,336 189 13,059 1,840 13 1,563

29039    Cedar   0.00 330 597 29 3,601 450 2 240

29041    Chariton   0.00 195 1,072 17 9,126 1,620 1 374

29043    Christian   0.00 2,310 502 148 12,755 1,669 9 1,268

29045    Clark   0.00 196 542 17 5,741 961 1 270

29047    Clay   0.00 3,418 285 515 8,968 1,581 27 2,725

29049    Clinton   0.00 462 1,214 40 6,151 822 3 457

29051    Cole   0.00 1,871 824 174 8,828 1,257 14 1,130

29053    Cooper   0.00 357 1,336 36 4,474 666 2 527

29055    Crawford   0.00 687 235 68 6,051 752 7 674

29057    Dade   0.00 200 794 17 3,688 530 1 223

29059    Dallas   0.00 382 720 28 4,504 546 2 263

29061    Daviess   0.00 192 1,480 17 4,654 706 2 344

29063    DeKalb   0.00 209 495 19 3,624 519 1 299

29065    Dent   0.00 368 203 31 3,597 453 4 235

29067    Douglas   0.00 316 405 30 3,549 436 3 236

29069    Dunklin   0.00 579 1,629 70 11,681 1,941 3 1,018

29071    Franklin   0.00 2,599 1,265 227 20,294 2,664 37 1,469

29073    Gasconade   0.00 383 516 40 4,348 560 5 427

29075    Gentry   0.00 161 1,497 17 3,513 525 1 212

29077    Greene   0.00 4,172 700 672 17,584 2,515 32 4,064

29079   Grundy   0.00 203 612 28 3,549 597 2 265
264 

FIPS   County Name   Lead CO   NH3   NOX   PM10

Primary  

PM2.5

Primary   SO2   VOC  

29081    Harrison   0.00 189 879 21 4,729 786 1 344

29083    Henry   0.00 504 1,015 59 6,421 1,017 6 644

29085    Hickory   0.00 252 263 17 3,189 388 1 172

29087    Holt   0.00 105 596 12 4,693 806 1 371

29089    Howard   0.00 211 421 22 3,463 532 2 250

29091    Howell   0.00 1,031 759 105 9,658 1,194 13 661

29093    Iron   0.99 267 88 19 2,695 336 1 153

29095    Jackson   0.01 10,472 496 1,811 17,064 3,640 90 9,159

29097    Jasper   0.00 2,230 1,551 334 12,303 1,846 22 1,978

29099    Jefferson   0.00 5,537 175 369 24,220 3,284 35 3,158

29101    Johnson   0.00 976 1,496 100 10,515 1,444 19 893

29103    Knox   0.00 103 653 9 3,264 538 1 243

29105    Laclede   0.00 918 739 103 7,425 950 11 787

29107    Lafayette   0.00 691 1,776 73 8,988 1,327 5 909

29109    Lawrence   0.00 751 2,535 79 7,844 1,003 6 666

29111    Lewis   0.00 248 664 24 5,329 798 2 314

29113    Lincoln   0.00 1,233 863 89 15,713 2,113 16 909

29115    Linn   0.00 271 569 38 4,363 663 3 318

29117    Livingston   0.00 299 556 37 5,979 1,062 2 397

29119    McDonald   0.00 709 2,673 79 7,652 928 10 413

29121    Macon   0.00 345 1,162 35 6,057 945 2 384

29123    Madison   0.00 408 299 26 2,743 351 2 209

29125    Maries   0.00 242 517 17 3,192 399 2 168

29127    Marion   0.00 556 1,561 75 6,171 1,084 4 648

29129    Mercer   0.00 88 364 8 2,223 344 1 121

29131    Miller   0.00 683 2,436 45 6,707 837 4 434

29133    Mississippi   0.00 263 1,636 29 6,916 1,273 1 512

29135    Moniteau   0.00 293 1,996 32 3,544 502 2 392

29137    Monroe   0.00 245 1,163 21 5,320 829 2 319

29139    Montgomery   0.00 324 858 27 4,707 694 2 479

29141    Morgan   0.00 516 2,682 38 6,858 834 3 371

29143    New Madrid   0.00 391 2,936 53 14,357 2,608 4 955

29145    Newton   0.00 1,373 3,906 139 12,812 1,617 11 960

29147    Nodaway   0.00 408 1,466 62 6,438 1,040 6 689

29149    Oregon   0.00 261 353 21 2,905 359 2 200

29151    Osage   0.00 334 1,775 34 4,998 638 7 271

29153    Ozark   0.00 261 415 20 3,182 386 2 380

29155    Pemiscot   0.00 332 1,873 48 9,011 1,578 3 827

29157    Perry   0.00 498 589 71 4,830 700 8 447

29159    Pettis   0.00 869 2,756 133 7,993 1,227 15 827

29161    Phelps   0.00 1,097 263 85 7,190 933 7 878

29163    Pike   0.00 364 2,194 38 6,568 1,067 3 506

29165    Platte   0.00 1,422 639 194 6,528 1,054 10 1,566

29167    Polk   0.00 690 1,802 51 7,287 907 4 521
265 

FIPS   County Name   Lead CO   NH3   NOX   PM10

Primary  

PM2.5

Primary   SO2   VOC  

29169   Pulaski   0.00 1,198 511 72 7,971 1,024 5 693

29171    Putnam   0.00 140 903 13 2,261 322 1 150

29173    Ralls   0.00 249 591 43 5,686 877 7 443

29175    Randolph   0.00 466 507 58 5,500 820 4 485

29177    Ray   0.00 508 625 50 8,992 1,336 3 458

29179    Reynolds   0.58 170 70 13 2,232 271 1 161

29181    Ripley   0.00 374 633 31 5,092 651 3 228

29183    St. Charles   0.00 4,727 900 627 14,500 2,598 34 4,792

29185    St. Clair   0.00 231 478 20 5,056 758 2 296

29186    Ste. Genevieve   0.00 521 829 49 5,078 659 5 404

29187    St. Francois   0.00 1,703 405 127 9,144 1,205 11 941

29189    St. Louis   0.01 14,585 718 2,681 24,594 5,315 142 16,228

29195    Saline   0.00 445 1,912 74 10,246 1,792 5 671

29197    Schuyler   0.00 109 261 8 1,910 265 1 112

29199    Scotland   0.00 119 702 12 3,703 612 1 212

29201    Scott   0.00 727 3,095 96 8,912 1,395 6 864

29203    Shannon   0.00 210 155 18 2,738 329 2 186

29205    Shelby   0.00 193 1,330 17 6,172 1,065 1 336

29207    Stoddard   0.00 746 4,368 93 14,529 2,376 12 1,101

29209    Stone   0.00 1,122 431 62 9,719 1,189 4 548

29211    Sullivan   0.00 176 3,276 31 2,745 376 3 161

29213    Taney   0.00 2,864 113 137 9,701 1,352 10 920

29215    Texas   0.00 667 889 51 8,436 1,016 5 560

29217    Vernon   0.00 438 3,931 54 8,342 1,367 5 589

29219    Warren   0.00 953 648 57 8,485 1,183 5 664

29221    Washington   0.00 571 185 38 6,525 783 4 370

29223    Wayne   0.00 343 147 28 4,596 565 2 257

29225    Webster   0.00 870 1,087 62 9,109 1,136 6 698

29227    Worth   0.00 53 253 5 1,265 194 0 101

29229    Wright   0.00 443 2,031 38 4,860 607 3 353

29510    St. Louis city   0.00 4,955 148 1,062 4,920 1,429 52 5,095
266 

Table 5 Nonpoint Source Emissions by SCC (tons per year) 

SCC SCC Level One SCC Level Two SCC Level Three SCC Level Four Lead CO NH3 NOX

P

2302002200

IndustrialProcesses

Food and Kindred

Products: SIC 20

Commercial Cooking‐ Charbroiling

Under‐fired

Charbroiling 404 

2302003100

IndustrialProcesses

Food and Kindred

Products: SIC 20

Commercial Cooking‐ Frying Flat Griddle Frying 38 

2302002100

IndustrialProcesses

Food and Kindred

Products: SIC 20

Commercial Cooking‐ Charbroiling

Conveyorized

Charbroiling 127 

2103008000

Stationary

Source Fuel

Combustion

Commercial/Institutional Wood Total: All Boiler Types 840 7 308 

2302003200

IndustrialProcesses

Food and Kindred

Products: SIC 20

Commercial Cooking‐ Frying

Clamshell GriddleFrying 

2102008000

Stationary

Source Fuel

Combustion Industrial Wood Total: All Boiler Types 667 8 244 

2104006000

Stationary

Source Fuel

Combustion Residential Natural Gas

Total: All Combustor

Types 2,148 1,074 5,047 

2103006000

Stationary

Source Fuel

Combustion

Commercial/Institutional Natural Gas

Total: Boilers and ICEngines 0.01 2,185 13 2,601 

2102006000

Stationary

Source Fuel

Combustion Industrial Natural Gas

Total: Boilers and ICEngines 0.01 994 38 1,183 

2104007000

Stationary

Source Fuel

Combustion Residential

Liquified Petroleum

Gas (LPG)

Total: All Combustor

Types 389 5 1,370 

2102004001

Stationary

Source Fuel

Combustion Industrial Distillate Oil All Boiler Types 0.00 7 1 30 
267 

SCC SCC Level One SCC Level Two SCC Level Three SCC Level Four Lead CO NH3 NOX

P

2102004002

Stationary

Source Fuel

Combustion Industrial Distillate Oil All IC Engine Types 0.00 193 0 896 

2104004000

Stationary

Source Fuel

Combustion Residential Distillate Oil

Total: All Combustor

Types 0.00 3 1 12 

2104011000

Stationary

Source Fuel

Combustion Residential Kerosene

Total: All Heater

Types 0.00 3 1 12 

2102005000

Stationary

Source Fuel

Combustion Industrial Residual Oil Total: All Boiler Types 0.00 2 0 25 

2103004001

Stationary

Source Fuel

Combustion

Commercial/Institutional Distillate Oil Boilers 0.00 1 0 5 

2103004002

Stationary

Source Fuel

Combustion

Commercial/Institutional Distillate Oil IC Engines 0.01 35 0 164 

2102011000

Stationary

Source Fuel

Combustion Industrial Kerosene Total: All Boiler Types 0.00 1 0 3 

2103011000

Stationary

Source Fuel

Combustion

Commercial/Institutional Kerosene

Total: All Combustor

Types 0.00 0 0 2 

2103005000

Stationary

Source Fuel

Combustion

Commercial/Institutional Residual Oil Total: All Boiler Types 0.00 0 0 4 

2102007000

Stationary

Source Fuel

Combustion Industrial

Liquified Petroleum

Gas (LPG) Total: All Boiler Types 31 1 56 
268 

SCC SCC Level One SCC Level Two SCC Level Three SCC Level Four Lead CO NH3 NOX

P

2103007000

Stationary

Source Fuel

Combustion

Commercial/Institutional

Liquified PetroleumGas (LPG)

Total: All Combustor

Types 0.00 17 0 30 

2102001000

Stationary

Source Fuel

Combustion Industrial Anthracite Coal Total: All Boiler Types ‐   ‐   ‐   ‐     

2102002000

Stationary

Source Fuel

Combustion Industrial

Bituminous/Subbituminous Coal Total: All Boiler Types ‐   ‐   ‐   ‐     

2103001000

Stationary

Source Fuel

Combustion

Commercial/Institutional Anthracite Coal Total: All Boiler Types ‐   ‐   ‐   ‐     

2103002000

Stationary

Source Fuel

Combustion

Commercial/Institutional

Bituminous/Subbituminous Coal Total: All Boiler Types ‐   ‐   ‐   ‐     

2104001000

Stationary

Source Fuel

Combustion Residential Anthracite Coal

Total: All Combustor

Types ‐   ‐   ‐     

2104002000

Stationary

Source Fuel

Combustion Residential

Bituminous/Subbituminous Coal

Total: All Combustor

Types ‐   ‐   ‐     

2104005000

Stationary

Source Fuel

Combustion Residential Residual Oil

Total: All Combustor

Types ‐   ‐   ‐   ‐     

2104008100

Stationary

Source Fuel

Combustion Residential Wood Fireplace: general 27,657 334 483 

2104008210

Stationary

Source Fuel

Combustion Residential Wood

Woodstove: fireplace

inserts; non‐EPA

certified 20,347 150 247 
269 

SCC SCC Level One SCC Level Two SCC Level Three SCC Level Four Lead CO NH3 NOX

P

2104008220

Stationary

Source Fuel

Combustion Residential Wood

Woodstove: fireplace

inserts; EPA certified;

non‐catalytic 3,959 25 64 

2104008230

Stationary

Source Fuel

Combustion Residential Wood

Woodstove: fireplace

inserts; EPA certified;

catalytic 979 8 19 

2104008310

Stationary

Source Fuel

Combustion Residential Wood

Woodstove:freestanding, non‐

EPA certified 18,633 137 226 

2104008320

Stationary

Source Fuel

Combustion Residential Wood

Woodstove:freestanding, EPA

certified, non‐

catalytic 3,627 23 59 

2104008330

Stationary

Source Fuel

Combustion Residential Wood

Woodstove:freestanding, EPA

certified, catalytic 896 8 17 

2104008400

Stationary

Source Fuel

Combustion Residential Wood

Woodstove: pellet‐fired, general

(freestanding or FP

insert) 222 4 53 

2104008510

Stationary

Source Fuel

Combustion Residential Wood

Furnace: Indoor,cordwood‐fired, non‐EPA certified 2,445 24 25 

2104008610

Stationary

Source Fuel

Combustion Residential Wood

Hydronic heater:

outdoor 6,062 30 31 

2104008700

Stationary

Source Fuel

Combustion Residential Wood

Outdoor wood

burning device, NEC

(fire‐pits, chimeas,

etc) 88 1 2 
270 

SCC SCC Level One SCC Level Two SCC Level Three SCC Level Four Lead CO NH3 NOX

P

2104009000

Stationary

Source Fuel

Combustion Residential Firelog

Total: All Combustor

Types 596 37 

2294000000

MobileSources Paved Roads All Paved Roads Total: Fugitives 

2296000000

MobileSources Unpaved Roads All Unpaved Roads Total: Fugitives 5

2302003000

IndustrialProcesses

Food and Kindred

Products: SIC 20

Commercial Cooking‐ Frying Deep Fat Fying 

2306000000

IndustrialProcesses

PetroleumRefining: SIC 29 All Processes Total 0.00 499 214 

2310000220

IndustrialProcesses

Oil and Gas

Exploration and

Production All Processes Drill Rigs ‐   ‐     

2310000330

IndustrialProcesses

Oil and Gas

Exploration and

Production All Processes Artificial Lift 21 13 

2310000550

IndustrialProcesses

Oil and Gas

Exploration and

Production All Processes Produced Water 

2310000660

IndustrialProcesses

Oil and Gas

Exploration and

Production All Processes

Hydraulic Fracturing

Engines ‐   ‐     

2310010100

IndustrialProcesses

Oil and Gas

Exploration and

Production Crude Petroleum Oil Well Heaters 3 3 

2310010200

IndustrialProcesses

Oil and Gas

Exploration and

Production Crude Petroleum

Oil Well Tanks ‐ 

Flashing &Standing/Working/Breathing 0 0 
271 

SCC SCC Level One SCC Level Two SCC Level Three SCC Level Four Lead CO NH3 NOX

P

2310010300

IndustrialProcesses

Oil and Gas

Exploration and

Production Crude Petroleum

Oil Well Pneumatic

Devices 

2310011000

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Oil

Production Total: All Processes 0 0 

2310011201

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Oil

Production

Tank Truck/RailcarLoading: Crude Oil 

2310011501

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Oil

Production Fugitives: Connectors 

2310011502

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Oil

Production Fugitives: Flanges 

2310011503

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Oil

Production

Fugitives: Open

Ended Lines 

2310011505

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Oil

Production Fugitives: Valves 

2310021010

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Gas

Production

Storage Tanks:

Condensate ‐   ‐   

2310021030

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Gas

Production

Tank Truck/Railcar

Loading: Condensate 

2310021100

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Gas

Production Gas Well Heaters ‐   ‐     
272 

SCC SCC Level One SCC Level Two SCC Level Three SCC Level Four Lead CO NH3 NOX

P

2310021202

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Gas

Production

Natural Gas Fired

4Cycle Lean BurnCompressor Engines

50 To 499 HP ‐   ‐     

2310021209

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Gas

Production

Total: All Natural Gas

Fired 4Cycle Lean

Burn Compressor

Engines ‐   ‐     

2310021251

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Gas

Production

Lateral Compressors

4 Cycle Lean Burn ‐   ‐     

2310021300

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Gas

Production

Gas Well Pneumatic

Devices 

2310021302

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Gas

Production

Natural Gas Fired

4Cycle Rich Burn

Compressor Engines

50 To 499 HP ‐   ‐     

2310021309

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Gas

Production

Total: All Natural Gas

Fired 4Cycle Rich

Burn CompressorEngines ‐   ‐     

2310021351

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Gas

Production

Lateral Compressors

4 Cycle Rich Burn ‐   ‐     

2310021400

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Gas

Production Gas Well Dehydrators ‐   ‐     

2310021501

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Gas

Production Fugitives: Connectors 
273 

SCC SCC Level One SCC Level Two SCC Level Three SCC Level Four Lead CO NH3 NOX

P

2310021502

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Gas

Production Fugitives: Flanges 

2310021503

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Gas

Production

Fugitives: OpenEnded Lines 

2310021505

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Gas

Production Fugitives: Valves 

2310021506

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Gas

Production Fugitives: Other 

2310021603

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Gas

Production

Gas Well Venting ‐ Blowdowns ‐   ‐   

2310111100

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Oil

Exploration Mud Degassing 

2310111401

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Oil

Exploration

Oil Well Pneumatic

Pumps 

2310111700

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Oil

Exploration

Oil Well Completion:

All Processes ‐   ‐   

2310121100

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Gas

Exploration Mud Degassing 

2310121401

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Gas

Exploration

Gas Well Pneumatic

Pumps 
274 

SCC SCC Level One SCC Level Two SCC Level Three SCC Level Four Lead CO NH3 NOX

P

2310121700

IndustrialProcesses

Oil and Gas

Exploration and

Production

On‐Shore Gas

Exploration

Gas Well Completion:All Processes ‐   ‐   

2311010000

IndustrialProcesses

Construction: SIC

15 ‐ 17 Residential Total 

2311020000

IndustrialProcesses

Construction: SIC

15 ‐ 17

Industrial/Commercial/Institutional Total 

2311030000

IndustrialProcesses

Construction: SIC

15 ‐ 17 Road Construction Total 

2325000000

IndustrialProcesses

Mining andQuarrying: SIC 14 All Processes Total 

2325060000

IndustrialProcesses

Mining andQuarrying: SIC 10

Lead Ore Mining and

Milling Total 1.57

2401001000

Solvent

Utilization Surface Coating

Architectural

Coatings

Total: All Solvent

Types 

2401005000

Solvent

Utilization Surface Coating

Auto Refinishing: SIC

7532

Total: All Solvent

Types 

2401008000

Solvent

Utilization Surface Coating Traffic Markings

Total: All Solvent

Types 

2401015000

Solvent

Utilization Surface Coating

Factory Finished

Wood: SIC 2426 thru

242

Total: All Solvent

Types 

2401020000

Solvent

Utilization Surface Coating

Wood Furniture: SIC

25

Total: All Solvent

Types 

2401025000

Solvent

Utilization Surface Coating

Metal Furniture: SIC

25

Total: All Solvent

Types 

2401030000

Solvent

Utilization Surface Coating Paper: SIC 26

Total: All Solvent

Types 

2401040000

Solvent

Utilization Surface Coating Metal Cans: SIC 341

Total: All Solvent

Types 

2401055000

Solvent

Utilization Surface Coating

Machinery and

Equipment: SIC 35

Total: All Solvent

Types 
275 

SCC SCC Level One SCC Level Two SCC Level Three SCC Level Four Lead CO NH3 NOX

P

2401060000

Solvent

Utilization Surface Coating

Large Appliances: SIC363

Total: All Solvent

Types 

2401065000

Solvent

Utilization Surface Coating

Electronic and Other

Electrical: SIC 36 ‐ 

363

Total: All Solvent

Types 

2401070000

Solvent

Utilization Surface Coating

Motor Vehicles: SIC

371

Total: All Solvent

Types 

2401075000

Solvent

Utilization Surface Coating Aircraft: SIC 372

Total: All Solvent

Types 

2401080000

Solvent

Utilization Surface Coating Marine: SIC 373

Total: All Solvent

Types 

2401085000

Solvent

Utilization Surface Coating Railroad: SIC 374

Total: All Solvent

Types 

2401090000

Solvent

Utilization Surface Coating

Miscellaneous

Manufacturing

Total: All Solvent

Types 

2401100000

Solvent

Utilization Surface Coating

IndustrialMaintenanceCoatings

Total: All Solvent

Types 

2401200000

Solvent

Utilization Surface Coating

Other Special

Purpose Coatings

Total: All Solvent

Types 

2415000000

Solvent

Utilization Degreasing

All Processes/All

Industries

Total: All Solvent

Types 

2420000000

Solvent

Utilization Dry Cleaning All Processes

Total: All Solvent

Types 

2425000000

Solvent

Utilization Graphic Arts All Processes

Total: All Solvent

Types 

2460100000

Solvent

Utilization

MiscellaneousNon‐industrial:

Consumer and

Commercial

All Personal CareProducts

Total: All Solvent

Types 
276 

SCC SCC Level One SCC Level Two SCC Level Three SCC Level Four Lead CO NH3 NOX

P

2460200000

Solvent

Utilization

MiscellaneousNon‐industrial:

Consumer and

Commercial

All HouseholdProducts

Total: All Solvent

Types 

2460400000

Solvent

Utilization

MiscellaneousNon‐industrial:

Consumer and

Commercial

All AutomotiveAftermarket Products

Total: All Solvent

Types 

2460500000

Solvent

Utilization

MiscellaneousNon‐industrial:

Consumer and

Commercial

All Coatings andRelated Products

Total: All Solvent

Types 

2460600000

Solvent

Utilization

MiscellaneousNon‐industrial:

Consumer and

Commercial

All Adhesives and

Sealants

Total: All Solvent

Types 

2460800000

Solvent

Utilization

MiscellaneousNon‐industrial:

Consumer and

Commercial

All FIFRA RelatedProducts

Total: All Solvent

Types 

2460900000

Solvent

Utilization

MiscellaneousNon‐industrial:

Consumer and

Commercial

MiscellaneousProducts (NotOtherwise Covered)

Total: All Solvent

Types 

2461021000

Solvent

Utilization

MiscellaneousNon‐industrial:

Commercial Cutback Asphalt

Total: All Solvent

Types 

2461022000

Solvent

Utilization

MiscellaneousNon‐industrial:

Commercial Emulsified Asphalt

Total: All Solvent

Types 
277 

SCC SCC Level One SCC Level Two SCC Level Three SCC Level Four Lead CO NH3 NOX

P

2461850001

Solvent

Utilization

MiscellaneousNon‐industrial:

Commercial

Pesticide Application:Agricultural Herbicides, Corn 

2461850002

Solvent

Utilization

MiscellaneousNon‐industrial:

Commercial

Pesticide Application:Agricultural Herbicides, Apples 

2461850003

Solvent

Utilization

MiscellaneousNon‐industrial:

Commercial

Pesticide Application:Agricultural Herbicides, Grapes 

2461850004

Solvent

Utilization

MiscellaneousNon‐industrial:

Commercial

Pesticide Application:Agricultural Herbicides, Potatoes 

2461850005

Solvent

Utilization

MiscellaneousNon‐industrial:

Commercial

Pesticide Application:Agricultural Herbicides, Soy Beans 

2461850006

Solvent

Utilization

MiscellaneousNon‐industrial:

Commercial

Pesticide Application:Agricultural

Herbicides, Hay &

Grains 

2461850009

Solvent

Utilization

MiscellaneousNon‐industrial:

Commercial

Pesticide Application:Agricultural

Herbicides, Not

Elsewhere Classified 

2461850051

Solvent

Utilization

MiscellaneousNon‐industrial:

Commercial

Pesticide Application:Agricultural

Other Pesticides,Corn 

2461850052

Solvent

Utilization

MiscellaneousNon‐industrial:

Commercial

Pesticide Application:Agricultural

Other Pesticides,Apples 

2461850053

Solvent

Utilization

MiscellaneousNon‐industrial:

Commercial

Pesticide Application:Agricultural

Other Pesticides,Grapes 
278 

SCC SCC Level One SCC Level Two SCC Level Three SCC Level Four Lead CO NH3 NOX

P

2461850054

Solvent

Utilization

MiscellaneousNon‐industrial:

Commercial

Pesticide Application:Agricultural

Other Pesticides,Potatoes 

2461850055

Solvent

Utilization

MiscellaneousNon‐industrial:

Commercial

Pesticide Application:Agricultural

Other Pesticides, Soy

Beans 

2461850056

Solvent

Utilization

MiscellaneousNon‐industrial:

Commercial

Pesticide Application:Agricultural

Other Pesticides, Hay& Grains 

2461850099

Solvent

Utilization

MiscellaneousNon‐industrial:

Commercial

Pesticide Application:Agricultural

Other Pesticides, NotElsewhere Classified 

2501011011

Storage and

Transport

Petroleum and

PetroleumProduct Storage

Residential Portable

Gas Cans Permeation 

2501011012

Storage and

Transport

Petroleum and

PetroleumProduct Storage

Residential Portable

Gas Cans

Evaporation (includes

Diurnal losses) 

2501011013

Storage and

Transport

Petroleum and

PetroleumProduct Storage

Residential Portable

Gas Cans

Spillage DuringTransport 

2501011014

Storage and

Transport

Petroleum and

PetroleumProduct Storage

Residential Portable

Gas Cans

Refilling at the Pump

‐ Vapor Displacement 

2501011015

Storage and

Transport

Petroleum and

PetroleumProduct Storage

Residential Portable

Gas Cans

Refilling at the Pump

‐ Spillage 

2501012011

Storage and

Transport

Petroleum and

PetroleumProduct Storage

Commercial Portable

Gas Cans Permeation 
279 

SCC SCC Level One SCC Level Two SCC Level Three SCC Level Four Lead CO NH3 NOX

P

2501012012

Storage and

Transport

Petroleum and

PetroleumProduct Storage

Commercial Portable

Gas Cans

Evaporation (includes

Diurnal losses) 

2501012013

Storage and

Transport

Petroleum and

PetroleumProduct Storage

Commercial Portable

Gas Cans

Spillage DuringTransport 

2501012014

Storage and

Transport

Petroleum and

PetroleumProduct Storage

Commercial Portable

Gas Cans

Refilling at the Pump

‐ Vapor Displacement 

2501012015

Storage and

Transport

Petroleum and

PetroleumProduct Storage

Commercial Portable

Gas Cans

Refilling at the Pump

‐ Spillage 

2501050120

Storage and

Transport

Petroleum and

PetroleumProduct Storage

Bulk Terminals: All

Evaporative Losses Gasoline 

2501055120

Storage and

Transport

Petroleum and

PetroleumProduct Storage

Bulk Plants: All

Evaporative Losses Gasoline 

2501060051

Storage and

Transport

Petroleum and

PetroleumProduct Storage

Gasoline ServiceStations

Stage 1: Submerged

Filling 

2501060052

Storage and

Transport

Petroleum and

PetroleumProduct Storage

Gasoline ServiceStations Stage 1: Splash Filling 

2501060053

Storage and

Transport

Petroleum and

PetroleumProduct Storage

Gasoline ServiceStations

Stage 1: Balanced

Submerged Filling 

2501060101

Storage and

Transport

Petroleum and

PetroleumProduct Storage

Gasoline ServiceStations

Stage 2:

DisplacementLoss/Uncontrolled 
280 

SCC SCC Level One SCC Level Two SCC Level Three SCC Level Four Lead CO NH3 NOX

P

2501060102

Storage and

Transport

Petroleum and

PetroleumProduct Storage

Gasoline ServiceStations

Stage 2:

DisplacementLoss/Controlled 

2501060103

Storage and

Transport

Petroleum and

PetroleumProduct Storage

Gasoline ServiceStations Stage 2: Spillage 

2501060201

Storage and

Transport

Petroleum and

PetroleumProduct Storage

Gasoline ServiceStations

Underground Tank:

Breathing and

Emptying 

2501070100

Storage and

Transport

Petroleum and

PetroleumProduct Storage

Diesel ServiceStations Stage 2: Total 

2501080050

Storage and

Transport

Petroleum and

PetroleumProduct Storage

Airports : Aviation

Gasoline Stage 1: Total 0.01 

2501080100

Storage and

Transport

Petroleum and

PetroleumProduct Storage

Airports : Aviation

Gasoline Stage 2: Total 0.00 

2505030120

Storage and

Transport

Petroleum and

PetroleumProductTransport Truck Gasoline 

2505040120

Storage and

Transport

Petroleum and

PetroleumProductTransport Pipeline Gasoline 

2610000100

Waste

Disposal,Treatment,

and Recovery Open Burning All Categories

Yard Waste ‐ LeafSpecies Unspecified 327 18 
281 

SCC SCC Level One SCC Level Two SCC Level Three SCC Level Four Lead CO NH3 NOX

P

2610000400

Waste

Disposal,Treatment,

and Recovery Open Burning All Categories

Yard Waste ‐ BrushSpecies Unspecified 409 15 

2610000500

Waste

Disposal,Treatment,

and Recovery Open Burning All Categories

Land Clearing Debris

(use 28‐10‐005‐000

for Logging DebrisBurning) 13,555 401 

2610030000

Waste

Disposal,Treatment,

and Recovery Open Burning Residential

Household Waste

(use 26‐10‐000‐xxx

for Yard Wastes) 6,734 475 

2630020000

Waste

Disposal,Treatment,

and Recovery

WastewaterTreatment Public Owned Total Processed 16 

2801000003

MiscellaneousArea Sources

AgricultureProduction ‐ Crops Agriculture ‐ Crops Tilling 

2801700001

MiscellaneousArea Sources

AgricultureProduction ‐ Crops Fertilizer Application Anhydrous Ammonia 7,335

2801700002

MiscellaneousArea Sources

AgricultureProduction ‐ Crops Fertilizer Application Aqueous Ammonia ‐  

2801700003

MiscellaneousArea Sources

AgricultureProduction ‐ Crops Fertilizer Application Nitrogen Solutions 5,974

2801700004

MiscellaneousArea Sources

AgricultureProduction ‐ Crops Fertilizer Application Urea 20,775
282 

SCC SCC Level One SCC Level Two SCC Level Three SCC Level Four Lead CO NH3 NOX

P

2801700005

MiscellaneousArea Sources

AgricultureProduction ‐ Crops Fertilizer Application Ammonium Nitrate 1,208

2801700006

MiscellaneousArea Sources

AgricultureProduction ‐ Crops Fertilizer Application Ammonium Sulfate 979

2801700007

MiscellaneousArea Sources

AgricultureProduction ‐ Crops Fertilizer Application

Ammonium

Thiosulfate 38

2801700010

MiscellaneousArea Sources

AgricultureProduction ‐ Crops Fertilizer Application

N‐P‐K (multi‐grade

nutrient fertilizers) 309

2801700011

MiscellaneousArea Sources

AgricultureProduction ‐ Crops Fertilizer Application

Calcium Ammonium

Nitrate 0

2801700012

MiscellaneousArea Sources

AgricultureProduction ‐ Crops Fertilizer Application Potassium Nitrate ‐  

2801700013

MiscellaneousArea Sources

AgricultureProduction ‐ Crops Fertilizer Application

DiammoniumPhosphate 2,362

2801700014

MiscellaneousArea Sources

AgricultureProduction ‐ Crops Fertilizer Application

MonoammoniumPhosphate 658

2801700015

MiscellaneousArea Sources

AgricultureProduction ‐ Crops Fertilizer Application

Liquid AmmoniumPolyphosphate 80

2801700099

MiscellaneousArea Sources

AgricultureProduction ‐ Crops Fertilizer Application

Miscellaneous

Fertilizers 3,353
283 

SCC SCC Level One SCC Level Two SCC Level Three SCC Level Four Lead CO NH3 NOX

P

2805001100

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Beef cattle ‐  finishingoperations on

feedlots (drylots) Confinement 1,009

2805001200

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Beef cattle ‐  finishingoperations on

feedlots (drylots)

Manure handling and

storage 0

2805001300

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Beef cattle ‐  finishingoperations on

feedlots (drylots)

Land application of

manure 767

2805002000

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Beef cattle

productioncomposite

Not Elsewhere

Classified 10,939

2805003100

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Beef cattle ‐  finishingoperations on

pasture/range Confinement 9,665

2805007100

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Poultry production ‐ 

layers with drymanure managementsystems Confinement 3,206

2805007300

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Poultry production ‐ 

layers with drymanure managementsystems

Land application of

manure 74

2805009100

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Poultry production ‐ 

broilers Confinement 5,110

2805009200

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Poultry production ‐ 

broilers

Manure handling and

storage 929

2805009300

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Poultry production ‐ 

broilers

Land application of

manure 4,181
284 

SCC SCC Level One SCC Level Two SCC Level Three SCC Level Four Lead CO NH3 NOX

P

2805010100

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Poultry production ‐ 

turkeys Confinement 4,286

2805010200

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Poultry production ‐ 

turkeys

Manure handling and

storage 771

2805010300

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Poultry production ‐ 

turkeys

Land application of

manure 3,854

2805018000

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Dairy cattle

composite

Not Elsewhere

Classified 1,259

2805019100

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Dairy cattle ‐ flush

dairy Confinement 26

2805019200

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Dairy cattle ‐ flush

dairy

Manure handling and

storage 74

2805019300

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Dairy cattle ‐ flush

dairy

Land application of

manure 7

2805021100

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Dairy cattle ‐ scrape

dairy Confinement 686

2805021200

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Dairy cattle ‐ scrape

dairy

Manure handling and

storage 930

2805021300

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Dairy cattle ‐ scrape

dairy

Land application of

manure 1,154
285 

SCC SCC Level One SCC Level Two SCC Level Three SCC Level Four Lead CO NH3 NOX

P

2805022100

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Dairy cattle ‐ deep pit

dairy Confinement 100

2805022200

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Dairy cattle ‐ deep pit

dairy

Manure handling and

storage 5

2805022300

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Dairy cattle ‐ deep pit

dairy

Land application of

manure 58

2805023100

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Dairy cattle ‐ 

drylot/pasture dairy Confinement 458

2805023200

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Dairy cattle ‐ 

drylot/pasture dairy

Manure handling and

storage 8

2805023300

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Dairy cattle ‐ 

drylot/pasture dairy

Land application of

manure 611

2805030000

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Poultry WasteEmissions

Not Elsewhere

Classified (see also28‐05‐007, ‐008, ‐

009) 710

2805030007

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Poultry WasteEmissions Ducks 20

2805030008

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Poultry WasteEmissions Geese 6

2805035000

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Horses and Ponies

Waste Emissions

Not Elsewhere

Classified 2,005
286 

SCC SCC Level One SCC Level Two SCC Level Three SCC Level Four Lead CO NH3 NOX

P

2805039100

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Swine production ‐ 

operations with

lagoons (unspecifiedanimal age) Confinement 7,739

2805039200

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Swine production ‐ 

operations with

lagoons (unspecifiedanimal age)

Manure handling and

storage 14,188

2805039300

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Swine production ‐ 

operations with

lagoons (unspecifiedanimal age)

Land application of

manure 1,210

2805040000

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Sheep and Lambs

Waste Emissions Total 269

2805045000

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Goats Waste

Emissions

Not ElsewhereClassified 672

2805047100

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Swine production ‐ 

deep‐pit houseoperations(unspecified animalage) Confinement 1,735

2805047300

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Swine production ‐ 

deep‐pit houseoperations(unspecified animalage)

Land application of

manure 726

2805053100

MiscellaneousArea Sources

AgricultureProduction ‐ Livestock

Swine production ‐ 

outdoor operations

(unspecified animalage) Confinement 35
287 

SCC SCC Level One SCC Level Two SCC Level Three SCC Level Four Lead CO NH3 NOX

P

2810060100

MiscellaneousArea Sources

OtherCombustion Cremation Humans 0.01 1 2 

2810060200

MiscellaneousArea Sources

OtherCombustion Cremation Animals 4 5 
288 

9.0 Mobile Source Inventory

9.1 Onroad Inventory

EPA’s MOVES model, version 2010b, was used to estimate total annual onroad emissions by county for

Missouri.  The 115 Missouri MOVES county input databases were updated with local activity data. These

updates more accurately reflect Missouri emissions than the default data in the 2011 County Databases

provided by EPA.  The Air Program updated the following Input Tables:

• hpmsvtypeyear: this table was updated for all 115 counties. VMT by county for the State of

Missouri was provided by MoDOT.  Area‐specific VMT by county for the St. Louis City region was

provided by the East/West Gateway Council of Governments. The VMT was distributed to the Vehicle

Source Type using a Statewide VMT‐Vehicle distribution provided by MoDOT.

• roadtypedistribution: this table was updated for all 115 counties. VMT distribution by road type

for the State of Missouri was provided by MoDOT. Seven MOVES road type distribution tables were

created, one for each of the seven MoDOT county districts.

District CD: Boone, Callaway, Camden, Cole, Cooper, Crawford, Dent, Gasconade, Howard,

Laclede, Maries, Miller, Moniteau, Morgan, Osage, Phelps, Pulaski, Washington

District KC: Cass, Clay, Jackson, Johnson, Lafayette, Pettis, Platte, Ray, Saline

District NE: Adair, Audrain, Clark, Knox, Lewis, Lincoln, Macon, Marion, Monroe, Montgomery,

Pike, Ralls, Randolph, Schuyler, Scotland, Shelby, Warren

District NW: Andrew, Atchison, Buchanan, Caldwell, Carroll, Chariton, Clinton, Daviess, DeKalb,

Gentry, Grundy, Harrison, Holt, Linn, Livingston, Mercer, Nodaway, Putnam, Sullivan, Worth

District SE: Bollinger, Butler, Cape Girardeau, Carter, Douglas, Dunklin, Howell, Iron, Madison,

Mississippi, New Madrid, Oregon, Ozark, Pemiscot, Perry, Reynolds, Ripley, Scott, Shannon,

St. Francois, Ste. Genevieve, Stoddard, Texas, Wayne, Wright

District SL: Franklin, Jefferson, St. Charles, St. Louis, St. Louis City

District SW: Barry, Barton, Bates, Benton, Cedar, Christian, Dade, Dallas, Greene, Henry, Hickory,

Jasper, Lawrence, McDonald, Newton, Polk, St. Clair, Stone, Taney, Vernon, Webster

• sourcetypeagedistribution:  this table was updated for all 115 counties. A list of Vehicle

Identification Numbers (VINs), by county, was provided by the Missouri Department of Revenue.  The

VINs were decoded into model year and MOBILE6 vehicle classes by ESP Data Solutions, Inc, a private

contractor. Specific age distributions were created for all current and formerly proposed non‐attainment

areas, as well as four distributions created for the remaining counties of the state. These age

distributions were converted to the MOVES format using the EPA provided Mobile6 to MOVES

conversion excel workbook.
289 

Northeast Counties in Attainment: Adair, Audrain, Boone, Callaway, Carroll, Chariton, Clark,

Cole, Cooper, Grundy, Howard, Knox, Lewis, Linn, Livingston, Macon, Marion, Mercer,

Moniteau, Monroe, Montgomery, Osage, Pike, Putnam, Ralls, Randolph, Saline, Schuyler,

Scotland, Shelby, Sullivan, Warren

Northwest Counties in Attainment: Andrew, Atchison, Bates, Benton, Buchanan, Caldwell,

Daviess, DeKalb, Gentry, Harrison, Henry, Holt, Johnson, Lafayette, Nodaway, Pettis, Ray,

Worth

Southwest Counties in Attainment: Barry, Barton, Camden, Cedar, Dade, Dallas, Douglas,

Hickory, Jasper, Laclede, Lawrence, McDonald, Miller, Morgan, Newton, Ozark, Polk, St.

Clair, Vernon, Webster, Wright

Southeast Counties in Attainment: Bollinger, Butler, Cape Girardeau, Carter, Crawford, Dent,

Dunklin, Gasconade, Howell, Iron, Madison, Maries, Mississippi, New Madrid, Oregon,

Pemiscot, Phelps, Pulaski, Reynolds, Ripley, St. Francois, Scott, Shannon, Stoddard, Texas,

Washington, Wayne

Kansas City formerly proposed Non‐Attainment area: Cass, Clay, Clinton, Jackson, Platte

Greene County formerly proposed Non‐Attainment area: Christian, Greene, Stone, Taney

St Louis current and formerly proposed Non‐Attainment area: Franklin, Jefferson, Lincoln, St

Charles, St Louis, St Louis City

Perry and Ste. Genevieve formerly proposed Non‐Attainment area: Perry, Ste. Genevieve

• sourcetypeyear: this table was updated for all 115 counties. A list of Vehicle Identification

Numbers (VINs), by county, was provided by the Missouri Department of Revenue.  The VINs were

decoded into model year and MOBILE6 vehicle classes by ESP Data Solutions, Inc, a private contractor.

Mobile6 vehicle population counts were created for each county. These county vehicle populations

were converted to the MOVES format using the EPA provided Mobile6 to MOVES conversion excel

workbook.

• fuelsupply: this table was updated for the 110 counties not in the St Louis NonAttainment Area.

In 2008, Missouri's ethanol mandate took effect and required a 10% ethanol blend in all gasoline sold

except premium gasoline.  The ‘fuelsupply’ table in the 2011 County Databases provided by EPA

estimate gasoline without ethanol comprising 27.4% of gasoline sales in Missouri counties outside of the

St Louis NonAttainment Area. According to data on the US Energy Information Administration website

(http://www.eia.gov/dnav/pet/PET_CONS_REFMG_D_SMO_VTR_MGALPD_A.htm), premium gasoline

sales comprised 2.65% of the total gasoline sales in Missouri in 2009, the most current year of available

data.  This data seems more accurate than the 27.4% market share currently listed in the 2011 County

Databases for Missouri. Using the US EIA data to update the ‘fuelsupply’ tables, the market share for

gasohol (E10) would be 97.35% and the market share for non‐ethanol‐blend gasoline would be 2.65%.
290 

The ‘fuelsupply’ tables for the five counties in the St Louis NonAttainment Area were already populated

with the reformulated gasoline that is required in those counties.

• imcoverage:  this table was updated for the five counties in the St Louis Ozone NonAttainment

Area. These counties are Franklin County (29071), Jefferson County (29099), St Charles County (29183),

St Louis County (29187), and St Louis City (29510). IM data was provided by the Air Program’s IM

Program. The Air Program used EPA technical guidance on appropriate input assumptions and sources of

data for the use of MOVES 2010 in State Implementation Plan

(http://www.epa.gov/otaq/models/moves/420b10023.pdf).  Section 3.10 of this guidance document

explains the appropriate assumptions and methods to be used when developing the I/M input table for

MOVES 2010.  This guidance was followed in the development of the I/M input Tables.  The following

outlines the approach used to develop each parameter of these I/M input tables in MOVES.  

Pollutant Process ID

To begin development of the I/M input table, the default data for the I/M input table for St. Louis

County was exported from the MOVES county database manager.  The default data included four

different I/M test types.  However, the actual St. Louis area only had two different test types (On‐board

diagnostics) OBD tests for the exhaust and evaporative systems.  In the default I/M input table, these

were the only two types of tests that were “turned on” along with the appropriate pollutant process IDs

that would be impacted by each test.  Therefore, the pollutant process IDs that were included in the

default table for the two OBD tests were the same pollutant process IDs used in the I/M input table for

the St. Louis nonattainment area.  The other two tests included in the default data along with their

associated pollutant process IDs were still included in the I/M input table, but they were “turned off”.

Source Type ID

The St. Louis I/M program includes passenger cars and also trucks with a gross vehicle weight rating of

8,500 lbs. or less.  Therefore, the three source type IDs included in the I/M input table for the St. Louis

nonattainment area are passenger cars, passenger trucks, and light commercial trucks (IDs = 21, 31, and

32).

Inspection Frequency

The St. Louis I/M program requires that emission be tested every two years, so the inspection frequency

ID that represents biennial tests (ID = 2) was used in the I/M input table for the OBD tests applicable to

the St. Louis nonattainment area.

Test Standards

The St. Louis I/M program is a centralized program with OBD tests for exhaust and evaporative systems

on the vehicles.  Therefore, the test standard IDs for exhaust OBD check and the evaporative system

OBD check (IDs = 43 and 51) were used in the I/M input table for the St. Louis nonattainment area.
291 

I/M Program ID

This is an arbitrary number developed by the MOVES user to define a unique test given for vehicles

within a range of model years.  Therefore, I/M program IDs were arbitrarily assigned to the various

unique tests within the St. Louis I/M program.

Beginning and Ending Model Years

The St. Louis I/M program applies to gasoline vehicles with a model year of 1996 or later and it also

applies to diesel vehicles with a model year of 1997 or later.  Since the emissions inspection is required

biennially, the ending model year would always be two years less than the emissions inventory year that

is being developed.  Therefore, for the tests for gasoline vehicles, the beginning model year is 1996 and

the ending model year is two years earlier than the year for which MOVES is being run, and the for

diesel vehicles the  beginning model year is 1997 and the ending model year is two years earlier than the

year for which MOVES is being run.

Compliance Factor

According to page 39 of the MOVES guidance document the compliance factor is calculated with the

following equation:

Compliance Factor = percent compliance rate x (100 – percent waiver rate) x regulatory class coverage

adjustment.

Therefore, in order to calculate the compliance factor for each source type included in the I/M program,

the compliance rate, waiver rate, and regulatory class coverage adjustment needed to be determined.  

These three values were determined by the processes described below and then the compliance factors

for each source type were calculated with the equation written above.

Compliance Rate

The compliance rate was calculated with the following equation:

Compliance Rate = Number of vehicles that were tested over a two year period (2010 – 2011) /

Population of vehicles that is theoretically subject to I/M during the same period.

In order to determine the compliance rate, as it compares to the source type population by model year,

the population of vehicles that is theoretically subject to I/M first needed to be determined.

In May 2012, the Missouri Department of Revenue (DOR) Vehicle Registration database was queried and

a VIN decoder was used to separate the vehicle counts into Mobile 6.2 vehicle classes by model year.  In

the St. Louis nonattainment area, the Mobile 6.2 vehicle classes that are subject to I/M include 1996 and

newer light duty gasoline vehicles, light duty gasoline trucks Class 1, light duty gasoline trucks Class 2,

light duty gasoline trucks Class 3, light duty gasoline trucks Class 4, as well as 1997 and newer light duty

diesel vehicles, light duty diesel trucks Class 1, light duty diesel trucks Class 2, light duty diesel trucks

Class 3, and light duty diesel trucks Class 4.  The table below shows the total combined population of
292 

these 10 vehicle classes within the appropriate model years by county in the St. Louis nonattainment

area according the May 2012 DOR data.   

Vehicles Theoretically Subject to the I/M Program in the St. Louis Nonattainment Area

County Light Duty Gas (1996 and newer) Light Duty Diesel (1997 and newer)

Franklin 74,904 398

Jefferson 158,322 553

St Charles 270,453 854

St Louis City 143,503 517

St Louis County 792,960 2,352

Total 1,440,142 4,674

Total Count 1,444,816

The Air Program also queried the I/M report generator to determine the total number of vehicles, which

had their emissions tested at least once from January 1, 2010 through December 31, 2011.  The query

also included the total number of vehicles that received waivers during the same time period.  The table

below, was generated with data from this query.

Initially Tested Vehicles that Received a Waiver in the St. Louis I/M Program from January 1, 2010

through December 31, 2011

Model

Year

Passenger Car Truck Total Initially Tested

Test

Count

Waivers %

Waivers

Test

Count

Waivers %

Waivers

Test

Count

Waivers %

Waivers

1996 32,015 295 0.92 % 10,024 75 0.75 % 42,039 370 0.88 %

1997 40,698 156 0.38 % 12,314 34 0.28 % 53,012 190 0.36 %

1998 52,841 236 0.45 % 15,709 72 0.46 % 68,550 308 0.45 %

1999 63,520 139 0.22 % 17,052 28 0.16 % 80,572 167 0.21 %

2000 78,614 318 0.40 % 19,769 67 0.34 % 98,383 385 0.39 %

2001 80,007 270 0.34 % 18,769 39 0.21 % 98,776 309 0.31 %

2002 97,599 314 0.32 % 21,911 62 0.28 % 119,510 376 0.31 %

2003 90,007 134 0.15 % 20,853 18 0.09 % 110,860 152 0.14 %

2004 99,537 161 0.16 % 22,613 34 0.15 % 122,150 195 0.16 %

2005 103,390 66 0.06 % 19,223 11 0.06 % 122,613 77 0.06 %

2006 101,753 116 0.11 % 18,218 18 0.10 % 119,971 134 0.11 %

2007 113,181 30 0.03 % 19,128 4 0.02 % 132,309 34 0.03 %

2008 109,592 64 0.06 % 16,640 14 0.08 % 126,232 78 0.06 %

2009 82,184 29 0.04 % 8,984 0 0.00 % 91,168 29 0.03 %

2010 27,720 19 0.07 % 2,918 3 0.10 % 30,638 22 0.07 %

2011 7,060 0 0.00 % 467 0 0.00 % 7,527 0 0.00 %

2012 124 0 0.00 % 2 0 0.00 % 126 0 0.00 %

Total 1,179,842 2,347 0.20 % 244,594 479 0.20 % 1,424,436 2,826 0.20 %
293 

Using the data from the two tables above, the compliance rate is calculated for the St. Louis I/M

Program with the following equation:

Compliance Rate: (1,424,436 / 1,444,816) x 100% = 98.59%

Waiver Rate

The waiver rate is the percentage of vehicles that fail an initial I/M test and do not pass a retest, but do

receive a certificate of compliance.  The waiver rate was determined by dividing the number of vehicles

that received waivers from January 1, 2010 through December 31, 2011 by the total number of vehicles

that were tested at least once during the same time period.  Therefore, the waiver rate was calculated

for the St. Louis I/M Program with the following equation:

Waiver Rate: (2,826 / 1,444,816) X 100% = 0.20%

Regulatory Class Coverage Adjustment

The regulatory class coverage adjustment is an adjustment that accounts for the fraction of vehicles

within a source type that are covered by the I/M program.  Since the I/M program in St. Louis exempts

vehicles with a gross vehicle weight rating above 8,500 lbs., the compliance factor needs to reflect the

percentage of vehicles in the source types subject to I/M that are exempt because of their GVWR.  Table

A.3 in the Appendix of the MOVES Technical Guidance Document was used to develop adjustments to

the compliance factor to account for this discrepancy. The adjustments are percentages of vehicle miles

traveled by the various regulatory weight classes within a source type.  The corresponding adjustment

factors used for the three source categories are as follow:

Passenger cars: 100%

Passenger Trucks: 94%

Light Commercial Trucks: 88%

Calculating the Compliance Factor

Based on the calculations listed above the compliance factor for each source category impacted by the

I/M program in St. Louis is listed below.

Passenger cars: 98.59% x (100% ‐ 0.20%) x 100% = 98.39%

Passenger Trucks: 98.59% x (100% ‐ 0.20%) x 94% = 92.49%

Light Commercial Trucks: 98.59% x (100% ‐ 0.20%) x 88% = 86.59%

9.2 Nonroad Inventory

9.2.1 Nonroad Model
294 

EPA’s NONROAD model (http://www.epa.gov/otaq/nonrdmdl.htm) estimates emissions from engines

not used on roads.  Examples include lawn and garden equipment, construction equipment, recreational

equipment engines, and portable industrial, commercial, and agricultural engines.  Commercial marine,

aircraft, and locomotive engine emissions are not included in the NONROAD model, and their emission

estimates are covered in sections 9.2.2 through 9.2.4.

The National Mobile Inventory Model (NMIM) (http://www.epa.gov/otaq/nmim.htm) is EPA’s

consolidated mobile emissions estimation system that allows EPA to produce nonroad mobile emissions

in a consistent and automated way for the entire country.  EPA encouraged state and local agencies to

submit NMIM inputs to the EIS for the 2011 NEI for inclusion in the National County Database (NCD).  

The NCD contains all the county‐specific information needed to run NONROAD.  Although NMIM was

also designed to estimate onroad emissions, it is no longer used for that purpose, and the MOVES model

is used for onroad emissions (see section 9.1).  Eventually, MOVES will be revised to also estimate

nonroad emissions and NMIM will be retired.   

NMIM estimates emissions for engines with a variety of fuel types, from diesel and gasoline to LPG and

CNG.  The model estimates monthly emissions for total hydrocarbons (THC), nitrogen oxides, carbon

monoxide, particulate matter, and sulfur dioxide, as well as calculates monthly fuel consumption.  

NMIM uses ratios from some of these emissions to calculate emissions for an additional 33 HAPs and 17

dioxin/furan congeners. All of the input and activity data required to run NMIM are contained within the

NCD, which is distributed with the model.  State and local agencies are able to update the data within

the NCD to create emission estimates that accurately reflect local conditions and equipment usage.

Missouri did not submit updates to the NCD as no state‐specific updates to equipment population,

distribution, or temporal usage is available.  The default NCD was used by EPA to estimate Missouri’s

emissions using the NONROAD model, and Missouri accepted these emission values.  To quality assure

the emission totals, Missouri also ran the NONROAD model using the default NCD, and the emission

totals matched EPA’s results.

9.2.2 Commercial Marine

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  No documentation

was provided by EPA.

9.2.3 Aircraft  

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  Documentation is

available in Appendix B‐5 – 2011 Aircraft LTO Processing for the National Emission Inventory.

9.2.4 Locomotive
295 

The Missouri DNR accepted EPA’s estimates of emissions for this source category.  Documentation is

available in Appendix B‐6‐ Development of 2011 Railroad Component for National Emissions Inventory.
296 

10.0 Biogenic Inventory

Per the AERR, EPA creates the biogenic inventory with no updates or improvement from state or

local agencies.  The documentation below is taken from EPA’s Draft NEI documentation  

Biogenic emission sources are emissions that come from natural sources. They need to be

accounted for in photochemical grid models, as most types are widespread and ubiquitous

contributors to background air chemistry. In the NEI, only the emissions from vegetation and soils

are included, but other relevant sources include volcanic emissions, lightning, and sea salt.  

Biogenic emissions from vegetation and soils are computed using a model which utilizes spatial

information on vegetation and land use and environmental conditions of temperature and solar

radiation. The model inputs are typically horizontally allocated (gridded) data, and the outputs are

gridded biogenic emissions which can then be speciated and utilized as input to photochemical grid

models.  

Sector Description		

In the 2011 NEI, biogenic emissions are included in the nonpoint data category, in the EIS sector

“Biogenics – Vegetation and Soil.” The table below lists the two SCCs used in the 2011 NEI that

comprise this sector. These 2 SCCs have distinct pollutants: SCC 2701220000 has only NOX emissions,

and SCC 2701200000 has emissions for CO, VOC and 3 VOC HAPs: formaldehyde, acetaldehyde and

methanol.

The biogenic emissions for the 2011 NEI were computed based on 2011 meteorology data from the

Weather Research and Forecasting (WRF) Model using the Biogenic Emission Inventory System, version

3.14 (BEIS3.14) model within SMOKE. The BEIS3.14 model creates gridded, hourly, model‐species

emissions from vegetation and soils. The 12‐kilometer gridded hourly data are summed to monthly and

annual level, and are mapped from 12‐kilometer grid cells to counties using a standard mapping file.

BEIS produces biogenic emissions for a modeling domain which includes the contiguous 48 states in the

U.S., parts of Mexico, and Canada. The NEI uses the biogenic emissions from counties from the

contiguous 48.  

The model‐species are those associated with the carbon bond 2005 chemical mechanism (CB05). The

NEI pollutants produced are: CO, VOC, NOX, methanol, formaldehyde and acetaldehyde. VOC is the sum

of all other biogenic species except CO, NO, SESQ. Mapping of BEIS pollutants to NEI pollutants is as

follows:
297 

 NO maps to NOX  

 FORM maps to formaldehyde;  

 ALD2 maps to acetaldehyde;  

 MEOH maps to methanol;  

 VOC is the sum of all other biogenic species except CO, NO, SESQ.  

The BEIS3.14 model is described further in:

http://www.cmascenter.org/conference/2011/slides/pouliot_tale_two_cmas08.ppt  

The inputs to BEIS include:  

 Temperature data at 2 meters which were obtained from the WRF input files to the air quality

model,  

 Land‐use data from the Biogenic Emissions Land use Database, version 3 (BELD3). BELD3 data

provides data on the 230 vegetation classes at 1‐km resolution over most of North America. These

data are available at http://www.epa.gov/ttnchie1/emch/biogenic/.  

Sources of data overview and selection hierarchy		

The only source of data for this sector is the EPA‐estimated emissions from BEIS3.14. States are neither

required nor encouraged to report emissions, and no state has done this. The name of the EPA dataset

in EIS is: 2011EPA_biogenics.  

Spatial coverage and data sources for the sector		

The spatial coverage of the biogenics emissions is governed by the “2011 platform” modeling domain

which covers all counties in the lower 48 states. More information on this modeling platform is available

at http://www.epa.gov/ttn/chief/emch/index.html#2011.  

Biogenic emissions are a very large fraction of the total NEI VOC, methanol, formaldehyde and

acetaldehyde emissions but a very small fraction of the CO and NOx.  

More detailed summaries of the BEIS model species at county level and monthly are available as a

supporting summary on the 2011 web page

(ftp://ftp.epa.gov/EmisInventory/2011/2011_biogenic_reports.zip).

   
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11.0 Event Inventory

The 2011 inventory included prescribed fires and wild fires, but no other events.  Missouri DNR accepted

EPA’s estimates of emissions for these types of events.  Appendix B‐7 is the technical memorandum

from Sonoma Technology, Inc. (STI) explaining STI’s role in developing wild fire emissions for EPA.   
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12.0 EIS Data Submission

A total of 505 facilities were required to be reported as point sources to the 2011 NEI according to the

AERR.  Facility information along with relevant emissions data was uploaded to the Emission Inventory

System (EIS) Gateway.  Several steps were taken to prepare MoEIS data for submission to the NEI.  Key

steps included:

 All active emission units for previously identified facilities were retrieved from MoEIS and

matched to corresponding emission units in EPA’s EIS.  Attributes such as operating status and

descriptions were changed in the EPA database as needed.  Also, new units were added to the

NEI.

 All facilities with Part 70 or Intermediate Operating Permits during the 2011 emission year were

identified.  Also, facilities that had a Part 70 or Intermediate Operating Permit for only a portion

of the year were found and added to the submission list.   

 A table of Emission Release Points for the previously identified Emission Units was compiled,

including all relevant stack data.  Missing stack data was obtained by contacting facility

representatives or reviewing issued permits.

 All active Emission Processes for the previously identified facilities were retrieved from MoEIS

and matched to corresponding emission units in EPA’s database.  Attributes such as the SCC

code were changed as needed.  Also, new processes were added to the EIS.

 Control device information was searched for missing data such as pollutant codes and

percentage controlled.  Data was obtained and added as needed.  Additionally, a query was

written to verify that all active control devices were connected to an emission unit, while others

verify that controlled units are marked as such and that controlled emission factors are used

when appropriate.

 The data was queried to ensure that emission factors are marked controlled or uncontrolled as

appropriate.   

 Both MoEIS and EPA’s system allow a division of emissions between different release paths.  

However, MoEIS requires the sum total of emissions to equal 100% at the unit level, while the

federal system requires a sum of 100% per emission process.  An Access query is used to

determine which units have multiple processes so that corrections can be made before

submission.

 An Access query was developed to ensure that point source facilities in the 5‐county St. Louis

ozone nonattainment area are including typical ozone season day emissions for VOC, NOx, and

CO on the Ozone Season worksheet as required.

Data was transferred in steps to lower the total number of errors during each step of the submittal

process.  Basic facility information was uploaded first, followed by:  

 Emission Units – All active emission units in MoEIS for the 505 facilities were uploaded.  

Operating status was changed for formerly active units.   

 Emission Release Points‐ All active emission release points were uploaded.  Operating status

was changed for formerly active units.
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 Emission Processes‐ All active emission processes uploaded and any that were no longer

reportable were given a “last reporting year” in the EIS gateway.  

 Control Approach‐ All active controls along with control percentage and pollutants

controlled were uploaded.   

 Emissions‐ Criteria and HAP annual pollutant emissions were uploaded to the EIS gateway.  

 Ozone emissions for facilities in the nonattainment area were uploaded.  

After each submittal, accuracy was verified by downloading the inventory from the gateway and

comparing it to the data in MoEIS.   

Each nonpoint data category was submitted individually to the EIS where Missouri was providing a state‐

specific update to an EPA‐provided number, or where Missouri estimated emissions independently of

EPA.  Where Missouri accepted the EPA estimate, a support request was sent via the EIS listing the SCCs

for which Missouri accepted EPA’s estimation.

Missouri submitted the onroad mobile data inputs for the MOVES model, as requested in the AERR.

Using those model inputs, EPA is able to run the model and create emission estimates identical to

Missouri’s model runs.