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POINT SOURCE, ON-ROAD, AND FIRE 

BASE YEAR, FUTURE YEAR, AND CONTROL 

STRATEGY EMISSIONS INVENTORIES 

DRAFT 

QUALITY ASSURANCE 

PROJECT PLAN 

for 

CONTRACT #: S-2009-06-02 

EPA Grant XA-95411009 

EPA Grant XA-96431505 

Effective Date: August 2009

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Table of Contents 

POINT SOURCE, ON-ROAD, AND FIRE 

BASE YEAR, FUTURE YEAR, AND CONTROL STRATEGY EMISSIONS 

INVENTORIES QA PROJECT PLAN 

1.0 PROJECT OVERVIEW .............................................................................................. 1-1

1.1 Project/Task Organization ....................................................................................... 1-1

1.2 Problem Definition/Background .............................................................................. 1-3

1.3 Project/Task Description .......................................................................................... 1-4

1.4 Quality Objectives and Criteria for Measurement Data ..................................... 1-11

1.5 Special Training Requirements / Certification Listed ......................................... 1-11

1.6 Documentation and Records .................................................................................. 1-11

2.0 SAMPLING ................................................................................................................... 2-1

2.1 Sampling Process Design (Experimental Design) ................................................... 2-1

2.2 Sampling Methods Requirements ............................................................................ 2-1

2.3 Sample Handling and Custody Requirements........................................................ 2-1

2.4 Analytical Methods Requirements .......................................................................... 2-1

2.5 Quality Control Requirements ................................................................................. 2-1

2.6 Instrument / Equipment Testing Inspection, and Maintenance Requirements .. 2-1

2.7 Instrument Calibration and Frequency .................................................................. 2-1

2.8 Inspection / Acceptance Requirements for Supplies and Consumables .............. 2-1

2.9 Data Acquisition Requirements for Non-direct Measurements ........................... 2-2

2.10 Data Management ..................................................................................................... 2-5

3.0 REPORTS TO MANAGEMENT ............................................................................... 3-1

3.1 Project Status Reports .............................................................................................. 3-1

3.2 Results of Performance Evaluations and Audits .................................................... 3-1

3.3 Results of Periodic Data Quality Assessments ........................................................ 3-1

4.0 DATA REVIEW AND VALIDATION ....................................................................... 4-1

4.1 Data Review, Validation, and Verification ............................................................. 4-1

4.2 Validation Methods and Verification Methods ...................................................... 4-1

4.3 Reconciliation with User Requirements .................................................................. 4-1

4.4 Representativeness Assessment ................................................................................ 4-1

5.0 REFERENCES ............................................................................................................. 5-1 

Appendix A Memorandum of Understanding 
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TABLES AND FIGURES 

 

 Figure 1. Project Organization Chart Section1 Page 2 

 Figure 2. Audit Check Form Section 3 Page 2 

 Table 1. Data Quality Objectives, Procedures, and Indicators Section1 Page 12 

Distribution List: 

John Hornback, SESARM (Executive Director) 

Ron Methier, SESARM (SESARM Project Coordinator) 

Brenda Johnson, EPA (Region 4 Technical Project Officer, Fine Particles/Ozone) 

Michele Notarianni, EPA (Region 4 Technical Project Officer, Regional Haze) 

Danny France, EPA (Region 4 QA Manager) 

William Barnard, MACTEC (Program Manager, Fire Source Task Leader) 

Edward Sabo, MACTEC (Point Source Task Leader) 

Dan Meszler, MESZLER Engineering Services, Inc. (On-road Mobile Source Task Leader) 

Gregory Stella, Alpine Geophysics, LLC. (Quality Assurance Coordinator) 
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1.0 PROJECT OVERVIEW 

1.1 Project/Task Organization 

Figure 1 identifies the individuals and organizations participating in the project. Their specific 

roles and responsibilities include: 

 Mr. John Hornback, SESARM Contract Officer (hornback@metro4-sesarm.org, 404-

361-4000), will oversee all activity on the contract, and supervise managerial aspects 

of the project. He will help facilitate communications among State/local agencies, 

MACTEC, and the SESARM Project Coordinator. 

 Mr. Ron Methier, SESARM Project Coordinator (ronmethier@comcast.net, 770-785-

7978), will work with the SESARM Contract Officer and State/local Agency 

Coordinators to define the emission inventory development activities needed to 

support regional haze modeling and planning activities. 

 State/local Agency Coordinators will compile and submit data to MACTEC, 

participate in QA/QC reviews, and help revise, update, and correct the inventory. 

 William Barnard, MACTEC Program Manager and Fire Task Leader 

(wrbarnard@mactec.com, 352-333-6617), will direct and monitor technical and 

financial performance throughout the project and will serve as a senior primary 

contact with SESARM on contract and project management issues. Mr. Barnard will 

also direct aspects of the projection inventory development related to fire and mobile 

sources. He will plan and conduct the technical aspects of the development of the fire 

and mobile source inventories, supervise daily activities, identify effective QC 

procedures and make recommendations on needed QC procedures. 

 Edward Sabo, MACTEC Point Source Task Leader (ejsabo@mactec.com, 703- 471-

8383), will plan and manage all point source activities. He will plan and conduct the 

technical aspects of the development of the point source inventory, supervise daily 

activities, identify effective QC procedures and make recommendations on needed 

QC procedures. 

 Dan Meszler, MACTEC Mobile Source Task Leader (dan@meszler.com, 410- 569-

0599), will plan and manage all mobile source activities. He will plan and conduct the 

technical aspects of the development of input files for the MOBILE/MOVES models. 

He will help identify effective QC procedures and make recommendations on needed 

QC procedures. 

 Mr. Gregory Stella, QA Coordinator (gms@alpinegeophysics.com, 828- 675-9045), 

will help ensure that adequate QA/QC procedures are incorporated into the inventory 

development process. He will work independent of the inventory development Task 

Leaders to assist in the conduct of project QA/QC assessments. 
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SESARM 

Project Coordinator

Ron Methier

SESARM State &

Local Coordinators

Program Manager

William Barnard

MACTEC

SESARM 

Contract Officer

John Hornback

Fire Source Task 

Manager

William Barnard

Mobile Source Task 

Manager

Dan Meszler

Point Source Task 

Manager

Edward Sabo

QA Coordinator 

Gregory Stella

Alpine Geophysics

FIGURE 1 – PROJECT ORGANIZATION CHART 

 
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1.2 Problem Definition/Background 

Southeastern States Air Resource Managers Inc. (SESARM) is a corporation registered in the 

state of Georgia and organized under the nonprofit provisions of the Internal Revenue Code, 

Title 26, Subtitle A, Chapter 1, Subchapter F, Part I, Section 501 (c)(3). It was formed by, and 

serves the needs of, the air pollution control agencies located in the southeastern region of the 

United States, to which the Environmental Protection Agency (EPA) refers as Region 4. Eight 

states are members of SESARM – Alabama, Florida, Georgia, Kentucky, Mississippi, North 

Carolina, South Carolina, and Tennessee. SESARM maintains its corporate office in Forest 

Park, Georgia. 

The United States Environmental Protection Agency (EPA) designated SESARM as the 

organization responsible for conducting regional air quality planning in the Southeast, 

specifically for regional haze. SESARM created a collaborative effort called Visibility 

Improvement – State and Tribal Association of the Southeast, also known as VISTAS. 

In 2001, SESARM invited the contiguous states of Virginia and West Virginia to join the 

regional haze effort. SESARM also invited the local agencies in the Southeast to be represented 

by the Knox County, Tennessee air pollution control program. Though southeastern tribes are 

not required to develop and submit tribal implementation plans, SESARM invited the Eastern 

Band of Cherokee Indians to represent the six federally-recognized Southeastern tribes. 

The participating state agencies have obligations to protect human health and the environment 

from the impacts of air pollutants. They are responsible for air quality planning efforts and have 

primary authority and responsibility to develop, adopt, and implement state implementation 

plans (SIPs) for all air pollutants and aesthetic concerns including fine particles, ozone, and 

regional haze. 

A memorandum of understanding was developed in 2001 by SESARM and executed among the 

participating agencies to formalize their regional haze project commitment as well as to establish 

formal goals and procedures for technical air quality analyses. An unsigned copy of the 

memorandum is provided in Appendix A. A policy board (the STAD), a day-to-day operations 

group (the Coordinating Committee), and three work groups (Data, Planning, and Technical 

Analysis) were created to oversee, guide, and conduct the collaborative work within SESARM’s 

structure. The projects continue to be managed in this manner. Later, fine particle and ozone 

SIP support was identified as an additional critical opportunity for SESARM to assist the 

participating state agencies in managing, improving, and maintaining air quality. 

The work of SESARM and the in-kind services of the participating agencies are designed to 

produce technical analyses to aid the participating agencies in developing SIPs required by the 

Clean Air Act. SESARM solicits input from various stakeholders to the fine particle, ozone, and 

regional haze projects. Participation is also encouraged from representatives of federal agencies 

including EPA, the Department of Agriculture’s Forest Service, and the Department of Interior’s 

National Park Service and Fish and Wildlife Service; the regulated community; academia; 

environmental groups; and the general public. 
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The project supported by this contract shall consist of development of a comprehensive annual 

emissions inventory for the Southeast to support modeling and assessment of the emissions and 

atmospheric processes that result in fine particles, ozone, and regional haze. This work shall 

include development of at least one base year inventory consistent with the Environmental 

Protection Agency’s (EPA’s) criteria for emission reporting. Candidate modeling base years for 

inventory development are 2005 and 2008. States are also considering whether meteorological 

conditions in 2006 or 2007 would be more representative as the modeling base year. In 

consultation with its participating agencies and EPA, SESARM will decide which year to use as 

the base year before the inventory work begins. 

This project shall include developing emissions inventories for at least one future year for 

emissions and air quality modeling purposes. SESARM will select the future modeling year or 

years as appropriate to support fine particle, ozone, and regional haze objectives. 

Finally, this project shall also include development of emissions inventories for future year 

control strategies that will support modeling and assessment of controls necessary to assess the 

extent of NAAQS attainment and regional haze. 

The purpose of this Quality Assurance Project Plan (QAPP) is to outline and guide the process 

for quality assuring the inventory development to ensure the development of complete, accurate, 

and consistent emission inventories. The QAPP is consistent with the recommendations in the 

EPA quality assurance requirements1

 and the Emission Inventory Improvement Program’s QA 

guidance2

. The QAPP includes tasks associated with obtaining State data, merging and 

augmenting State submittals with available EPA databases, improving the activity data and 

emission factors for important source categories, obtaining and developing growth and control 

factors, obtaining State and stakeholder review of the emission inventory, and providing 

documentation of the maintenance (revisions, updates, corrections) of the inventory. 

1.3 Project/Task Description 

MACTEC will produce preliminary and final sets of comprehensive annual base year and future 

year emissions inventories for point sources, on-road mobile sources, and fire sources for the 

participating states to support regional air quality modeling and assessment of fine particles, 

ozone, and regional haze. Emissions shall be reported by source category (i.e., point, on-road 

mobile, fire) by county for each county in Alabama, Florida, Georgia, Kentucky, Mississippi, 

North Carolina, South Carolina, Tennessee, Virginia, and West Virginia. The emissions 

inventory development shall be specific to these states only. SESARM shall obtain emissions 

inventories for other states directly from those states or their respective regional organizations. 

Additional reporting requirements for the major source categories are discussed below. 

The emissions inventories shall consist of all primary and precursor emissions necessary to 

accurately model fine particles and ozone including ammonia (NH3), carbon monoxide (CO), 

nitrogen oxides (NOx), particles with a diameter less than 2.5 micrometers (PM2.5), particles with 

a diameter less than 10 micrometers (PM10), sulfur dioxide (SO2), and volatile organic 

compounds (VOCs) for point sources, on-road mobile sources, and fire sources. 
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To project emissions from the base year to future years, MACTEC will review, summarize, and 

recommend methods and growth and control factors consistent with SESARM’s objective to 

develop future year base case and control strategies for demonstrating attainment with the PM2.5

and ozone National Ambient Air Quality Standards (NAAQS) and to meet reasonable progress 

obligations for improving visibility. These methods and factors shall include the control 

technologies and associated percentage reductions, rule effectiveness, rule penetration values, 

growth rates, and energy efficiency factors used to generate the future year base case and control 

strategy emissions inventories. 

The emission inventories shall be delivered in electronic format consistent with the requirements 

for conducting regional emissions and air quality modeling. The emission model input formats 

shall be defined once the emissions model has been selected. Inventories shall also be provided 

consistent with EPA’s current emissions inventory reporting requirements. The SESARM 

Project Coordinator shall provide more specific direction on inventory formats, if clarification is 

needed, after development of a detailed work plan is initiated. 

Current emission inventory reporting requirements can be found in a variety of documents 

available on EPA’s website. Links to some of these documents include sections 6, 7, 9, 10 and 

11 of the 2008 NEI/EIS implementation plan found at 

http://www.epa.gov/ttn/chief/net/neip/index.html, as well as more general guidance documents 

which can be found at http://www.epa.gov/ttn/chief/publications.html. Finally aspects of both 

the Air Emissions Reporting Rule (AERR) and Consolidate Emissions Reporting Rule (CERR) 

will be employed in developing inventories for this project. Documents detailing emission 

reporting requirements under these two rules can be found at http://www.epa.gov/ttn/chief/aerr/

and http://www.epa.gov/ttn/chief/cerr/index.html, respectively. 

MACTEC will work consistent with Contract provisions, federal grant and project requirements, 

and the final project work plan to collect, quality assure, document, and prepare 

recommendations for the use or revision of these data for the purposes of developing base year 

and future year inventories. MACTEC will participate in meetings and conference calls and 

provide insight, background, and suggestions within their areas of expertise. Further, MACTEC 

will provide upon request written reports and/or analyses of certain aspects of the inventory 

development work. The methods used to develop the inventories shall be documented in 

technical reports for purposes of supporting state implementation plans (SIPs) for fine particles, 

ozone, and regional haze. All revisions to inventories and the sources of the revisions shall be 

clearly documented. 

The Project Coordinator shall provide overall SESARM program management and specific 

technical direction to this project. 

This QAPP focuses on the tasks associated with developing these inventories. 

Base Year Inventory Activities. 

The effort includes the following point, on-road and fire emission activities: 

EGU Point Source Activities. For point sources, the following tasks will be performed: 
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1. Obtain State/local 2005 CERR submittals from EPA’s ftp site (or directly from the 

State/local agency if the State/local agency has updated the 2005 inventory since 

submittal to EPA). Version 3 of the 2005 NEI (containing the 2005 CERR submittals) 

will be the primary source of this data. 

2. Obtain unit-level 2005 EGU annual emissions and other data from CAMD’s eGRID 

database. 

3. Obtain 2005 EGU hourly CEM data from CAMD website; determine whether State/local 

agencies have CEM data that differs from or is in addition to the CAMD data; perform 

QA/QC checks of CEM data to identify missing data or potential outliers. 

4. Develop a cross-reference file from the above three data sets to relate unit identifiers in 

the CERR submittals with the CAMD unit identifiers; coordinate with State/local 

agencies in resolving inconsistencies. 

5. Compare the 2005 data to SESARM’s 2002 Best and Final Inventory and identify any 

unmatched units or large changes in emissions. 

6. Analyze the PM emissions in the CERR submittal and determine which PM species are 

present (i.e. PM10 vs. PM2.5, filterable vs. condensable); augment data as necessary using 

EPA’s NEI PM data augmentation procedures or recently developed PM condensable 

emission factors for EGUs. 

7. Prepare an easily reviewable master EGU cross-reference table for 2005 that includes the 

following elements: CERR and CAMD unit identifiers; annual NOx and SO2 emissions, 

heat input, and base year air pollution control systems from the three data sources 

(CERR, CAMD annual, CAMD hourly); PM emissions as reported in the CERR along 

with any adjustments resulting from the PM augmentation procedure; emissions of other 

criteria pollutants; and stack parameters and location coordinates. 

8. Provide the EGU table for review and verification by the State/local agencies. 

9. Determine which source of emissions data is preferred for use in the base year file, either 

for the SESARM region as a whole or on a case-by-case basis as directed by SESARM or 

the State/local agencies. 

10. Perform QA/QC checks on stack and location data to identify missing data or potential 

outliers. 

11. Prepare electronic data files in NIF output format, maintaining data fields to clearly 

document the source of data used for each emission value. 

12. Execute EPA’s Basic Format and Content Checker tool to verify referential integrity of 

the database. 

The above items assume a 2005 base year. If an alternative base year is selected the methods will 

be revised to reflect the change in base year. In some cases this will result in elimination of some 

items and in others the comparisons made will differ. For example if 2008 is chosen as the base 

year the 2008 inventory developed will use updated data from the States on the EGUs and will 
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be compared to the 2005 CERR submittals rather than to 2002 Best and Final Inventory (or a 

comparison of all three inventories may be made). 

In addition to the actual emission base year inventory, MACTEC will prepare a typical base year 

inventory for EGUs to correct for possible non-typical operating conditions during the modeling 

base year. We will obtain and review any existing ERTAC EGU Temporal and CEM Data Work 

Group methods or recommendations, and provide any additional recommendations to SESARM. 

We will obtain CEM data for EGUs for the 2001-2005 (and additionally 2006-2008, if directed 

by SESARM) so that we have five years of data corresponding to the five years that contribute to 

the base year design value. Previously, MACTEC used the average heat input from the 

contributing years to define heat input and emissions for the typical EGU inventory. The specific 

methods and years to be used for typical EGU emissions will be determined in consultation with 

SESARM. 

Non-EGU Point Source Activities. For non-EGU point sources, the following tasks will be 

performed: 

1. Obtain State/local 2005 CERR submittals from EPA’s file transfer protocol (ftp) site (or 

directly from the State/local agency if the State/local agency has updated the 2005 

inventory since submittal to EPA). Version 3 of the 2005 NEI (containing the 2005 

CERR submittals) will be the primary source of this data. 

2. Remove any units from the CERR file that have already been accounted for in the EGU 

file developed above to ensure that no double-counting of emissions occurs, particularly 

for co-generation plants where double-counting was a concern during the development of 

the 2002 Best and Final Inventory. 

3. Execute EPA’s Basic Format and Content Checker to identify errors or anomalies in the 

2005 CERR data; coordinate with State/local agencies in resolving any issues. 

4. Determine whether State/local agencies have hourly CEM data for non-EGU sources that 

are not in the CAMD database; obtain CEM data and perform QA/QC checks to identify 

missing data or potential outliers. 

5. Compare the 2005 data to the SESARM’s 2002 Best and Final Inventory and identify any 

unmatched facilities or facilities with large differences in emissions between 2002 and 

2005; provide comparison to State/local agencies for verification. 

6. Analyze the particulate matter (PM) emissions in the CERR submittal and determine 

which PM species are present (i.e. PM10 vs. PM2.5, filterable vs. condensable); augment 

data as necessary using EPA’s NEI PM data augmentation procedures or recently 

developed PM condensable emission factors for non-EGUs. 

7. Perform QA/QC checks on stack and location data to identify missing data or potential 

outliers, focusing review on the larger non-EGU sources. 

8. Prepare electronic data files in NIF output format, maintaining data fields to clearly 

identify the source of data used for each emission value. 
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9. Re-execute EPA’s Basic Format and Content Checker tool to verify referential integrity 

of the database. 

As with EGU sources, if a different base year from 2005 is chosen the methods listed will be 

modified to work with the year chosen. 

Fire Emission Activities. For fire emissions, the following tasks will be performed: 

1. Data collection and data entry - available electronic fire activity data will be collected for 

at least for one year from 2005 to 2008, from state and federal forestry agencies in the 

Southeast all available electronic records of fire activity for wild fire, prescribed fire, land 

clearing, and agricultural burning. If states do not have an electronic version of 

prescribed fire records, MACTEC will consult with SESARM to receive further 

direction. MACTEC will review all submitted electronic records and shall identify to 

state and federal forestry agencies missing data records. An important aspect of this work 

is to identify duplicate records since activity data received from State and Federal 

agencies may contain overlapping records. MACTEC will use comparisons of time, date, 

latitude and longitude and other identification tools to assist in indentifying the duplicate 

records. Data for land clearing and agricultural burning will also be collected. 

2. Development of an initial fire inventory for the modeling base year – MACTEC will 

work with State and Federal forestry agencies to modify or update the existing 

CONSUME database if necessary to calculate emissions consistent with fire 

characteristics in the Southeast. Information updated will include methods to define 

acreage and parameters for calculating emissions for wild land fires, prescribed fires, land 

clearing, and agricultural burning. Because fuel loading is one of the keys to assessing 

fire emissions, MACTEC will use a reasonable fuel loading model. Data for daily 

emissions shall be collected and summarized monthly by county, state, fire type, and 

pollutant. 

3. Evaluation and merger of satellite and ground-based fire activity data - the ground-based 

fire activity data collected from the State and Federal forestry agencies will be compared 

to the SMARTFIRE activity data based on satellite records of fire occurrence. Depending 

upon funding availability, the efficiency of SMARTFIRE in merging the two fire activity 

data sets will be evaluated for a single modeling year. MACTEC will compare, for the 

modeling base year only, the ground-based fire activity records developed and the 

merged satellite and ground-based fire activity records from SMARTFIRE and provide a 

technical assessment of SMARTFIRE’s performance in identifying and merging 

corresponding fire events. MACTEC will recommend methods that might improve the 

merged satellite and ground-based data for the modeling year and secondarily, for an 

average of the period 2005-2008. MACTEC will then provide methods and costs to 

complete this evaluation and recommendations including options to review records for a 

single state rather than ten states as an approach to reduce the costs of the evaluation. The 

State and Federal forestry and air quality agencies will review these recommendations 

and available funding to determine the level of effort that will be authorized to expand on 
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merging SMARTFIRE and SESARM ground based fire activity data. If authorized by the 

SESARM Project Coordinator, MACTEC will implement the methods approved by state 

and federal agencies for merging the satellite and ground-based data. 

4. Apply approved fire inventory development methods to merged fire activity data and 

electronically archive – MACTEC will work with all parties to finalize the methods to be 

used for the Southeast to develop a base year fire emissions inventory for SESARM’s 

regional air quality modeling purposes. MACTEC will apply approved fire inventory 

development methods to merged satellite and ground-based fire activity data 

5. Document fire inventory - the fire inventory methods and results will be summarized in a 

report. A draft report will be delivered with the initial fire inventory. That report will be 

revised to reflect the methods and results arising from later tasks (e.g., the SMARTFIRE 

comparison). 

6. Develop typical modeling base year fire inventory - a typical fire inventory will be 

developed and reported consistent with emissions and air quality modeling requirements. 

To correct for possible non-typical fire activity during the modeling base year for 

purposes of future year inventory projections for each county and/or state, MACTEC will 

develop average activity data for 2005-2008 for wild fire and prescribed fires. MACTEC 

will adjust acreage for individual fires in the modeling year by the average acreage for 

the county or state over the period 2005-2008. The specific methods applied shall be 

resolved in consultation with SESARM and federal forestry and air quality agencies. 

On-road Mobile Source Emission Activities. For on-road mobile source emission sources, the 

following tasks will be performed: 

1. MACTEC will collect the latest available on-road mobile data from southeastern 

agencies and EPA for the selected modeling base year. Southeastern air quality agencies 

shall coordinate with local air agencies, state transportation agencies, and/or local 

planning organizations as necessary to obtain relevant mobile model input data for the 

base year. Link-level mobile activity data shall be obtained for those states that request 

that link data be used in mobile modeling. At this time, Georgia is on-record with such a 

request. 

2. Currently, on-road emissions are calculated using the MOBILE6 emissions model. EPA 

is developing a new model called MOVES (Motor Vehicle Emission Simulator) that will 

eventually replace the MOBILE and NONROAD models, and that states may soon be 

required to use for on-road and/or non-road mobile emissions calculations.. EPA released 

a draft version of MOVES on April 9, 2009, requested comments on "Draft 

MOVES2009" by July 2009, and plans to release a "final" version of MOVES (for onroad sources; draft for nonroad) by the end of 2009. The final version of MOVES is 

expected to be functional for emissions modeling, but it is unclear how/if it will interface 

with air quality modeling emissions processors (e.g., SMOKE). MACTEC will process 

local and state data and provide model inputs to the southeastern agencies for review and 

confirmation. Upon direction from the SESARM Project Coordinator, the Contractor may 
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be requested to run MOBILE6/SMOKE or MOVES to produce mobile emissions that are 

consistent with relevant EPA emission inventory reporting requirements. For emissions 

modeling purposes, MACTEC will provide the approved model inputs to the emissions 

and air quality modeling contractor to process the mobile emissions. As the status of 

MOVES becomes more certain, MACTEC will, at SESARM’s request, prepare a specific 

scope of work revision and cost estimate for work resulting from this transition that is not 

reflected in this Contract. MACTEC will initiate and complete work consistent with the 

revised scope of work upon direction from SESARM. 

3. SESARM is participating in a national project to evaluate particulate matter emission 

profiles for highway vehicles using results of an emission measurement study for 

gasoline and diesel vehicles in Kansas City, Kansas. The current project will develop 

revised mobile emissions profiles for two northern cities, Detroit, Michigan and New 

York, New York and compare these revised profiles to those currently used in 

MOBILE6. MACTEC will review these findings and recommend modifications, if any, 

to mobile emissions profiles for southeastern states. 

In addition to developing a base year inventory, MACTEC will also be developing projection 

year inventories. The projection year is anticipated to be either 2012 or 2013. Projection 

inventory activities are listed below. 

Projection Inventory Activities. 

The effort includes the following activities: 

1. Assemble preliminary “base case” data for 2012/2013. 

2. Prepare the draft “base case” inventory for 2012/2013. 

3. Growth and control factor review and assessment. Growth and control factors available 

for use in developing the draft and final 2012/2013 inventory will be reviewed, assessed 

and recommendations which factors to use will be made to SESARM. Any required 

changes will be made and applied to the final inventory. This will include an evaluation 

of preparation of EGU projections both with and without proprietary projection models 

(e.g., IPM). 

4. Assemble the final 2012/2013 “base case” inventory. This inventory will be based off of 

the latest revision to the base year inventory, revised control information and revised 

growth factors. 

5. Recommend methods for control strategies. 

6. Prepare control strategy inventories (if funded). 

7. Develop a projection inventory for an alternative future year (if funded). 

8. Develop a “typical year” inventory for electric generating units (EGUs) 

9. Develop a “typical year” inventory for wild and prescribed fires. 
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Other Activities. In addition to the above tasks related to base and projection year inventories, 

the following tasks will be performed: 

1. Contingencies related to other work tasks. 

2. Preparation of reports. 

3. Data display and archive. 

1.4 Quality Objectives and Criteria for Measurement Data 

The goal of the inventory process is to provide the best possible inventory under given resource 

constraints. Data Quality Objectives (DQO) are statements about the level of acceptable 

uncertainty or error. Their purpose is to ensure that the final data will be sufficient for the 

intended use of the inventory. A well developed and implemented quality assurance program 

fosters confidence in the inventory and any resulting regulatory program. It also gives the end 

user important information about the limitations of the emission estimates in order to avoid 

misuse of data. 

Table 1 summarizes the Data Quality Objectives for the SESARM inventories that will be 

compiled for this contract. The first column of Table 1 defines four data quality objectives: 

accuracy, completeness, comparability and representativeness. The second column identifies the 

procedures that will used to achieve each objective. The third column identifies Data Quality 

Indicators (DQI), which are qualitative and quantitative descriptors used in interpreting the 

degree of acceptability or utility of data. 

1.5 Special Training Requirements / Certification Listed 

All staff performing data review and analysis are air quality professionals and have sufficient 

education/experience to perform emission estimation calculations and work with emission 

inventory databases. Most staff have received specific emission inventory training through 

conferences, workshops, self-study programs, and on-the-job work experiences. There are no 

specifically mandated training requirements for work performed on this project. 

1.6 Documentation and Records 

QAPP Control. Any changes to this QAPP will be initiated either by the Program Manager, the 

Task Leaders, or the QA coordinator. Each change will be given a revision number and date in 

the document control block in the upper corner of the affected pages. It will be the responsibility 

of the initiating person to distribute copies of the changed pages to all the persons on the 

Distribution List and to the appropriate project team members. 

Data Collection Records. Clear documentation of the data collected from the State/local 

agencies, EPA, and other agencies is integral to the quality analysis review. Records will be 

maintained containing a description of the data received, the name of the person and agency 

submitting the data, the date of the submission, and other relevant information about the data 

submission. The following types of data will be collected during this project: 
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 EPA’s 2005 National Emission Inventory (version 3) 

 State CERR submittals 

 State/local agency data submittals in NIF 3.0 format 

 Forestry officials data submittals for wild and prescribed fires 

 Mobile source input files provided by State/local air agencies or EPA 

 EPA’s Final Summary Emission Reports for CEM information for electric utilities 

regulated by the Acid Rain Program 

 EPA’s Toxic Release Inventory for ammonia emissions data 

 State agency submittals of information necessary to calculate fire emissions and 

geographically locate where these fires occurred in the base year. 

 State/local agency revisions, updates, corrections in response to various QA/QC 

checks. These may be provided in a variety of formats depending on the nature of the 

response. 

 Department of Energy fuel efficiency data 

 EGAS or other growth factors available from EPA, DOE, or the States 

 VMT data 
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TABLE 1

DATA QUALITY OBJECTIVES, PROCEDURES, AND INDICATORS 

Data Quality Objective Procedures Example Indicators 

Accuracy - reduce uncertainty in 

emission estimates where possible, 

validate that data elements needed 

for modeling are within accepted 

parameters, and verify that emission 

estimates agree with accepted 

reference values. 

1. Identify weaknesses in existing 

inventories, identify new 

methods/data to reduce 

uncertainty, and obtain new 

activity/emission factor data 

where available. 

2. Use EPA’s NIF QA tool and adhoc reports to perform 

computerized checks of valid 

codes/data ranges and to identify 

outliers. 

3. Conduct senior technical review 

of pollutant totals by facility, 

source category, state, and region. 

4. Compare to other published data. 

1. Qualitative assessment of the 

inventory’s strengths and 

weaknesses. 

2. 100% of stack data and temporal 

factors in valid ranges for > 100 

tpy sources. 

3. 100% of sources have valid 

geographic coordinates. 

4. 100% correction of significant 

outliers. 

5. Agreement of SESARM 

emissions and EPA CEM data and 

EPA TRI data. 

6. Compare projection emissions to 

base year emissions to ensure that 

values are within expected ranges. 

Completeness – include all major 

point sources, include emission 

estimates for PM2.5 and ammonia, 

verify that all on-road mobile source 

categories and fire sources are 

accounted for. 

1. Compare SESARM utility data to 

EPA CEM data. 

2. Compare SESARM point source 

ammonia data to EPA TRI data. 

3. State/local agencies compare 

facility list to their Title V permit 

lists. 

4. Compare small point source 

emissions to area source 

emissions. 

5. Compare PM10 and PM2.5

emissions. 

6. Plot fire sources by type. 

1. 100% of all utilities accounted for 

in database. 

2. 100% of large ammonia sources 

in TRI accounted for in database. 

3. 100% of Title V sources 

accounted for in database 

4. Small point sources included as 

either small point sources or as 

area sources. 

5. PM2.5 and ammonia emissions 

included in inventory 

6. Fire emissions for all counties in 

region accounted for. 

7. All mobile sources accounted for. 

8. Explanation of any missing data 

or sources. 

Comparability – verify that 

emission estimates are similar to 

other peer-reviewed inventories and 

that any major deviations are 

explained. 

1. Compare emission totals by 

source category, pollutant, 

geographic region, and year with 

previous emission inventories. 

1. Explanation for large 

discrepancies in emissions 

Representativeness – use emission 

estimation methods that reflect local 

conditions and the time period of 

interest. 

1. Identify where national defaults 

used instead of local activity data. 

2. Identify where emissions were 

grown for base year 2002 data 

were not available. 

3. Identify growth factors for 

projection years. 

1. Explanation for use of national 

defaults. 

2. Determination of representative 

values for “typical years” for 

some sources for projections (i.e., 

fires, utility emissions). 
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Data Handling Records. Another key element of the QA program is maintaining written 

documentation of calculations, assumptions, and all other activities associated with incorporating 

the State/local agency submittals and other data with the EPA’s National Emission Inventory. 

Nearly all data being developed and/or compiled will use computerized databases or other 

electronic files. For many of these databases, we will use blank fields in the database tables to 

keep track of the source of the data. We will also maintain a log of activities to document how 

the data described above were incorporated to create the SESARM inventories. The log will 

include complete descriptions of the data sources used, the procedures used to incorporate the 

data, the approach used to determine the completeness, and any contacts made with data 

submitters to resolve questions. A file will be maintained to ensure that the data handling records 

are retained and easily located. 

QA/QC Records. We will perform a variety of quality control reviews of the inventory. For 

example, we will check stack parameters, source classification codes, and geographic 

coordinates for point sources that emit at least 100 tons of any pollutant per year. Reports 

containing the results of these checks will be transmitted to the State/local agencies for 

investigation and correction. Documentation of each finding will include a description of the 

action or data reviewed that led to the quality concern and will provide recommendations for 

corrective actions. 

Corrective Action Records. Records of corrective and follow-up actions identified during the 

quality review process will be maintained. Both the corrective action identified and the results of 

the actions taken in response will be documented for inclusion in the final report. If no corrective 

action can be made, we will document the implications on the overall quality of the inventory. 

Data Reporting Package. The final data reporting package will contain four elements: 

 An emission summary report that describes the emissions inventory by pollutant and 

source category, summarizes the methods and data used to compile the inventory, 

assesses the limitations and appropriate uses of the inventory data, and contains any 

other information pertinent to the inventory (including emission density maps); 

 A quality assurance summary report that describes the quality assurance efforts 

completed, summarizes the corrective actions taken, and provides suggestions for 

further inventory improvement based on the results of the quality assurance process; 

 Electronic data files containing the SESARM inventories in NIF 3.0 format as well as 

SMOKE or other specified format (including GIS shape files where applicable); and 

 Electronic and paper files containing all original data submittals and all backup 

documentation will be stored on file at MACTEC for a period of no less than three 

years. 
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2.0 SAMPLING 

This section describes any sample handling, sampling methods, analytical methods, quality 

control requirements as they relate to samples, instrumentation testing, inspection, maintenance 

and calibration, consumable inspection and acceptance criteria, data acquisition requirements for 

non-direct measurements and data management operations. 

Since this project is an emission inventory development effort most of the sampling areas are not 

applicable to this work. 

2.1 Sampling Process Design (Experimental Design) 

No sampling will be performed as part of this work, thus this section does not apply to this work 

effort. 

2.2 Sampling Methods Requirements 

No sampling will be performed as part of this work, thus this section does not apply to this work 

effort. 

2.3 Sample Handling and Custody Requirements 

No sampling will be performed as part of this work, thus this section does not apply to this work 

effort. 

2.4 Analytical Methods Requirements 

No sampling will be performed as part of this work, thus no analyses will be performed so this 

section does not apply to this work effort. 

2.5 Quality Control Requirements 

No sampling will be performed as part of this work, thus this section does not apply to this work 

effort. 

2.6 Instrument / Equipment Testing Inspection, and Maintenance Requirements 

No sampling will be performed as part of this work, thus this section does not apply to this work 

effort. 

2.7 Instrument Calibration and Frequency 

No sampling will be performed as part of this work, thus this section does not apply to this work 

effort. 

2.8 Inspection / Acceptance Requirements for Supplies and Consumables 

No supplies or consumables affecting quality will be acquired as part of this work effort thus this 

section is not applicable. 
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2.9 Data Acquisition Requirements for Non-direct Measurements 

The base year and projection year SESARM inventories will rely primarily on air emission 

information from existing databases. The data collection, handling, and management process is 

described below, along with the associated quality control procedures and methods. The QC 

system is designed to: 

 Provide routine and consistent checks and documentation points in the inventory 

development process to verify data integrity, correctness, and completeness; 

 Identify and reduce errors and omissions; 

 Maximize consistency within the inventory preparation and documentation process; 

 Facilitate internal and external inventory review processes. 

The data acquisition process should be viewed as an iterative process. As decisions are made, 

new questions will surface that require solutions, until the iterations are complete. 

2.9.1 Base Year Inventory Update Procedures 

For the base year inventory update, the following procedures will be used to compile and quality 

assure the revised base year SESARM emission inventory: 

1. Discuss with States what information was submitted to EPA as part of the CERR process 

to determine where differences are between CERR and SESARM base year inventory 

2. For those States that indicate that CERR submittals should be used, obtain State CERR 

inventory submittals 

a. Download State files from EPA ftp site or EPA NEI version 3 files 

b. Prepare and review emission summaries at the SCC level to verify that emissions 

by source category, geographic region, and pollutant are complete and reasonable. 

c. Maintain log of data received and identify format. 

d. Compare facility level emissions from State/local agency submittal with CERR, 

identify significant discrepancies in emissions (especially PM2.5 and ammonia), 

identify potentially missing facilities. 

e. Provide State/local agencies with results of 2(b) and 2(d) and ask for State/local 

agency assistance in resolving any problems/issues that have been identified 

f. Obtain and process State/local agency corrections/updates as required 

3. Augment with PM2.5 data if State/local submittal did not include PM2.5 using EPA NEI 

augmentation methodology 

4. Augment with ammonia emissions data if State/local submittal did not include ammonia 

using EPA NEI augmentation methodology or possibly augment with ammonia emission 

data from the EPA TRI database (point sources only). 

5. Assess the procedures used to evaluate and to account for potential double counting. 
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6. Compare and augment (if necessary) with base year specific NOx and SO2 emissions data 

collected by ETS/CEM procedures by EPA’s Clean Air Market Division 

7. Track comments/concerns received and corrective actions taken 

8. Provide inventory for review by State/local agencies 

a. Prepare an emission summary report that describes the emissions inventory by 

pollutant and source category, summarizes the methods and data used to compile 

the inventory, assesses the limitations and appropriate uses of the inventory data, 

and contains any other information pertinent to the inventory 

b. Prepare a QA/QC summary report that describes the efforts completed, 

summarizes the corrective actions taken, and provides suggestions for further 

inventory improvement based on the results of the quality assurance process 

c. Provide data files containing the base year SESARM inventory in NIF 3.0 or 

other specified format 

d. Provide electronic data files in SMOKE or other specified format 

e. Track comments/concerns received and corrective actions taken 

9. Incorporate feedback from stakeholders and prepare final reports and electronic files. 

2.9.2 Projection Year Inventory Procedures 

For the projection inventories, the following procedures will be used to compile and quality 

assure the inventory: 

1. Prepare Base Growth Inventory 

a. Use the final version of the SESARM Base/Typical Year inventory 

b. Back calculate uncontrolled emissions for Base/Typical Year inventory to use as 

starting point for sources that will be grown for the projection inventory. 

2. Prepare/Obtain Growth and Control files 

a. Obtain growth factor files from EGAS or other appropriate growth factor source 

for use with categories that will be grown with growth factors. 

b. Obtain control factors for “on-the-book” and “on-the-way” controls as well as any 

controls for control strategy evaluations. Controls will be obtained from recent 

EPA rulemakings, proposed rules, and State SIPs. 

c. Obtain and calculate DOE energy efficiency factors for use with combustion 

sources. 

d. Determine/obtain growth factors for non-EGAS sources. Growth factors for these 

sources will be calculated from existing projection inventories prepared by EPA. 

Growth factors will be calculated using linear interpolation of projected emissions 

if the actual year is not available. 

3. Project sources using growth and control factors 

a. For sources to be grown using growth factors, apply growth and control factors. 

b. For combustion sources apply energy efficiency factor. 
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c. Identify and resolve any errors/discrepancies from the use of growth factors or 

other growth factor data 

d. Track comments/concerns received and corrective actions taken 

4. Determine emissions for sources requiring “typical” year emissions. 

a. These sources include EGUs and fires 

b. For fires obtain long term estimates of acres burned. Determine average fire 

emissions across the period that the data cover. Estimate “typical” emissions 

based on either average spatial distribution or random selection of fires across 

time period. 

c. Obtain typical year emission data from EGU sources coupled with long term 

reported CEM data. 

d. Alternatively use IPM projection inventories for projection years. If this approach 

is taken, review by stakeholders prior to final inventory. 

5. Develop mobile source emission inventories 

a. Prepare projected VMT for review by States/stakeholders for onroad mobile 

sources. 

b. Prepare MOBILE or MOVES input files for review by States/stakeholders. 

MOBILE/MOVES input files will contain required control programs either “on-

-the-books” or “on-the-way”. 

6. Conduct QA/QC to identify errors and inconsistencies 

a. Prepare emission density maps and ad-hoc reports to identify gaps and logical 

inconsistencies. 

b. Ask States/local agencies to provide feedback on large scale inconsistencies and 

on missing sources. 

c. Update database with State/local supplied revisions. 

d. Track comments/concerns received and corrective actions taken 

7. Provide inventory for review by State/local agencies 

a. Prepare an emission summary report that describes the emissions inventory by 

pollutant and source category, summarizes the methods and data used to compile 

the inventory, assesses the limitations and appropriate uses of the inventory data, 

and contains any other information pertinent to the inventory (including emission 

density maps for all source categories) 

b. Prepare a quality assurance summary report that describes the quality assurance 

efforts completed, summarizes the corrective actions taken, and provides 

suggestions for further inventory improvement based on the results of the quality 

assurance process 

c. Provide electronic data files containing the SESARM inventories in NIF 3.0 or 

other appropriate format 

d. Provide electronic data files in SMOKE or other appropriate format (including 

GIS shape files) 

e. Track comments/concerns received and corrective actions taken 
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8. Incorporate feedback from stakeholders and prepare final reports and electronic files 

2.10 Data Management 

MACTEC will provide to SESARM at least one electronic copy of all input files and output files 

for emissions models used to develop the emissions inventories (e.g., MOBILE/SMOKE or 

MOVES) and any supporting technical analyses to the SESARM Project Coordinator and State 

and Local Agencies in accordance with SESARM’s prescribed schedule. 

Inventory data shall be designed for archival on a common SESARM data website. MACTEC 

will promptly post the electronic inventory data on an interim web site. When a new version of 

the inventory is developed, previous versions of inventory shall be moved to an archive section 

of the website so that it is clear which data sets are the most recent. Some data may be kept on a 

password protected website. MACTEC will keep the website up-to-date. The procedures for data 

archival will be clearly described in the draft and final reports. At the conclusion of the project, 

MACTEC will provide the interim and final products in a format prescribed by SESARM to 

SESARM’s webmaster for permanent posting. 

Data storage and retrieval will be performed using MACTEC’s computer and Microsoft Access 

database management software. Some data may be stored in MySQL files (if MOVES is used to 

prepare the on-road emission estimates). 

Data file storage will be on MACTEC’s servers. The data on these servers is backed up nightly 

to a tape backup system. Restoration of lost or damaged files can be accomplished in a matter 

of hours. All data on MACTEC’s servers are limited access using password protected user 

profiles and storage spaces. Delivered files can be password protected or delivered in an 

uneditable format (e.g., locked PDF files). Spreadsheets will be protected to mitigate changes to 

any data submitted. 
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3.0 REPORTS TO MANAGEMENT 

The subsections in this group address the activities for assessing the effectiveness of project 

implementation and associated QA and QC activities. The purpose of the assessment is to ensure 

that the QA Project Plan is implemented as prescribed. The assessment consists of external 

activities that include a planned system of review and audit procedures by personnel not actively 

involved in the inventory development process. The key concept of this component is 

independent objective review by a third party to access the effectiveness of the internal Quality 

Control program and the quality of the inventory, and to reduce or eliminate any inherent bias in 

the inventory process. 

3.1 Project Status Reports 

Monthly project status reports will be delivered via telephone by the MACTEC Program 

Manager to the SESARM Technical Coordinator. The monthly status reports will include a 

discussion of any QA issues arising from either scheduled audits or interim findings as a result of 

on-going QA procedures. 

3.2 Results of Performance Evaluations and Audits 

The MACTEC Quality Assurance Coordinator will conduct technical systems audits throughout 

the project. Audits are managerial tools used to evaluate how effectively the emission inventory 

team complies with predetermined specifications for developing an accurate and complete 

inventory. The MACTEC QAC will conduct audits at the initiation of each project to review the 

Work Plan and QAPP, at the 50% complete and 75% complete levels to review the technical 

aspects of each project and at the 95% completion level to review the data submittal package. 

This provides assessment of the project during the planning stage, the data collection stage, the 

emissions calculations stage, and the report preparation stage. An example audit checklist for 

point sources is presented in Figure 2. 

3.3 Results of Periodic Data Quality Assessments 

Audit reports will be distributed within two weeks of the conduct of each audit to the persons 

interviewed and the MACTEC Task Leaders. A summary of the types of quality concerns found 

will be periodically forwarded to the MACTEC Program Manager to keep him informed of the 

quality issues found and actions being taken to resolve them. Audit reports will be retained in a 

file and used to conduct subsequent audits and plan follow-up activities. When an audit team 

finds items that require immediate action, they will inform the MACTEC Program Manager of 

the necessary corrective actions. 
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AUDIT CHECKLIST

Auditor: ______________________________________ 

Date: _________________________________________ 

Data/Procedure Reviewed: _____________________________________________________________ 

___________________________________________________________________________________ 

Project Personnel Involved in Work: _____________________________________________________ 

____________________________________________________________________________________ 

Instructions: Select a facility or source category with high emissions and evaluate the quality of the data 

and adequacy of the data handling procedures. Record the findings and recommendations for corrective 

actions, if any, on this checklist and comment sheet. If recommendations for corrective actions are made, 

discuss them with the Project Manager immediately following the audit. Conduct follow-up activities to 

determine if the actions taken in response to the recommendations appropriately resolved the quality 

issues identified. 

I. DATA

A. Identify the source category evaluated: _____________________________________________ 

B. Describe the data included in the master file for the facility or source category. 

 _____________________________________________________________________________ 

 _____________________________________________________________________________ 

C. Are the data documented in a manner that will not have the potential to be misinterpreted? Y/N 

 Were the instructions for documenting the data followed? ................................................. Y/N 

D. Are there missing data fields? .................................................................................................... Y/N 

 What procedures are taken by the Task Leaders to ascertain missing? 

___________________________________________________________________________ 

 ___________________________________________________________________________ 

 At what point in the inventory process are requests for missing data made? 

___________________________________________________________________________ 

 ___________________________________________________________________________ 

 How is the receipt of the missing data handled? 

 ___________________________________________________________________________ 

 ___________________________________________________________________________ 

 Is the procedure followed to ascertain missing data efficient and adequate? ............................ Y/N 

E. How do emissions compare to other inventories? 

 2005 NEI ________________________________________________________ 

 2005 TRI _____________________________________________________________________ 

 2005 ETS/CEM ________________________________________________________________ 

 Are differences in emissions understandable and explainable? ................................................. Y/N 

 If any of the values are incorrect, explain how the emissions data were corrected. 

___________________________________________________________________________ 

Figure 2 Audit Check Form
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II. EMISSIONS DATABASE

A. Who provided the data for incorporation into the database? __________________________ 

 _______________________________________________________________________ 

B. Was there evidence that the data were reviewed for accuracy and completeness prior 

 to incorporation in the database? ............................................................................................... Y/N 

C. Were data logs maintained to describe how the data was incorporated? ................................... Y/N 

D. Ask the data incorporation personnel to explain the QC procedures followed to ensure 

 data quality. Do they agree with the procedures described in the QAPP? ................................. Y/N 

E. Does the computer system appear to be adequate for its intended use? (Ask the 

 data processing personnel about the problems they have experienced with the system.) .......... Y/N 

F. Is the data entry progressing as expected and are the procedures followed adequate 

 to ensure data quality? ............................................................................................................... Y/N 

III. RECOMMENDATIONS FOR CORRECTIVE ACTIONS

_____________________________________________________________________________________ 

_____________________________________________________________________________________ 

_____________________________________________________________________________________ 

_____________________________________________________________________________________ 

_____________________________________________________________________________________ 

IV. COMMENTS

_____________________________________________________________________________________ 

_____________________________________________________________________________________ 

_____________________________________________________________________________________ 

_____________________________________________________________________________________ 

_____________________________________________________________________________________ 

V. SIGNATURES 

______________________________ ____________________________ 

(QA Auditor) (QA Coordinator) 

______________________________ ____________________________ 

(Program Manager) (Task Manager) 

______________________________ ____________________________ 

(Project Participant) (Project Participant) 

Figure 2 Audit Check Form (Concluded) 
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4.0 DATA REVIEW AND VALIDATION 

Section 4 addresses the QA activities that occur after the data collection phase of the project is 

completed. Implementation of these subsections determines whether or not the data conform to 

the specified criteria, thus satisfying the project objectives. 

4.1 Data Review, Validation, and Verification 

A qualitative discussion of accuracy will include an assessment of the extent to which the 

initially identified weaknesses in the inventory have been remedied through the use of improved 

activity data, emission factors, or other sources of information. Remaining weaknesses will be 

assessed. 

The accuracy assessment will include a summary of whether any data identified as outside of its 

valid range remained outside of the valid range in the final inventory. If any data remained 

outside of its valid range, an explanation will be given. The qualitative discussion will also 

include a summary of errors or discrepancies identified in the QA/QC process. 

A final semi-quantitative discussion of accuracy will consist of pollutant summaries for 

individual facilities, industry types, source categories, and statewide totals. The SESARM 

inventory will be compared to other peer-reviewed inventories, and where major discrepancies 

exist, we will provide an assessment of the reasons for the differences in emission estimates.

4.2 Validation Methods and Verification Methods 

A statement will be prepared assessing whether all required facilities, source categories, 

pollutants, and data elements were included in the inventory. If any facilities or source categories 

were not included, an explanation of the omission will be provided. If any individual data 

elements were not provided, we will discuss the elements, frequency of omissions, and overall 

impact on the quality of the inventory.

4.3 Reconciliation with User Requirements 

Several summations of emissions data will be made to address comparability. Overall percentage 

differences for individual facilities (current year to prior year), industry types, processes, and 

statewide inventory will be calculated. Explanations of any large differences will be made.

4.4 Representativeness Assessment 

A statement will be prepared describing where national defaults have been used instead of local 

activity data. 
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5.0 REFERENCES 

1. U.S. Environmental Protection Agency. March 2001. EPA Requirements for Quality 

Assurance Project Plans (EPA/240/B-01/003). http://www.epa.gov/quality/qs-docs/r5-

final.pdf

2. Emission Inventory Improvement Program (EIIP) Document Series - Volume VI Quality 

Assurance Procedures and DARS Software. EPA | TTN CHIEF | EIIP | Technical 

Reports | Volume VI Quality Assurance Procedures

3. U.S. Environmental Protection Agency. November 18, 2002. 2002 Base Year Emission 

Inventory SIP Planning: 8-hr Ozone, PM2.5 and Regional Haze Programs. 

http://www.4cleanair.org/members/committee/criteria/EPA200211181.pdf
Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories

Appendix A

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Appendix A – Memorandum of Understanding 
Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories

Appendix A

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MEMORANDUM OF UNDERSTANDING VISIBILITY IMPROVEMENT - STATE AND TRIBAL ASSOCIATION 

OF THE SOUTHEAST (VISTAS) 

WHEREAS, The national goal of the visibility program, as set forth by Congress, is to remedy any existing impairment 

and prevent any future impairment in mandatory Class I Federal areas that are caused by human activity; 

WHEREAS, The visibility program highlights the need to implement other regional planning processes to improve air 

quality in the geographic area located within the States of Alabama, Florida, Georgia, Kentucky, Mississippi, North 

Carolina, South Carolina, Tennessee, Virginia, and West Virginia; 

WHEREAS, These States and Tribes, who have the authority and responsibility to develop, adopt, and implement 

their individual State and Tribal air quality implementation plans, recognize the benefits of coordination on many of 

the projects relating to air quality that are underway in the region; 

WHEREAS, The Southeastern States Air Resource Managers (SESARM) has been designated by the United States 

Environmental Protection Agency (EPA) as the entity responsible for coordinating and implementing regional 

planning for the eight SESARM states (Alabama, Florida, Kentucky, Georgia, Mississippi, North Carolina, South 

Carolina and Tennessee) plus Virginia, West Virginia, and Tribes. 

NOW, THEREFORE, it is hereby agreed to by the signatories as follows: 

1. The parties agree to collaborate in the initiation and coordination of planning activities associated with the 

management of regional haze, visibility, and other air quality issues. This collaboration shall be known as Visibility 

Improvement - State and Tribal Association of the Southeast (VISTAS). 

2. The purposes of VISTAS are as follows: 

To promote the coordinated efforts of States and Tribes in their efforts to address federal regional haze and visibility 

requirements. 

To identify regional or common air management issues. 

To conduct research and undertake other activities to provide the membership with scientific and technological 

information which may be of value in development of agency strategies. 

To develop strategies on regional haze and other air quality issues for use by member States and Tribes, where 

appropriate, in developing their implementation programs, regulations and laws. 

4. VISTAS shall operate as described more fully in the attached Bylaws, which are hereby adopted by the parties to this 

Memorandum of Understanding (MOU). 

5. SESARM shall continue to operate as the entity responsible for applying for, receiving, and disbursing funds 

necessary for coordinating and implementing regional planning for the eight SESARM states plus Virginia, West 

Virginia, and Tribes. 

6. VISTAS shall not apply for, receive, or disburse any funds. In the Bylaws, “VISTAS funds”, “expenses of VISTAS”, 

and other such references shall mean SESARM funds used for VISTAS purposes. 

7. VISTAS has no independent regulatory authority and has no authority to direct or establish individual State or Tribal 

law or policy. Participants retain their own rights and legal authorities. 

8. This MOU is not a binding agreement. It is a voluntary collaboration of the parties to aid in planning activities 

associated with the management of regional haze, visibility, and other air quality issues. 
Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories

Appendix A

Revision No. 1.11

Revision Date: 7/29/09

Page 3 of 6

The Parties hereto have executed this MOU. 

Agreed to this______ day of ______________, 2001: 

For the Southeastern States Air Resource Managers (SESARM): 

Executive Director 
Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories

Appendix A

Revision No. 1.11

Revision Date: 7/29/09

Page 4 of 6

The Parties hereto have executed this MOU 

Agreed to this______ day of ______________, 2001: 

For The State of Virginia: 

Title 

 
Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories

Appendix A

Revision No. 1.11

Revision Date: 7/29/09

Page 5 of 6

The Parties hereto have executed this MOU 

Agreed to this______ day of ______________, 2001: 

For the State of West Virginia: 

Title 

 
Project: SESARM Base, Future Year, and Fire Control Strategy Emissions Inventories

Appendix A

Revision No. 1.11

Revision Date: 7/29/09

Page 6 of 6

The Parties hereto have executed this MOU 

Agreed to this______ day of ______________, 2001: 

For the Eastern Band of Cherokee Indians: 

Title