### 1 

# SHELBY COUNTY HEALTH DEPARTMENT

Pollution Control Section ( SCHD

- PCS)

SCHD

- PCS AIR EMISSION INVENTORY

QUALITY ASSURANCE PROJECT PLAN

(QAPP)

November 30, 2011

Shelby County Health Department

Pollution Control Section

814 Jefferson Avenue Memphis, Tennessee 38105

Phone 901

- 222

- 9599 • Fax 901

- 222

- 9550

### 2 Detailed Quality Assurance Project Plans (QAPP ’ s) for environmental data operations performed by or for the EPA are required by CIO 2105.0 (previously EPA Order 5360.1, P olicy and Program Requirements for the Mandatory Agency

- Wide Quality System ) . This QAPP provides

a n outline and guide for the Pollution Control Section of the Shelby County Health Department

, in formulating the compilation of a nnual and 3

- Year cycle i nvent ories and in general guides the compilation of related inventories needed for state implemantation plans such as: B ase Y ear, Reasona ble Further Progress (RFP), A ttainment D emonstration ( modeling ) , transportation conformity emission budgets, and redesignati on inventories

.

### 3 A. PROJECT MANAGEMENT

A1. TABLE OF CONTENTS

A2. Title and Approval Sheet 4

A3. Distribution List 5

A4. Project/Task Organization 6

A4.1 Roles and Responsibilities 7

A5. Problem Definition/Background 9

A6. Project/Task De scription 10

A6.1. Purpose/Background 10

A6.2. Description of the Work to be Performed 12

A7. Quality Objectives and Criteria for Measurement Data 13

A8. Special Training Requirements/Certification 14

A9. Documentation and Records 14

A9.1 Purpo se/Background 14

A9.2 Information Included in the Reporting Packages 14

A9.3 References 15

B. MEASUREMENT/DATA ACQUISITION

B5

. Quality Control Requirements 16

B 9

. Data Acquisition Requirements (Non Direct Measurements) 1 7

B 10

. Data Management 1 8

C. ASSESSMENT/OVERSIGHT

C1. Assessments and Response Actions 19

C2. Reports to Management 19

D. DATA VALIDATION AND USABILITY

D1. Data Review, Validation, and Verification Requirements 19

D2. Validation and Verification Methods 20

D3. Recon ciliation with Data Quality Objectives 20

APPENDICES

Appendix E1 Sources of Potential Point Sources 22 Appendix E2 EPA Inventory Checklist 23 Appendix E3 Area Source Categories 24 Appendix E4 Shelby County 2010 EIQ Email Letter 25 Appendix E5 E mission Inventory Questionnaire Instructions 26 Appendix E6 EIQ Screenshots 60

### 5 A3. DISTRIBUTION LIST

All individuals and their organizations designed to receive the QAPP and any subsequent

revisions are:

Robert Rogers

, Technical Man ager Billy Smith

, Engineering Supervisor Pollution Control Section, 4 th 

### Floor Major Source Branch Shelby County Health Department Pollution Control Section, 4 th 

### Floor

814 Jefferson Avenue Shelby County Health Department Memphis, TN 38105 814 Jefferson Avenue

901

- 222

- 9578/fax 901

- 222

- 9550 Memphis, TN 38105

901

- 222

- 9577/fax 901

- 222

- 9550

Pam Lindsey

, Supervisor Denis Fritchie

, Engineering Supervisor

Minor Source Branch Air Planning Branch Pollution Control Section, 4 th 

### Floor Pollution Control Section, 4 th 

### Floor Shelby County Health Department Shelby County Health Department

814 Jefferson Avenue 814 Jefferson Avenue Memphis, TN 38105 Memphis, TN 38105

901

- 222

- 9564/fax 901

- 222

- 9550 901

- 222

- 9580/fax 901

- 222

- 9550

Chris Boyd

– Lead Engineer Angie Pitcock Air Planning Branch Emission Inventory Manager Pollution Control Section, 4 th 

### Floor Tennessee Division of Air Pollution Control Shelby County Health Department 9 th 

### Floor, L & C Annex

814 Jefferson Avenue Nashville , TN 37243

- 1531 Memphis, TN 38105 615

- 532

- 0093/fax 615

- 532

- 0614

901

- 222

- 9571/fax 901

- 222

- 9550

Gwendolyn G. Graf Brenda Johnson Section 105 Project Officer Technical Project Officer U.S. EPA Region 4 U.S. EPA Region 4 61 Forsyth Street, S.W. 61 Forsyth Street, S.W. Atlanta, Georgia 30303 Atlanta, Georgia 30303

404

- 562

- 9289/fax 404

- 562

- 9095 404

- 562

- 9037 /fax 404

- 562

- 9095

Danny France Quality Assurance NManager U.S. EPA Region 4 980 College Station Road Athens, GA 30605

Phone: 706

- 355

- 8 738

### 6 A4

. PROJECT/TASK ORGANIZATION

The Clean Air Act of 1970 and the associated Amendments of 1990 provide statutory requirements for improving air quality in the United States. Quantification of air quality necessitates the gathering, storage, retrieval and analysis of air pollution data. These data, stored in the computer

- based National Emission Inventory (NEI) database system, provide information essential to inquiry, investigation and decision

- making. For example, analysis of the data may

lead to a mo re thorough consideration of certain industries or certain emissions sources, it may provide the basis for the development or evaluation of control strategies, and it may serve as the basis for an evaluation of the effectiveness of regulations.

The Shelby County Health Department , through the Pollution Control Section , collects data pertaining to the emissions of air pollutants and reports this data in turn to the Environmental Protection Agency (EPA) Administrator using the Exchange Network and the EIS Ga teway.

The reported data are drawn from submitted Emission Inventory Questionnaire (EIQ) spreadsheets for point source data. Calculations by various EPA approved methodologies are used for area sources. The National Mobile Inventory Model (NMIM) is used f or one area category, and the Mobile Vehicle Emission Simulator (MOVES) for mobile source data. These systems are installed on the agency’s computer system at the Shelby County Health Department

in Memphis . Data are updated and retrieved through various us er

- generated programs in this system, which is accessible to users via both a Wide Area Network (WAN) and a Local Area Network (LAN).

Because of the importance of air emissions data, assurance of its quality is essential. A thorough description of the ste ps involved in the collection, analysis, entry, and extraction of the data are described below, immediately following a discussion of the roles and responsibilities of the people involved in these tasks.

### 7 A4.1 ROLES AND RESPONSIBI LITIES

Organizational C hart

The e mission invent or y staff is responsible for the overall functioning of emissions inventory data management activities. Responsibilities include, among others:

• Ensuring t imely and accurat e entry of air pollution dat a into MS

- Access pertaining to targeted

indust ry annual emission inventory

.

• Providing reports to management.

• Ensuring timely transmission of required annual emission inventory data from the EIQ s to the NEI using the established BRIDGE tool and EIS Gateway for data conversion/retrieval.

• Providing minimally reportable data for Federal use.

• Serving as EPA point of contact for SCHD

- PCS air emissions inventory data.

• Setting quality assurance standards and initiating and coordinating p rojects and activities that improve the overall quality of the data.

• Participating in national meetings with EPA to stay current with emissions inventory issues.

• Directing the collection and quality assurance of area, on

- road and non

- road mobile source act ivity data and model inputs.

• Completing timely quality assurance of required annual/daily or seasonal emissions inventory

information.

• Providing input as requested for quality assurance of data for State use.

• Reviewing activity data and methodologies for c ompiling area source emissions inventories

• Extracting and mailing the E IQ s throughout the quality assurance and data entry processes.

• Maintaining a record of data entered. Robert Rogers Technical Manager/Program Manager
Pollution Control Section Emission Inventory Provides management review of inventory documents

and calculations to ensure quality a nd consistency.
Data user.

Denis Fritchie Engineering Supervisor/QA Officer Air Planning Branch Emission Inventory

Pro vides quality assurance of

inventory documents and

calculations.

Data user. 

## Shelby County Health Department

Chris Bo yd Lead Engineer/Project Manager Air Planning Branch Emission Inventory Reviews all calculations, methodologies, and data for accuracy. Compiles Point, Area, Biogenic,
Nonroad and On

- Road Mobile Data.
Data user. Bill Smith Engineering Supervisor
Title V Sources Branch

Checks for accuracy, completeness, comparability and reasonableness of point

source data.

Data user. Pam Lindsey Acting Supervisor
Minor Sources Branch
Checks for ac curacy, completeness, comparability and reasonableness of point

source data.

Data user.

### 8 Data Flow Chart

Data Managed and Stored in SCHD

- PCS Database

Data Submitted to EIS Production Environment via

Central Data E xchange (CDX)

Data Checked by EPA EIS QA/QC Tool via Central Data Exchange (CDX)

- Errors Fixed

Data Converted to EIS

On

- Road Mobile Source Format Data Converted to EIS

Area Source Format Data Converted to EIS

Point Source Format Data Converted to EIS

Non

- Road Mobile Source Format

Non

- Road Mobile Source Data

Reviewed & Validated On

- Road Mobile Source Data

Reviewed & Validated Area Source Data

Reviewed & Validated Point Source Data Reviewed, Validated, and Entered

I nto Database

Project Manager QA/QC Checks Project Manager Approval Project Manager QA/QC Checks Project Manager Approval Project Manager QA/QC Checks Project Manager Approval Project Manager QA/QC Checks Project Manager Approval

Engineering Quality Assurance Checks, Reasonableness Checks,

Validation Checks Engineering Quality Assurance Checks, Reasonableness Checks,

Validation Checks Compliance Engineers Check EIQs for Accuracy, Completeness, Comparability, Reasonableness Engineering Quality Assurance Checks, Reasonableness Checks,

Valida tion Checks

Calculation of Emissions Using

NONROAD Model Calculation of Emissions Using Activity Data Via Mobile Model Calculat ion of Emissions Using Activity Data Via Spreadsheets,
Models, Databases, etc. Receipt of Emission Certification Forms and EIQs Documented

Verify Mobile Model Inputs, Verify Changes to Mobile Model Default Settings Collection of Activity Data Surveys, Request Letters, Other Agencies,
Internet Searches, etc. Emission Certification Forms and Emission Inventory Questionnaires (E IQs) Received Verify NONROAD Model Inputs,

Verify Changes to NONROAD Model Default Settings

Collection of Activity Data Surveys,

Request Letters, Other Agencies,
Contractors, etc. Request Letters To Agencies,

Small Facilities Request Letter and Emission Inventory Questionnaire Sent to All

R egistered Sources Collection of Activity Data Surveys, Request Letters, Internal Searches,
Contractors, etc. Receipt of

Returned Data

Documented

### 9 A5. PROBLEM DEFINITION/BACKGROUND

The Quality Assurance Project Plan (QAPP) is being prepared for the development of air

emission inventor ies and to meet an EPA Section 105 grant co mmitment . An emission inventory is a tabulation of all sources of air pollutant emissions, complete with the

emissions from th o se sources, in a given area. Emission inventories are the fundamental building blocks used to develop air quality control strat egies and maintenance strategies on a local, regional, and national level.

The Air Emissions Reporting Rule ( A ERR) ( 73 FR 76539

, December 17 , 200 8 ) specifies the regulatory requirements for reporting emissions inventories. The reporting requirements also dictate the requirements for emission inventory data collection and quality assurance. The purpose of the AERR is to simplify reporting, offer options for data collection and exchange,

and to unify reporting dates for various categories of inventories.

The AERR establishes requirements for the reporting of s ulfur oxides (SO

x 

### )

, volatile organic compounds ( VOC )

, n itrogen oxides (NO

x 

### )

, c arbon monoxide (CO)

, l ead and lead compounds, p rimary PM 2.5 

### and p rimary PM 10 

### (to include condensible and filterable

emissi ons of each), ammonia ( NH 3 

### ); and, the reporting requirements for all types of sources (Poin t, Area, Onroad mobile, Nonroad , and Biogenic). It requires reporting on an annual cycle for selected point (Type A) sources and a 3

- Year cycle for all other ( Type B, Title 5, Synthetic Minor and smaller ) sources.

While the AERR integrates the reporting requirements of the Clean Air Act and 40 CFR 51.321, there are some additional s tate i mplementation p lan (SIP) inventory requirements that merit specific discussion as s ome inventories are developed for r easons other than the

standardized annual and triennial inventor ies . Differences can be due to inclusion of new emission factors, results from specific studies, and different inventory versions used for

different t im eframes or types of SIP submissions. In the past Shelby County has developed

emission inventories for different pollutants to demonstrate attainment and maintenance of associated NAAQS, using different generation methods

.

The Shelby County Health Departm ent

- Pollution Control Section ( SCHD

- PCS ) will include

emissions from p oint s ources, area sources, non

- road m obile s ources, and on

- road mobile

sources , as called for, in each emission inventory

. The SCHD

- PCS will supply emissions for point sources drawn fr om source submitted emission inventory questionnaires. If needed, t he

SCHD

- PCS will use the NONROAD 200 8 a emissions model t o generate emissions for off

road equipment and will use the Airport Emissions and Dispersion Model (EDMS5.1.3) to
generate a ircraft a nd ground support equip me nt emissions

. Aircraft engine emissions occuring during landing and takeoff operations and the ground suppot equipment and auxiallary power units associated with the aircraft will be included in the point source inventory. C ommerc ial marine emissions w ould be estimated from U.S. Army Corp of Engineers Trips and Drafts tables in concert with AP

- 42 emission factors with the emissions, whether underway or in

- port, to be included in the non

- point category

. Rail line s operating in

Shelb y County will be surveyed to obtain data such as hours of operation and fuel consumption in order to develop emissions utilizing AP

- 42. Railyard emissions will be included in point source inventories. E ither MOBILE6.2 or the MOVES 2010 a emissions

model will be used to generate on

- road mobile emissions

. After March 1, 2012, only

MOVES2010 a will be used for the deveolpment of inventories for SIPs with some possible

### 10 case

- by

- case exceptions. The SCHD

- PCS will consider EPA estimates for biogenic

emissions or wi ll develop them in

- house using BEIS3.12

.

Data has been and will be provided to EPA’s National Emissions Inventory (NEI) database using the most current v ersion of the NEI data format. Data will be provided in accordance

with the National Emission Factor a nd Inventory Group’s website instructions on the Air

CHIEF website and by e

- mail to EPA ( http://www.epa.gov/ttn/chief/eis /index.html 

### ).

In addition to use as a building block in developing air quality control and maintenance strategies, other specific uses of the emission inventory data include:

• State oversight of point sources

• Public Requests and Websites

• Use in the EPA National Annual Trends Report

• Emission Trading

• Compliance Demonstrations

• Document regulatory impact assessments

• Permitting

• Air Quality As sessments

• Human Exposure Modeling

A6. PROJECT/TASK DESCRIPTION

A6.1 PURPOSE/BACKGROUND

The SCHD

- PCS will create e mission i nventor ies to comply with Federal air quality standards and U.S. Environmental Protection Agency regulations and which may be used to aid in air quality planning, air quality modeling, and in environmental risk assessment

. The development and use of the emission inventories will improve the ability to plan for good air quality.

For A ERR reporting (annual and base year): As required by the A ERR, the SCHD

- PCS conduct s an annual (Type A) /triennial (Type B

, Title 5, Synthetic Minor) inventory to document air emissions, set permit requirements, and provide information to the EPA. The applications for emissions inventory data include use o f the data in annual trends reports, s tate i mplementation p lan (SIP) development , compliance demonstrations, emissions fees programs, the development of transportation conformity emission budgets and in modeling activities designed to evaluate ambient air concentrations encountered by the general public. For the SIP program, the air emission inventory is a bas is

in the develop ment of air quality control and maintenance strateg ies . S helby County regulations require point sources to report and certify emissio ns of air pollution

, annually.

Point Sources:

The SCHD

- PCS is the lead agency responsible for compiling the point source emissions inventory for Shelby County

, Tennessee , including identification of sources, documenting

the method used to calculate emissi ons from each source, and presenting the f indings.

The agency collects emission inventory data via a reporting process that starts with the annual inventory survey sent to major and minor point sources for the purpose of emission

### 11 fees payment followed by another survey , the Emissions Inventory Questionnaire (EIQ), to develop the technical aspects of the emission inventory . Records of permit holders , past
inventories and other sources of information pertaining to manufacturers in Shelby County

are used to c ompile list s of sources to be inventoried. S ources of information used to compile

the list s are provided in Appendix E1

.

Once received, agency personnel document receipt of the survey inventor ies, review and analyze the questionnaires for inconsistencies and discuss findings with permit engineers and specialists in the agency

. Lack of information and/or questionable information is discussed with the source prior to final acceptance. The inventory data is then consolidated into the

database and internal che cks are performed to verify its accuracy

, completion

, and consistency with database needs required by the NEI

. It should be noted that Federal Emission Inventory System ( EIS ) requirements are reviewed annually and the SCHD

- PCS EIQ and database is then amen ded to be equivalent to the EIS

. Sources not returning the questionnaire by specified date s are contacted

. F ailure to submit the surveys can result in

enforcement action s . See Section A9 for reference documents pertaining to data quality and

Section B5 fo r quality control requirements for point source inventories

. The data is then

entered into the e mission i nventory system when it’s accuracy has been verified by staff

.

The Shelby County stationary point source inventory is the result of efforts to charact erize pollutant emissions sources since the 1970's. The SCHD

- PCS database consists of a large

number of large (AERR Type A and Type B) and small air emission sources that have been compiled since th at time

. As a result, the database of point sources
, abo ve and below an actual emission level of 100 tons per year per pollutant

, is essentially, if not totally, complete. This database provides the foundation of new and future emission inventories developed by

the SCHD

- PCS

.

Several methods of source identifi cation are used by the SCHD

- PCS to ensure the point source inventory remains as complete as possible. The primary data source is the SCHD

- PCS major and minor source permit program , which overse e s the registration requirements found

in the air pollution con trol codes of Shelby County and the m unicipal itie s therein . These

codes have adopted by reference the State of Tennessee Chapter 1200

- 3

- 9,

CONSTRUCTION AND OPERATING PERMITS . The permit program identifies other point sources th r ough annual facility inspect ions of existing sources, through new source review and inspection, and through investigations conducted in response to citizen complaints. In addition, sources are found, investigated, and/or added to the source list by reviewing commercial news media

, tr ade association memberships, performing area surveillance, by refe rr als from other government agencie s
, the Chamber of Commerce, and

from source consultants

, among possible others

.

Following investigation, m ost of these sources are not considered to be po int sources as defined for inventory purposes, even though they may require permits. As an example, emissions from some sources can be less than one ton per year. However, all sources that are permitt ed by the SCHD

- PCS are tracked until notification is r eceived that the equipment or

emiss ion source has ceased operation

. As such, all point source emissions are then subtracted from the generated area source category, the remainder of which becomes the “area sources” category for Shelby County.

Area Sources :

### 12 Area sources are required to be included in 3

- Year cycle inventories. Methodologies for emission estimations are chosen and activity data is gathered for each area source category
base d on the availability of data a fter all activity data is collected by means of survey, request, research, or census. Calculations of area source categories are compiled using EPA guidance

, and after approval by the project manager, are entered into the emission inventory data system ( A ccess D atabase). Area Source Categories inventoried are listed in Appendix

E 3

.

On

- Road Mobile Sources:

On

- road mobile sources are required to be included in 3

- Year cycle inventories . On

- road mobile emissions are prepared by using EPA’s MOBILE6 .2 model or MOVES2010 to produce emission factors an d a local travel

- demand model Vehicle Miles Traveled (VMT). Data is compiled for EPA in the most current v ersion of the NEI data format.

Non

- Road Mobile So urces: Non

- road mobile sources are required to be included in 3

- Year cycle inventories

. S mall engin e emissions from various categories are calculated using EPA’s NONROAD 2008

emissions model. L ocomotive emissions are prepared in accordance with methodolog ies in

EPA’s Procedures for Emission Inventory Preparation, Volume IV: Mobile Sources . Aircraft

emis sions were calculated using EPA’s EDMS model. Data is compiled for EPA in the most

current v ersion of the NEI data format.

Biogenic Sources: Biogenic sources are required to be included in 3

- Year cycle inventories

. When calculated by the SCHD

- PCS, b ioge nic emissions are prepared using the EPA’s Biogenic Emission Inventory System (BEIS3 .12 ). Data is compiled for EPA in the most current v ersion of the

NEI data format. The SCHD

- PCS accepts b iogenic emissions estimates generated by EPA but retains the opti on of generating these emissions in

- house

.

A6.2 DESCRIPTION OF THE W ORK TO BE PERFORMED

1. P oint source surveys will provide annual (or seasonal) actual emissions data on a 1

- year (actual emissions of 100 tons per year and greater) or 3

- y ear (actual emis sions less than 100 tons per year) cy cle. Questionnaires are mailed on or about February 1 each year and source response is required by April 1. The data is reviewed, corrected where necessary

and forwarded to EPA on or before December 15.

2. A pplicable t echnical criteria to be used are found in the example instructions and screenshots of the EIQ (see Appendices E5 and E6) . Section A9 lists all reference

material.

3. P ersonnel and e quipment r equirements: Staff performing data review and analysis are profe ssional engineers or have sufficient education/experience to perform emission

estimat ion calculations and work with models. The agency has the computer equipment

and software necessary to run the MOBILE6.2 , MOVES2010a, NONROAD2008 and

BEIS 3.2 models. Trai ning requirements are outlined in Section A8.

4. The following activities will be utilized for review of data:

• Survey Review

### 13 • Comparison of like industries

• Checklist Requirements

• Peer Review

• Audit of Coordinates

• Certified Emission Statement Review

• Audit of emission estimate calculations completed before data is forwarded to EPA

• Comparison of Permit Allowabl es to Emission Inventory Survey

• Compa rison of Toxic Release data to data provid ed in Emission Inventory Survey

5. Schedule of Work:

• Preparation of s urve y ( Mail out survey by February following the year to be surveyed )



### • Receipt of s urvey ( April following the surveyed year)



### • Internal r eview ( May to December following the surveyed year)



### • Preparation of a rea s ource i nventory (January to November following the su rveyed year)



### • Preparation of m obile s ource i nventory (January to November following the surveyed year)



### • Pr eparation of b iogenic i nventory ( January to November following the surveyed year)



### • Approv al of i nventory ( December following the surveyed year)



### • Compilati on of data in NEI f ormat (as soon as emissions are calculated and verified they are placed in NEI Format)



### • Submittal to EPA: Emission r eport to the Regio n, Electronic Data to the NEI.

(Emission r eport s are submitted on or before (December 15) the required r eporting date , December 31

, following the surveyed year )



### 6. Projec t and Quality Records Required:

• Completed surveys on file

• Completed checklists on file

• Documentation of other data bases used for information on file

• Emission Report to the Region on file

• C orrespondence to sources and EPA on file

A7. QUALITY OBJECTIVES AND CRITERIA FOR MEASUREMENT DATA

Emission data collected for reporting to the NEI will encompass industrial air pollution

sources, area sources, non

- road mobile sources, and on

- road mobile sources. Emission inventories will be entered on an annual basis for Type A point sources and every three years (or less) for smaller point sources

. A rea and mobile source emissions will be submitted in lieu of EPA generated emissions every three years or as deemed necessary. The data will generally be used as discussed in Section A.5.

Data quality objectives of accuracy, completeness, comparability, and representativeness are addressed to ensure an inventory of high quality. The target goals for each obj ective are listed

below.

Accuracy: All estimates must be calculated and documented using acceptable methods. Individual source requirements and availability of data and resources will affect the

estimation method selection.

### 14 Completeness: Completeness is addressed by ensuring that all point sources (depending upon thresholds) and all applicable area source categories are included in the inventory, and that all information required to estimate emissions is present. Applicable area source categories

are list ed in Appendix E3.

Comparability: Data will be compared to the most recent base year inventories depending upon the purpose of the project. Generally the base year for the most recent NEI will become the previous NEI (i.e, the 2005 for the 2008 NEI). Diff erent base years for various SIPs and budgets will be determined depending upon future needs driven by regulatory requirements and past accomplishments as warranted. P erceived discrepancies (data outliers) in comparin g

one year to another will be corrected or justified.

Representativeness: Actual annual and seasonal daily emissions , as appropriate, will be

calculated and compared to base year inventor ies

. Local data will be used in inventory calculations wherever possible.

A8. SPECIAL TRAINING REQUIREME NTS/CERTIFICATION

All emission inventory quality assurance staff shall have a minimum of a bachelor’s degree in engineering or related scientific discipline. These staff members are trained in standard emissions estimation methods. The current training re quirement is “in house” or on

- the

- job training. Memberships in environmental organizations are voluntary.

A9. DOCUMENTATION AND RECORDS

A9.1 Purpose/Background

C ompleted point source EIQs, area source, non

- road mobile source, and on

- road mobile

source data is retained by the SCHD

- PCS. Hard copies of questionnaires and other relevant data are kept in files man a ged by the emission inventory lead engineer. Electronic copies of the EIQ and other electronic data are kept on SCHD

- PCS computer hard drives and in Shelby County Information Technology archives. Backup disks are created to store completed files

as well. D ata is kept for an indefinite period of time and can be found dating back to the

1970’s.

A9.2 Information Included in the Reporting Packages

Poi nt Source: Electronic files are submitted to EPA through the Exchange Network Web Client v2.0 and the EIS Gateway annually an d on a three year basis

.

Area, & Mobile Sources: Emissions from area, on

- road mobile, and non

- road mobile sources are reported as a Shelby County total. The VOC, NOx, CO, PM10, PM2.5, SO2, and ammonia emissions are reported in annual tons per year and in daily tons per average ozone season day. In addition, emissions for each category are reported by individual Source

Classification Code (SCC). For non

- road mobile sources the SCCs are combined into classes (e.g., lawn and garden equipment, construction equipment) as class totals. Summary tables are provided which include major category (point, area, on

- road mobile, and non

- road

mobile ) totals. Historically, inventories developed for these categories have been used ‘in

-

### 15 house’ and EPA generated inventories for Shelby County have been used in the NEI. The option exists for SCHD

- PCS to generate and submit these categories for use in the NE I. Should this occur, this information will also be submitted to EPA through the Exchange Network Web Client v2.0 and the EIS Gateway.

A9.3 References

• References used to compile the inventory include:

• 2008 NEI/ EIS Implementation Plan ( http://www.epa.gov /ttnchie1/net/neip/index.html )

• EPA CHIEF Emission Factor and Inventory Group : http://www.epa.gov/ttn/chief

• EPA NEI EIS Data Submittal Procedures : http://www.epa.gov/ttn/chief/ei s /index.html

• EPA Emissions Inventory Guidance for Implementation of Ozone and P articulate Matter

National Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations

, EPA454/R

- 05

- 001, August 2005

• EPA Handbook for Criteria Pollutant Inventory Development: A Beginner’s Guide for

Point and Area Sources , EPA454 / R

- 99

- 037, Septembe r 1999

• Emission Inventory Improvement Program, Volume I, Introduction and Use

• Emission Inventory Improvement Program, Volume II, Point Sources

• Emission Inventory Improvement Program, Volume III, Area Sources

• Emission Inventory Improvement Program, Volume I V, Mobile Sources

, EPA420/R

- 92

- 009, December 1992

• Emission Inventory Improvement Program, Volume VI, Quality Assurance Procedures

• Emission Inventory Improvement Program, Volume VII, Data Management Procedures

• Technical Highlights, Emission Factors for Loco motives , EPA420/F

- 09

- 025, April 2009

• AP

- 42, Fifth Edition, Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources

• EPA Non

- Road Model : NONROAD2008a

• EPA On

- Road Model s: MOBILE6.2 or MOVES2010a

• EPA Quality Review Guidelines for 1990 Base Year Emission Inventories ; EPA454/R

92

- 007; August 1992

• EPA Procedures for the Preparation of Emission Inventories for Carbon Monoxide and Precursors of Ozone , Volume 1, EPA454/4

- 91

- 016; May 1991

• EPA December 200 7 Guidance for Quality Assura nce Project Plans , EPA QA/G

- 5 Final

• United States Census Bureau : County business (employment) and residential patterns (employment)

• Tennessee Department of Transportation (TDOT)

- Vehicle Miles Traveled and Lane

Miles

• Federal Highway Administration Annual Report of Highway Statistics: For miles

traveled.

• State and County Highway Department Records: Traffic paint usage values, lane miles painted.

• Railroad Survey s

• Class I: Burlington Northern Sante Fe, Union Pacific, CSX, CN, NS

• Passenger: AMTRAK

• Commercial M arine : U.S. Army Corp of Engineers Trips and Drafts Tables

• Aircraft : Airport Emissions and Dispersion Model EDMS5.1.3

### 16 B. MEASUREMENT/ DATA ACQUISITION

B5. QUALITY CONTROL REQUIREMENTS

Point Source: The SCHD

- PCS maintains a list of all point sources that have received air pollution control operating permits. Sources are added to the list as a result of construction and operating permit applications, complaints received, surveys performed, media releases and referrals from other agencies and the community. This list is maintained and is relied upon to actuate Type A and Type B major source lists as the case may be. Once attained, these sources are required to provide technical data to better understand and estimate emissions and emissions potential. Sources that close are included in the system until such time as it is apparent, with certainty, that they will not reopen in the future. Often, closure letters are required, where possible, and inspections performed, if needed, to verify such events. Existing so urces are required by law to verify their annual emissions. File reviews and source inspections are conducted annually on major sources and every three years on

minor sources as a check on the sources status. Enforcement action is taken where needed to

ass ure continued compliance with Shelby County regulations.

The SCHD

- PCS is authorized to collect air emission inventory information in Shelby County, Tennessee pursuant to a number of laws and regulations which are cited in the transmittal letter to the sou rces . This

letter can be found in Appendix E 4

.



### Estimation Methods And Data Gathering

Information s ources found in A9.3 will be utilized to select estimation methods and gather information necessary to develop the inventory . See Appendix E 5 and E 6 ( EIQ in structions and EIQ screenshots)

. QC activities during data gathering include thorough documentation of methods and data sources, and checking for reasonableness of data obtained. General

estimation methods and calculations are discussed in the EIQ instruct ions. The emissions are compared with previous year emissions to detect significant differences.

Missing Data Missing data will be identified by the inability to complete the calculations. If data are found to be missing, a reasonable effort will be made to acquire the data. If this is unsuccessful, estimates will be made based on past years' data or default information contained in EPA

documents and models. Sources of all data are required to be documented.

Application Of Rule Effective And Rule Penetrat ion Rule effectiveness (RE) reflects the ability of a control device or regulation to achieve all the emission reductions that could be achieved by full compliance at all times. Rule penetration (RP) is a measure of the extent to which a regulation covers emissions from a source

category. RE/RP has been the subject of ongoing discussion nationally and is the topic of a draft report by the Emissions Inventory Improvement Program (EPA/STAPPA/ALAPCO). Briefly, the report recognizes that control efficiencies are often based on in

- use conditions, and when this is the case, RE has already been taken into account. This is the situation for point sources in the NAAs. Additionally, some point source emissions are estimated through source testing, and therefore do not use control efficiencies and RE/RP to calculate emissions. For area sources, SCHD

- PCS will evaluate each control measure to determine whether EPA default RE and RP estimates (80% and 100%) should be applied or some more

r epresentative value used

.

### 17 Corr ective Action

Corrective and follow

- up actions identified during the inventory development process will be noted and referred to the appropriate staff. Both the corrective actions identified and results of actions taken in response will be documented and k ept on file.

Written documentation specifying inventory methodology and information sources will be required

.

Area and Mobile Sources : Emissions will be documented in order to trace the sources of the methodologies and activity data, including work perfo rmed by contractors. Checklists, emissions comparison tables, and methodology audits are used in the quality assurance process to ensure completeness of data and conformity with methodologies. Peer review of contracted and staff generated emissions estimat ions are conducted by staff. Modeling staff reviews the data as well prior to usage. Rule effectiveness and rule penetration are incorporated into affected category emissions. Emissions from point sources are subtracted where applicable. The emissions are compared with previous year emissions to detect significant differences. These significant differences are further reviewed for accuracy. All categories are reviewed to determine validity.

In General

• All emission calculations shall be traceable to source reporting or county estimation

methods.

• Locations of point sources shall be physical addresses; source names shall includ e the corporate name and site.

• All latitudinal and longitudinal coordinates will be verified for accuracy

.

• N on

- reactive volatile organi c compounds will not be included as VOC based upon the

most recent version of 40 CFR 51.100

.

B 9

. DATA ACQUISITION REQUIREMENTS (NON

- DIRECT MEASUREMENTS)

Point Source: All point

- source data are acquired directly from reporting companies.

Area & Mobile S ources : Area source c ategories are listed in Appendix E3 . Other general area categories will be obtained from EPA draft versions of the NEI. Quality control requirements described in Section B5 will be applied, which may require replacement or

elimination of generic data with specific data. Generic data may be replaced with better activity or surrogate data. Better activity data consists of the use of the results of surveys of categories reporting actual activity data (e.g., fuel use or paint or solvent use ), which is used in emissions calculations. More appropriate surrogate data m ay be used (e.g., the actual number of employees occupied in an area source business type) to estimate emissions as opposed to using the total county population to estimate emissi ons from that category.

As generic data may be limited in scope or developed for a different domain, data specific to Shelby County will be sought out and used whenever available , to include converting state and national statistics to county relevant data . Such limitations are noted in national and state

level data that when apportioned to the county level tend to misstate the impact of the

### 18 category. This is readily apparent in aviation, commercial marine, and railroad data for Shelby County.

Additional D ata Sources

United States Census Bureau

- County business patterns (employment)

Tennessee Department of Transportation

- Vehicle Miles Traveled / Lane Miles

B 10

. DATA MANAGEMENT

The following information in this section generally describes the efforts t aken to collect, protect, and report emission inventory data for Shelby County, Tennessee, so that it may be used by the EPA, other agencies, and the public

, with a high degree of confidence.

Completed point source EIQs, area source, non

- road mobile sourc e, and on

- road mobile source data is retained by the SCHD

- PCS. Hard copies of questionnaires and other relevant data are kept in files managed by the emission inventory lead engineer. Electronic copies of the EIQ and other electronic data are kept on SCHD

- PCS computer password protected hard drives and in Shelby County Information Technology archives. Backup disks are created to store completed files as well. Data is kept for an indefinite period of time and can be found dating back to the 1970’s.

Screensh ots of the standard E IQ form used for point source submittal can be found in Appendix E6 . This form is in MS

- Excel and therefore the staff has Excel on their computers.

This data is then transferred into MS

- Access which is also available to staff

.

The sta ff also ha s Internet access to contact companies and to submit data to EPA in the NEI format and to the public and other agencies as needed in a readible format . The Bridge tool,

downloadable from EPA’s site is also used

.

In order to process the off road and on road data, both the NONROAD2008 model for

non road mobile and Mobile Vehicle Emission Simulator (MOVES) for mobile source data

are used

.

Locomotive emissions are prepared in accordance with methodologies in EPA’s Procedures for Emission Inventory Pr eparation, Volume IV: Mobile Sources . Aircraft emissions were calculated using EPA’s EDMS model. Data is compiled for EPA in the most current version

of the NEI data format.

Again, s creenshots of the electronic EIQ are found in Appendix E6

. The EIQ can be used as

a checklist and as a reporting tool for emissions from po i nt sources that are required to be

submitted to the SCHD

- PCS.

Models for the generation of on

- road and non

- road mobile will be used as checklists in and

of themselves. Default values in th ose models, EDMS, NONROAD2008, and MOVES2010a, will be used where applicable, and will be replaced, where appropriate, with values specifice to Shelby County, Tenne ssee.

### 19 Area source checklists will be developed depending upon the area source category and will generally follow guidance found in the Emission Inventory Improvenment Program (EIIP) or

AP

- 42, among others.

C. ASSESSMENT/OVERSIGHT

C1. ASSESSMENTS AND RESPONSE ACTIONS A number of data quality assessments are performed on the data before it is s ubmitted to

EPA.

Point Source : When at least 95 percent of the sources in an EIQ cycle have been completed, emission inventory team members conduct a quality assurance survey of all data, identifying incorrect or suspicious data, including large sources o f unspeciated VOCs, suspiciously high annual emissions rates, suspiciously high and suspiciously low ozone season emissions rates, probable errors in emissions determination methodologies, suspect emission point parameters, and incorrect or suspicious Lat/ Long coordinates for emission points. By comparing the numbers to those in other inventory databases, the team may identify discrepancies in the reporting of hazardous air pollutants. Any suspicious or incorrect data discovered during this process is inve stigated and documented.

As a final step in the QA process, the emission inventory team considers each account individually, comparing the total account emissions for the current year with those from the previous year. Following the completion of the QA process, the emission inventory team evaluate the types of errors and their causes, and when appropriate implement guidance for QA review to decrease errors discovered during the QA process.

Area and Mobile Sources : The inventory team conducts audits of n ewly completed area and mobile emissions inventories. Audits are performed comparing two or more inventories for the same year and categories to determine the most accurate methodologies being used in development. The final inventory will be comprised of d ata from the audited inventories with the best methodologies having been selected on a category

- by

- category basis.

The inventory team is responsible for ensuring that updates are made and that correct replacement methodologies are implemented. MOVES mode l input data is carefully audited by inventory staff to ensure accuracy of emissions calculations.

C2. REPORTS TO MANAGEMENT

Status and summary of point source accounts and area and mobile source types and level s of

emissions are reported to the Air Plann ing Branch S upervisor and the Pollution Control Section Technical Manager, among others, upon request.

D. DATA VALIDATION AND USABILITY

D1. Data Review, Validation, and Verification Requirements

The SCHD

- PCS will accept, reject, or qualify data in an ob jective and consistent manner depending on the validity and verification of the data source. Stationary point sources, for

### 20 instance, must certify their emission levels with the signature of a responsible company official (i.e., owner, operator, CEO). Data review is an in

- house examination to ensure that data have been recorded, transmitted, and processed correctly. That includes, for example, checking for data entry, transcription, calculation, and transformation errors.

D2. Validation and Verification Met hods

Once input data is gathered , it is used to calculate emissions for on

- road, non

- road, and area

sources. For point sources, if the EIQ is found to be complete and acceptable, the stated emissions are used as provided. If emissions calculated or receive d are not comparable with similar inventories or seem to have discrepancies

, the staff will check and if needed contact
the data source and correct the errors. The Project Manager will finalize any methods used,

correctio ns made , or the acceptance of emiss ion s data

.

EIQs are filed and maintained by the SCHD

- PCS. They are available to the EPA, and others, in toto, where confidential information has been taken into account. Outputs from the on

road and non

- road models list the information used to generate th e results and are therefore available upon request. Area source information is available upon re q uest and will show calculations made and assumptions used in generating their results.

D3. Reconciliation with Data Quality Objectives

The SCHD

- PCS intends t o address, to the extent feasible, NEI requirements which are used in the development of emission inventories for NAAQS and hazardous air pollutants. To this end, emission inventories developed by the EPA for on

- road and non

- road mobile and area

sources ar e reviewed and considered against inventories generated in like manner by the

SCHD

- PCS and takes into account new EIIP and Office of Transportation Air Quality guidance . Where anomalies occur, data in

- puts of both inventories are studied as to their

proper relevance and a decision is made to accept one which is deemed more accurate for Shelby County. Data specific to Shelby County and the surrounding area is generally preferred by the SCHD

- PCS to data with a regional or national connotation.

Concerning sta tionary point sources, requirements of the EPA’s NEI are reviewed annually

and modifications are then made to the SCHD

- PCS Emission Inventory Questionnaire (EIQ) so that data obtained from Shelby County point sources are equivalent or equal to data that

wo uld be required by EPA should EPA conduct such a survey of Shelby County. Stationary

p oint sources , in addition to reporting information requested by the EIQ, must certify their

emission levels with the signature of a responsible company official. In the a bsence of other emission inventories, this certification acts to validate as much as possible the data and the calculated emissions sent to EPA for input to the NEI. A newly developed inventory will be compared to previously developed inventories to check for completeness and correctness of

data and for the purpose of discovering changes in emissions that may or may not have been

discovered in source compliance inspections and file review. These comparisons will take

into account new EIIP and AP

- 42 guidance

.

Other audits and activities will be conducted as deemed appropriate and include, among other things, the following :

Peer Review: An o ngoing data review and validation will be conducted by staff, the

P roject M anager and the Q uality A ssurance O ffice r bef ore entering emissions and data

into the SCH D

- PCS da ta system.

### 21 Independent Audit: Can be conducted by a contract or or by a different agency upon request by the EPA.

Survey Check: Once all survey data is collected and emissions are verified for each point source, data is input into the SCHD

- PCS data system by the project manager who

insures that each point source is accounted for.

TRI Audit: Project Manager will compare calculated and reported emissions SCHD

- PCS

emissions to recent TRI data and report dis crepancies to an SCHD

- PCS e nforcement personnel

.

SCHD

- PCS data review by EPA: Data submitted to the NEI will be checked by EPA’s EIS QA. When corrections and/or changes have been made and all errors removed, the data is finalized and input into EPA’s EIA production environment.

Permit Allowables to Actual Emissions Comparison : P roject Manager will use M S

Access software to quarry, compare, and maintain a record of allowable to actual

emissions.

### 22 

## APPENDICES

APPENDIX E1 : SOURCES OF POTENTIAL POINT SOURCE S

• The SCHD

- PCS Air Quality Permit Program

o Records of local air permit holders

• The SCHD

- PCS Air Quality Compliance Program

o Stationary Source Inventory Database

• The SCHD

- PCS Complaint Program

• The Commercial Appeal

– a general circulation newspaper

• The Dail y News

– a general circulation newspaper

• Referrals from sister agencies

• Referrals from the Chamber of Commerce

• Referrals from source conultants

• Referrals from trade association memberships

### 23 APPENDIX E2 : EPA INVENTORY CHECKLIST

Emission Inventory Checklist

Note: The checklist is intended to be a guide for completing company emission review.

Company Name:_________________________________

Date E IQ received:_______________________

E IQ Review

_____Company c ontact person present _____Erroneous or generic S CC’s were replaced where possible
_____Erroneous p ollutant c ode were replaced where possible
_____Emission units are correct units _____Legally responsible party signed the Emissions Data Certification Form _____All of the EIQ pages were returned

Access R eview

_____All tables are present
_____Data is in correct column for each table _____All duplicate emissions are removed _____All non operating units are removed

Final Steps

_____Convert using BRIDGE tool _____Zip the XML (extended markup language) file _____Upload company to QA _____Review feedback report for critical errors

If errors are found _____Correct any Critical or System Errors Found _____Convert using BRIDGE tool _____Zip the XML file _____Upload company to QA _____Review feedback report for c ritical errors, repeat above steps, as necessary When ready for Production, proceed below _____Change file to Production _____Convert using BRIDGE tool _____Upload company to Production _____Review feedback report for critical errors Repeat above steps as necessary to get it right.

### 24 APPENDIX E 3 : AREA SOURCE CATEGORIES

2102006000 Stationary Fuel Comb /Industrial /Natural Gas /Total: Boilers and IC Engines 2102007000 Stationary Fuel Comb /Industrial /Liquified Petroleum Gas /Total: All Boiler Types

21 02011000 Stationary Fuel Comb /Industrial /Kerosene /Total: All Boiler Types 2103006000 Stationary Fuel Comb /Commercial/Institutional /Natural Gas /Total: Boilers and IC Engines 2103007000 Stationary Fuel Comb /Commercial/Institutional /Liquified Petroleum Gas /Total: All Combustor Types 2103008000 Stationary Fuel Comb /Commercial/Institutional /Wood /Total: All Boiler Types 2103011000 Stationary Fuel Comb /Commercial/Institutional /Kerosene /Total: All Combustor Types
2104004000 Stationa ry Fuel Comb /Residential /Distillate Oil /Total: All Combustor Types 2104006000 Stationary Fuel Comb /Residential /Natural Gas /Total: All Combustor Types 2104007000 Stationary Fuel Comb /Residential /Liquified Petroleum Gas /Total: All Combustor Ty pes 2104008100 Stationary Fuel Comb /Residential /Wood /Fireplace: general 2104008300 Stationary Fuel Combustion/ Residential/ Wood/ Woodstove: freestanding, general 2104009000 Stationary Fuel Comb /Residential /Firelog /Total: All Combustor Types 2104011000 Stationary Fuel Comb /Residential /Kerosene /Total: All Heater Types 2294000000 Paved Roads /All Paved Roads /Total: Fugitives 2296000000 Unpaved Roads /All Unpaved Roads /Total: Fugitives 2301030000 Chemical Manufacturing /Process Emissions from Pharmaceutical Manuf /Total

2302000000 Food & Kindred Products /All Processes /Total
2311010000 Construction: SIC 15

- 17 /Residential /Total
2311020000 Construction: SIC 15

- 17 /Industrial/Commercial/Institutional /Total

231103000 0 Construction: SIC 15

- 17 /Road Construction /Total
2399000000 Industrial Processes: NEC /Industrial Processes: NEC /Total 2401001000 Surface Coating /Architectural Coatings /Total: All Solvent Types 2401005000 Surface Coating /Auto Refinishi ng /Total: All Solvent Types 2401008000 Surface Coating /Traffic Markings /Total: All Solvent Types 2401015000 Surface Coating /Factory Finished Wood /Total: All Solvent Types 2401020000 Surface Coating /Wood Furniture /Total: All Solvent Types

24 01040000 Surface Coating /Metal Cans /Total: All Solvent Types 2401050000 Surface Coating /Misc Finished Metals /Total: All Solvent Types 2401055000 Surface Coating /Machinery & Equipment /Total: All Solvent Types 2401065000 Surface Coating /El ectronic & Other Electrical /Total: All Solvent Types 2401075000 Surface Coating /Aircraft /Total: All Solvent Types 2401080000 Surface Coating /Marine /Total: All Solvent Types 2401085000 Surface Coating /Railroad /Total: All Solvent Types

240109 0000 Surface Coating /Misc Manufacturing /Total: All Solvent Types 2401100000 Surface Coating /Industrial Maintenance Coatings /Total: All Solvent Types 2401200000 Surface Coating /Other Special Purpose Coatings /Total: All Solvent Types

241500000 0 Degreasing /All Processes/All Industries /Total: All Solvent Types 2420000000 Dry Cleaning /All Processes /Total: All Solvent Types 2425000000 Graphic Arts /All Processes /Total: All Solvent Types
2440000000 Misc Industrial /All Processes /To tal: All Solvent Types

2460100000 Misc Non

- indus: Consumer & Comm /All Personal Care Products /Total: All Solvent Types

2460200000 Misc Non

- indus: Consumer & Comm /All Household Products /Total: All Solvent Types

2460400000 Misc Non

- indus: Consume r & Comm /All Auto Aftermarket Products /Total: All Solvent Types

2460500000 Misc Non

- indus: Consumer & Comm /All Coatings & Related Products /Total: All Solvent Types

2460600000 Misc Non

- indus: Consumer & Comm /All Adhesives & Sealants /Total: All S olvent Types

2460800000 Misc Non

- indus: Consumer & Comm /All FIFRA Related Products /Total: All Solvent Types

2460900000 Misc Non

- indus: Consumer & Comm /Misc Products (Not Otherwise Covered) /Total: All Solvent Types

2461021000 Misc Non

- industria l: Commercial /Cutback Asphalt /Total: All Solvent Types

2461022000 Misc Non

- industrial: Commercial /Emulsified Asphalt /Total: All Solvent Types

2461850000 Misc Non

- industrial: Commercial /Pesticide Application: Agricultural /All Processes

246580000 0 Misc Non

- indus: Consumer /Pesticide Application /Total: All Solvent Types 2501000000 Petroleum and Petroleum Product Storage 2505000000 Petroleum and Petroleum Product Transport
2601000000 On

- site Incineration /All Categories /Total

261000050 0 Open Burning /All Categories /Land Clearing Debris (use 28

- 10

- 005

- 000 for Logging Debris Burning)
2630020000 Wastewater Treatment /Public Owned /Total Processed 2640000000 TSDFs /All TSDF Types /Total: All Processes 2801000003 Agric

- Crops / Tilling 2801700000 Agric

- Crops /Fertilizer Application 2805000000 Agric

- Livestock 2810010000 Human Perspiration and Respiration /Total
2806010000 Domestic Animals Waste Emissions /Cats /Total

2806015000 Domestic Animals Waste Emissions /Dogs /Total
2807030000 Wild Animals Waste Emissions /Deer /Total 2810030000 Structure Fires /Unspecified

### 25 APPENDIX E 4 : SHELBY COUNTY 2010 EIQ EMAIL LETTER

Dear :

The Shelby County Health Department

– Pollution Control Sect ion (SCHD

- PCS) is conducting the 2010 Emissions Inventory Questionnaire (2010 EIQ) of major sources. The goal of the 2010 EIQ is to have all major sources update the emissions that were furnished to SCHD

- PCS in the 2009 EIQ

. Since we expect this to be fair ly simple, facilities are required to submit their completed 2010 EIQ to
the SCHD

- PCS by close of business on December 22, 2011

.

To accomplish this task, SCHD

- PCS has attached to this e

- mail a MS

- Excel workbook loaded with the emissions data provided for your facility in the 2009 Emissions Inventory Questionnaire (2009 EIQ). Each workbook contains 4 spreadsheets as follows:

• General Plant Information Form Note: data reported in the 2009 EIQ is provided on this form, please update where necessary.

• Emissions Form Note: data reported in the 2009 EIQ is provided on this form, please update where necessary.

• New Emission Sources Form Note: input the requested data to this form only if you are reporting emissions on the

Emissions Form from an emissions source that was not reported in the 2009 EIQ. Otherwise, no input is required.

• Emissions Data Certification Form. Note: verify that the emissions totals indicated on these forms are correct then have it signed by a responsible official (i.e. the owner, or the operat or).

SCHD

- PCS is authorized to collect air emission inventory information in Shelby County, Tennessee pursuant to the following:

1. Sections 110 (a) (2) (F) (ii) and 112 (s) (1) (2) (3) (4) of the Federal Clean Air Act

2. Sections 68

- 201

- 105 and 68

- 201

- 115 of t he Tennessee Code Annotated

3. Section 14.5

- 30 of the Shelby County Code

4. Section 16

- 98 of the City of Memphis Code

5. Similar sections for each of the other incorporated areas in Shelby County, Tennessee

When returned, the 2010 EIQ should include:

1. hardcopy of y our facility’s emissions

2. electronic copy of your facility’s emissions, and

3. a cover letter.

a. a breakdown of each air pollutant in tons per year (TPY).

b. an explanation of significant increases or decreases in emissions

c. information on the addition of new Group s and Process Unit

d. information on Groups/Process Units to be deleted and the reasons for the deletions

If the emissions from your facility have not changed from the 2009 EIQ, simply provide a cover letter to SCHD

- PCS that includes a statement to that effe ct and it will be used for your 2010

emissions. No other information will be needed.

Finally, notice that the 2010 EIQ Packet has a .piz file extension. Save this file to your hard drive and rename .piz to .zip. Be sure to keep copies of all forms, calcul ations, and information used to determine the emissions stated in your facility’s EIQ. For additional assistance, please contact the Emission Inventory Staff at (901) 222

- 9571.

### 26 APPENDIX E 5 : EMISSION INVENTORY QUESTIONNAIRE INSTRU CTIONS



# SHELBY COUNTY

HEALTH DEPARTMENT



# INSTRUCTIONS

for reporting the



# 2010

Point Source

Emissions Inventory

Pollution Control Section Robert Rogers, P.E.

Technical Manager

Air Planning Branch

814 JEFFERSON AVENUE, MEMPHIS, TENNESSEE 38105

Phone (901) 544

- 7766 Fax (901) 544

- 7308 Mark H. Luttrell, Jr. Mayor Shelby County Y VONNE S. M ADLOCK H ELEN M ORROW , M.D.

D IRECTOR A CTING H EALTH O F F ICER

### 27 Table Of Contents

Introduction

..................... ........................... ............................................................................ ......... ...... 3

I. Getting Started......

......................................................................................................... ................. 4

1. How to Open the Questionnaire

..................................................................................................... .... 4

2. How to Complete the 2010 Emission Inventory Questionnaire (EIQ)...........................................

................. . 7

A. Step 1...........................................................................................................

................ ..... 7

B. Step 2................................................................................................................

................ 9

C. Step 3...................................................................................................

............ ................. . 9

D. Step 4..............................................................................................................

................. . 9

II. General Instructions

....................................................................................................... .................. . 10

1. General Plant Information Form......................................................................................

.................. . 11

2. Emission Period Form.......................................

........................................................... ................. 15

3. Emission Process Form..................................................................................................

....................... 18

4. Emission Unit Form..................................................................................................

................... . 21

5. Emission Release Point Form........................................................................................

.................. . 23

6. Emission Form.........................................................................................................

.................. 2 6

7. Control Equipment Form.............................................................................................

.................. . 29

8. Emission Data Certification Form...................................................................................

.................. 32

2

### 28 

## Introduction

The Pollution Control Section of the Memphis and Shelby County Health Department (SCHD

- PCS) is required by

federal law to collect detailed information from facilities located in Shelby County, Tennessee that emit

contaminants to the atm osphere on actual annual emissions for calendar year 2010. Each facility receiving this emission inventory package is required to complete and return it by September 19, 2011. When returned, the Emissions Inventory Questionnaire (EIQ) should contain the fo llowing:
 All of the requested data forms and any supporting documentation and calculations
 Examples of calculations used to determine the emissions stated in the Emission Inventory forms
 Actual annual emissions of all pollutants of interest (see topic “Re porting Emissions Estimates”)
 Material throughputs for annual and seasonal rates
 Fuel parameters of heat content, % ash, and % sulfur
 Operating parameters for effective Start and End dates and times
 Emission release point parameters of height, diameter, ex it gas temperature, velocity, and flow rate
 Name and description of pollution control equipment in use
 SIC number(s), NAICS number(s), SCC number(s), and any MACT Codes that apply

The primary objectives of the EIQ are:
 To collect and maintain data in a st andard format
 To ensure the data meets the requirements of the Federal Clean Air Act
 To ensure the use of the most current emissions determination methods

SCHD

- PCS is authorized to collect air emission inventory information in Shelby County, Tennessee p ursuant to the following:

1. Sections 110 (a) (2) (F) (ii) and 112 (s) (1) (2) (3) (4) of the Federal Clean Air Act

2. Sections 68

- 201

- 105 and 68

- 201

- 115 of the Tennessee Code Annotated

3. Section 14.5

- 30 of the Shelby County Code

4. Section 16

- 98 of the City of Memph is Code

5. Similar sections for each of the other incorporated areas in Shelby County, Tennessee

The information provided will be used to assist SCHD

- PCS to track emission trends affecting Shelby County.

Be sure to keep copies of all forms, calculations, a nd information used to determine the emissions stated in your facility’s EIQ. Thank you for your help in this matter. For additional assistance, please contact Christopher Boyd at (901) 222

- 9571.

3

### 29 

## I. Getting Started

1. How to Open the Questionnaire

a. Inst r uctions for Microsoft Office 1997, 2000, and 2003 users

To open the Emission Inventory Questionnaire (EIQ) spreadsheet application, Microsoft Office 1997, 2000, and 2003

users must ensure that the Microsoft Excel security setti ng allows macros to be enabled. To adjust the security settings you must open the Security dialog box. This is done following these 3 steps:

1. Select Tools from the toolbar

2. Select Macro from the dropdown menu

3. Select Security from the dropdown menu

Figure 2a i llustrates how to select the Security Panel from the list of options on the MS Excel menu bar.

Figure 2a: Select Tools > Macro > Security

Figure 2b displays the Security Level dialog form with the (3) security settings for macros. This spreadsheet

a pplication will not operate if the Security Level is set on “High” . The only choices that will allow the spreadsheet application to function are either “Medium” or “Low” (be sure to select “OK” otherwise this modification will not take effect).

Figure 2 b: The MS Excel Security Panel

Remember, only two of the security settings, either low or medium, will permit the EIQ spreadsheet application to
operate.

The following three bullets describe how each setting affects the behavior of macros.
 "High" is the highest level of security. It automatically disables all unsigned macros. This setting will not allow

the EIQ spreadsheet application to function properly . It will prevent the EIQ spreadsheet application from opening. I f your Microsoft Excel security sett ing is set to “High” it must be adjusted downward.

4

### 30  "Medium" is the midrange level of security. It displays a warning window stating the dangers of opening documents containing Macros and will allow you to make the decision whether to enable
 or disable the macros. You must choose “enable macros” . Doing so will allow the EIQ spreadsheet application to function properly . WHEN YOU HAVE COMPLETED YOUR EIQ, YOU MUST RESET

YOUR SECURITY SETTINGS TO THEIR PREVIOUS CONDITION AT ONCE IN ORDER TO PROTECT

YOUR COM PUTER OR SYSTEM FROM MACROS THAT MAY HAVE VIRUSES.
 "Low" is the lowest level of security. It allows all macros to run. This setting will allow the EIQ spreadsheet application to function properly . WHEN YOU HAVE COMPLETED YOUR EIQ, YOU MUST RESET

YOUR SECUR ITY SETTINGS TO THEIR PREVIOUS CONDITION AT ONCE IN ORDER TO PROTECT

YOUR COMPUTER OR SYSTEM FROM MACROS THAT MAY HAVE VIRUSES.

b. Inst r uctions for Microsoft Office 2007 users

To open the Emission Inventory Questionnaire (EIQ) spreadsheet application, Mi crosoft Office 2007 users must ensure

that the Microsoft Excel security settings allow macros to be enabled. To adjust the security settings, locate the

“ Security Warning ” message bar and left

- click on the button labeled “Options” (see Figure 3a). This wil l display the “Microsoft Office Security Options” userform. Proper operation of this

Figure 3a: the “ Security Warning ” message bar

spreadsheet application requires the activation of “Macros and ActiveX” content. To activate this cont ent (see Figure 3b) you must :

1. select “Enable this content”

2. left

- click the button labeled “OK”

Note: Microsoft Office 2007 users must performed this operation each time the EIQ is opened.

Figure 3b: The MS Excel Security Panel

5

### 31 • After the security setting has been adjusted to allow the EIQ spreadsheet application to open, place the EIQ CD from the emission inventory packet into the CD drive on your computer and use these steps to open the EIQ spreadsheet application as follows:

1. Open the My Computer icon then locate and open the CD drive labeled “ 2010 EIQ CD”

. 2. When the CD drive windows opens, right

- click and Copy the folder labeled “ The 2010 Emissions Inventory Questionnaire Packet ”

. 3. Paste the “ The 2010 Emissions Inventory Questi onnaire Packet ” folder onto your Desktop.

4. From your Desktop

, right

- click and Open “ The 2010 Emissions Inventory Questionnaire Packet ” folder

. This

folder contains two files: 1.) “Instructions 2010 Emission Inventory Questionnaire”, and 2.) “The 2010 Emissio n Inventory Questionnaire” (use it to report calendar year 2010 air emissions)

5. Left double

- click on the “ The 2010 Emissions Inventory Questionnaire ” icon, this will open the EIQ spreadsheet application and reveal the Menu window, which is displayed in Figu re 4.

Figure 4. The 2010 EIQ spreadsheet application Menu window

The EIQ forms are accessed by left

- clicking the appropriate button name. Also notice, the Due Date, return mailing address, and contact information are prominently displayed. In additio n, under the Useful Website

section are links to AP

- 42, WebFIRE, Tanks, and etc. Make sure your web browser is open before left

clicking on any of these links.

6. Under the heading “2010 EIQ FORM

– Menu”, locate the Select a Form frame. Here you will find a command button for each of the listed forms. To open a form, left

- click the command button. To navigate back to the

Menu either select the Menu button (found on every form) or select the Menu name tab (located at the bottom of the MS Excel Window).

6

### 32 No te: It is be helpful to have a copy of your current permit(s) on hand. From your permit(s), you should be able to determine the operations for which you will need to report emissions and do calculations. Next, you will need to gather production rate inform ation. This might be in the form of the amount of fuel burned, cubic yards of concrete produced, or pounds of solvent used, etc. Remember, only report emissions from equipment operated in 2010.

2. How to Complete the 2010 Emission Inventory Questionnaire (EIQ)

STEP 1 : Table 3 displays a list of the EIQ forms. Included in it are brief remarks for each form. Pay particular attention to these remarks because they indicate the specific form that each source type is responsible for completing. If your

facili ty is a Minor Source you must complete only the “ General Plant Information Form” and the “Emission Data Certification Form” . Otherwise, if your facility is a Major or Synthetic Minor Source you must complete all of the EIQ forms with the exception of the C ontrol Equipment Form, which is required only when there are devices employed

to control air contaminants.

Table 3

- List of 2010 Emissions Inventory Questionnaire Forms

Form

Number A. Form

Name Form Description Remarks

1. General Plant

Information Lists and details general information. Required for all Sources

.

2. Emission Period Lists and details operating schedules. Required for all Major and Synthetic Minor Sources

.

3. Emission Process Lists and details processes. Required for all Major and Synthetic Minor Sources

.

4. Emission Unit Lists and details the emissions units. Required for all Major and Synthetic Minor Sources

.

5. Emission Release

Point Lists and details t he emissions release points to the atmosphere. Required for all Major and Synthetic Minor Sources

.

6. Emission Lists and details all of the air contaminants released to the atmosphere. Required for all Major and Synthetic Minor Sources

.

7. Control Equip ment Lists and details stack information. Required for all Major and Synthetic Minor Sources

with an emission control device(s).

8. Emission Data

Certification Used to certify that the information provided is

accurate and truthful. Required for all Sourc es

.

7

### 33 Order of Completion of the EIQ Forms and Data Flow

The flowcharts below illustrate the order of completion of the EIQ forms and data flow. The number affixed to each flow chart symbol indicates the order of completion. Major and Synthet ic Minor Sources must complete the entire Emissions Inventory Questionnaire (EIQ) by filling

- out each form in numerical sequence, starting with the “ General Plant Information Form” and ending with the “Emission Data Certification Form” as indicated in Figu re 5a. Whereas, Minor Sources must only complete two forms, the “ General Plant Information Form” and the “Emission Data Certification
Form”, as indicated in Figure 5b and no others. DO NOT mistake the data flow lines depicted here with the “order of comple tion”. The data flow lines are provided to illustrate the path and direction that data follows in populating the “Auto

- Filled ” columns from the source to the target.

a.) Order of completion for Major and Synthetic Minor Sources only , complete form number 1 through form number 8 in numerical

sequence. Further, the dash line from 1 to 8 is a bypass not a junction

b.) Order of completion for Minor Sources only , complete only form number 1 and f orm number 8 .

Figure 5: Flowcharts showing the Order of Completion of EIQ Forms

8 1

- General Plant Information Form ( writes selected data fields to the Emission Data Certification Form, as indicated by the data flow line)

3

- Emission

Process

Form 4

- Emission

Unit

Form 5

- Emission

Release

Point

Form 6

- Emission Form
(writes control information to the Control Equipment Form and pollutant amounts to the Emission Data Certification Form, as indicated by the data flow lines)

7

- Control Equipment

Form 8

- Emission

Data

Certification

Form 2

- Emission Period Form
(writes selected d ata fields to the Emission Period, Emission Unit, Emission Release Point, and Emission Forms, as indicated by the data flow lines)

1

- General Plant Information Form ( writes selected data fields to the Emission

Data C ertification Form as indicated by the data flow line) 8

- Emission

Data

Certification

Form

Note: For this spreadsheet applicatio n to work as intended, it is important that all sources complete the forms in the order required as illustrated above in Figure 5. Data Flow Line Data Flow Line

### 34 STEP 2 : When you have completed the 2010 Emissions Inventory Questionnaire, make copies for your records. Moreover, you should also keep records and calculations use d to make emissions estimates.

STEP 3 : Print the General Plant Information Form and the Emission Data Certification Form . Make sure that a responsible company representative signs the Emission Data Certification Form.

STEP 4 : Be sure to include your c ompany name, source number (which is the first five digits of your permit number), and contact information on all correspondence submitted with your report. Return the completed 2010 Emissions Inventory Questionnaire, along with the General Plant Informati on Form and the signed Emission Data Certification Form, by mail, to the SCHD

- PCS address:

Attention: 2010 Emission Inventory Pollution Control Section, 4 th Floor Memphis and Shelby County Health Department

814 Jefferson Avenue Memphis, TN 38105

9

### 35 

## III. General Instructions

The information presented in this guidance document will provide details pertaining to the data elements that appear on each form. Use this as a guide. When returned, the annual Emissions Invent ory Questionnaire (EIQ) for 2010 should contain the following:

 All the completed data forms and any supporting documentation and calculations
 Examples of calculations used to determine emissions stated in the Emission Inventory forms
 Actual annual emissio ns of all pollutants of interest (see page 5, “Reporting Emissions Estimates”)
 Material throughputs for annual and seasonal rates
 Fuel parameters of heat content, % ash, and % sulfur
 Operation parameters for effective Start and End dates and times and annu al operating schedule
 Emission release point parameters of height, diameter, exit gas temperature, velocity, flow rate
 Name and description of pollution control equipment in use
 SIC number(s), NAICS number(s), SCC number(s), and any MACT Codes that apply

Note: If any item on this EMISSION INVENTORY QUESTIONNAIRE is not applicable to your facility, the item must be

filled in with "NOT APPLICABLE" OR "N/A".

10

### 36 1. General Plant Information Form Instructions

Sample Gener al Plant Information Form

Use the instructions below to complete the General Plant Information Form.

Step 1:

Select the appropriate Permit Type button on the form depending upon your classification as a Major or Synthetic

Minor Source or as a Minor Source

.


### Please note the following helps

Command Buttons:

MENU



### - Select to open the Menu which will show links to other forms, websites and a variety of information needed to submit the emission inventory.

NEXT

- This selection will open the Emission Period Form for a Major or Synthetic Minor Source that has checked the appropriate Permit Type button on the form. Otherwise, if you are a Minor Source and have selected the corresponding Permit Type button, this selection will open the Emission Data

Certification Form.

HELP

- Select to open Online Help for instructions in the completion of the emission inventory forms



### .

11

### 37 Step Two:

Complete the following data fields in the numerical order that they appear as, at times, data may be lost if the order

is not followed:



### I. Plant Information Section

Item 1

- Source Number: Left double

- click and enter the 5

- digit source number assigned to identify a facility by

SCHD

- PCS

Item 2

– Parent Company/Owner’s Name: Left double

- click and enter the facilit y owner’s name.

Item 3

– Company/ Facility Name: Left double

- click and enter the business name of the facility.

Item 4

- Facility Address: Left double

- click and enter the physical address of the facility.

Item 5

– City: Left double

- click and enter th e name of the city where the correspondence should be sent.

Item 6

– State: Left double

- click and enter the name of the state where the correspondence should be sent.

Item 7

– Zip Code: Left double

- click and enter the zip code where the correspondence should be sent.

Item 8

– Plant Latitude (decimal degrees): Left double

- click and enter the latitude coordinate in decimal degrees. This is a positive data point for N. America. Include (+) sign, Example: The latitude for the MSCHD is +35.14354.

Item 9

– Plant Longitude (decimal degrees): Left double

- click and enter the longitude coordinate in decimal degrees. This is a negative data point for N. America. Include (

- ) sign, Example: The longitude for the MSCHD is

- 90.03315.

Item 10

– Mailing Address: Left double

- click and enter the mailing address where correspondence should be sent.

Item 11

– Mailing City: Left double

- click and enter the name of the city where the correspondence should be sent.

Item 12

– Mailing State: Left double

- click and enter the name of the state where the correspondence should be sent.

Item 13

– Mailing Zip code: Left double

- click and enter the zip code where the correspondence should be sent.

Item 14

– Plant Description: Left double

- click and enter the physical descript ion of your facility.

Item 15

– Principal Product: Left double

- click and enter the major activity or principal product at your facility, e.g., “manufacturing and painting of metal office furniture”, or the nature of the business, such as, “cotton seed oi l refinery plant”, “hot asphalt plant”, “chemical manufacturing” and etc.

Item 16

– Number of Employees: Left double

- click and enter the total number of full

- time and the equivalent number of part

- time employees at your facility. For example; two part

- ti me workers each employed 20 hours per week are
equivalent to one full

- time worker



### .

Item 17

– Property Size (acres): Left double

- click and enter the amount of acreage occupied by the site upon which the facility is located. his should include contiguous o r adjacent sites owned or operated by the same company.

Item 18

– Federal Facility ID: Left double

- click and enter the unique 12

- digit Federal ID number assigned to the Facility.

Item 19

- Facility Category: Left double

- click and select the code that ap plies to your facility. The response options are 01 (MAJOR HAP Emitting Facility), 02 (AREA HAP Emitting Facility), or 03 (Non

- HAP Emitting Facility). This field indicates whether the facility is classified as a major source or an area source by the follow ing Clean Air Act definitions: MAJOR Sources are large stationary sources that have the potential to emit more than 10 tons per year of any listed HAP or 25 tons per year or more per year of a combination of listed HAPs; AREA Sources are smaller

stationar y sources that have the potential to emit less than 10 tons per year of a single HAP or less than 25 tons per year

of a combination of listed HAPs.

12

### 38 Item 20

– ORIS Facility Code: Left double

- click and enter the “ORIS Facility Code” number assigned to yo ur facility. This is a Department of Energy (DOE) code exclusive to electrical power production facilities (primarily SIC = 4911). See www.eia.doe.gov

Item 21

– Primary SIC Code: Left double

- click in the cell to init iate a code search then follow the instructions provided by the onscreen dialog boxes. Select the 4

- digit Standard Industrial Classification code that best applies to your facility from the codes retrieved by the code search. Should you need assistance cal l (901) 222

- 9571.

Item 22

– Secondary SIC Code: Left double

- click in the cell to initiate a code search then follow the instructions provided by the onscreen dialog boxes. Select the 4

- digit Standard Industrial Classification code that best applies to yo ur facility from the codes retrieved by the code search. Should you need assistance call (901) 222

- 9571.

Item 23

– Primary NAICS Code: The North American Industrial Classification System (NAICS) code directly corresponds to the Standard Industrial Classi fication code. The computerized version of this questionnaire is equipped so that the Primary NAICS is automatically selected when the Primary SIC is determined. Otherwise enter the NAICS Code here (see www.census.gov/epcd/www/naics.html for valid codes). Should you need assistance call (901) 222

- 9571.

Item 24

– Secondary NAICS Code: The North American Industrial Classification System (NAICS) code directly corresponds to the Standard Industrial Class ification code. The computerized version of this questionnaire is equipped so that the Secondary NAICS is automatically selected when the Secondary SIC is determined. Otherwise enter the NAICS Code here (see www.census.gov/epcd/www/naics.html for valid codes). Should you need assistance call (901) 222

- 9571.

Item 25

– National Toxic Inventory (NTI) Site ID: Left double

- click and enter the “National Toxic Inventory Site ID” number assigned to your faci lity. For HAP reporting only. If this is not available then enter N/A.

THE FOLLOWING INFORMATION IS PROVIDED RELATIVE TO ITEMS 26 AND 27: Maximum Achievable Control Technology (MACT) Standards are technology

- based air emission standards established under Title III of the 1990 Clean Air Act Amendments. The CAAA initially identified 189 (now 188) hazardous air pollutants (HAPs) to be regulated. These substances are carcinogens, mutagens, or reproductive toxins, and they are produced by certain "source

speci fic" industries. "Major" sources of HAPs are defined as sources that emit 10 tons or more per year of any single
HAP or 25 tons or more per year of a mixture of HAPs. 

### " Area" sources are smaller facilities that release lesser quantities of toxic pollutants into the air. Area sources are defined as sources that emit less than 10 tons per year of a single air toxic, or less than 25 tons per year of a combination of air toxics. Each MACT standard establishes its own compliance date. The MACT compliance date is usually but not always three years after the promulgation of the MACT standard. In addition, the standards typically include record keeping and reporting provisions. MACT standards are codified in 40

CFR Part 63.

Item 26

– MACT Compliance Status Code: Le ft double

- click in the cell to initiate a code search then follow the instructions provided by the onscreen dialog boxes. Select the 1

- digit MACT Compliance Status code that best applies to your facility from the codes retrieved by the code search. If this is not available then select or enter N/A. Should you need assistance call (901) 222

- 9571.

Item 27

– Site MACT Code: Left double

- click in the cell to initiate a code search. Then follow the instructions provided by the onscreen dialog boxes. Select the 3

- digit Maximum Achievable Control Technology (MACT) code that best applies to your facility from the codes retrieved by the code search. If this is not available then enter N/A. Should you need assistance call (901) 222

- 9571.

Item 28

– Dun and Bradstree t Number: Left double

- click and enter the “Dun and Bradstreet” number assigned to your facility. If this is not available then enter N/A.

Item 29

– Toxic Release Inventory (TRI) ID: Left double

- click and enter the “Toxic Release Inventory ID” number

ass igned to your facility. If this is not available then enter N/A



### II. Primary Contact Information Section

Item 30

– Name of the Primary Contact: Left double

- click and enter the name of the person to contact concerning data in this emission inventory repo rt.
13

### 39 Item 31

– Title: Left double

- click and enter the title of the person to contact concerning data in this emission inventory

report.

Item 32

– Telephone (with area code): Left double

- click and enter the telephone number of the person to contact

con cerning data in this emission inventory report.

Item 33

– Fax (with area code): Left double

- click and enter the fax number of the person to contact concerning data in this emission inventory report.

Item 34

– Email: Left double

- click and enter the emai l address of the person to contact concerning data in this emission inventory report.



### III. Emission Inventory Preparer Information Section

Item 35

– Name of Preparer: Left double

- click and enter the name of the person who completed the EIQ forms.

Item 36

– Title: Left double

- click and enter the title of the person who completed the EIQ forms.

Item 37

– Company Name: Left double

- click and enter the name of the company that employs the person who completed the EIQ forms.

Item 38

– Mailing Address: L eft double

- click and enter the mailing address where correspondence should be sent if

other than Item 10.

Item 39

– City: Left double

- click and enter the name of the city where the correspondence should be sent if other than

Item 11.

Item 40

– State: L eft double

- click and enter the name of the state where the correspondence should be sent if other

than Item 12.

Item 41

– Zip code: Left double

- click and enter the zip code where the correspondence should be sent if other than

Item 13.

Item 42

– Telepho ne (with area code): Left double

- click and enter the telephone number of the person to contact if

other than Item 32.

Item 43

– Fax (with area code): Left double

- click and enter the fax number of the person to contact if other than Item

33.

Item 44

– E mail: Left double

- click and enter the email address of the person to contact if other than Item 34.

14

### 40 2. Emission Period Form Instructions

Sample Emission Period Form

The Emission Period Form is used to designate th e time period during which the reported emissions occur. Use the instructions below to complete the Emission Period Form.

Complete the following data fields in the numerical order that they appear as, at times, data may be lost if the order is not

followe d.



### Please note the following helps

Command Buttons:

MENU

- Select to open the Menu which will show links to other forms, websites and a variety of information needed to submit the emission inventory.

PREVIOUS

- Select to open the General Plant Informatio n Form.

NEXT

- This selection will open the Emission Process Form for a Major or Synthetic Minor Source

. HELP

- Select to open Online Help for instructions in the completion of the emission inventory forms.

Item 1

- Emissions Unit ID: Left double

- click a nd enter the ID number (up to 6 digits) assigned to the Emissions Unit (See "Identification Numbers" on page 6). The information entered here will automatically be entered on all the other forms where it is required.

Item 2

– Emission Release Point ID: L eft double

- click and enter the number ID number for point/ location where

emissions are released to ambient air (See "Identification Numbers" on page 6). The information entered here will automatically be entered on all the other forms where it is required

.

Item 3

– Process ID: Left double

- click and enter the ID number (up to 6 digits) that is assigned to the Process (See "Identification Numbers" on page 6). The information entered here will automatically be entered on all the other forms where it is requ ired.

Items 4 and 5

– Annual Operation Dates

Start Date: Left double

- click and enter the start date of the period expressed in units of yyyymmdd. For example, a start date of January 1, 2010 is expressed as 20100101.

End Date: Left double

- click and ente r the end date of the period expressed in units of yyyymmdd. For example, an end date of December 31, 2010 is expressed as 20101231.

Item 6

– Annual Operation Times

Start Time: Left double

- click and enter the start time of the period expressed with milit ary time in units of hhmm. For example, a start time of 8:00 a.m. is expressed as 0800.

End Time: Left double

- click and enter the end time of the period expressed with military time in units of hhmm. For example, an end time of 12:00 a.m. or midnight is e xpressed as 2400.

Item 7

– Actual Thru

- put: Left double

- click and enter the actual throughput of the activity, operation, or process you are reporting.

Actual Thru

- put Units of Measure: Left double

- click and enter the units of measure.

15

### 41 Item 8

– SCC Code: Left double

- click in the cell to initiate a code search. Then follow the instructions provided by the onscreen dialog boxes. Select the EPA Source Category Code that best applies to your facility from the codes retrieved by the code search. If this is not available then enter N/A.

Item 9

– Material Code: THIS COLUMN IS AUTO

- FILLED WITH A DEFAULT VALUE A default value has been selected based upon the SCC Code Selection. If this value is inappropriate left double

- click in the cell then follow the

in structions provided by the onscreen dialog boxes. Select the Material Code that best applies from the codes that are displayed

Item 10

– Material I/O Code: The Material I/O is a designation that indicates whether a material is input, output, or existing. THIS COLUMN IS AUTO

- FILLED WITH A DEFAULT VALUE A default value has been selected based upon the SCC Code Selection. If this value is inappropriate left double

- click in the cell then follow the instructions provided by the onscreen dialog boxes. Enter the Material I/O Code that best applies from the codes displayed.

Item 11

– Material Description: THIS COLUMN IS AUTO

- FILLED WITH A DEFAULT VALUE A default code has been selected based upon the SCC Code Selection. If this value is inappropriate follow the i nstructions outlined in item 10 above and this value will be replaced with one that is more suitable.

Item 12

– Operation Period (wks/wk): Enter the number of days per week the process is active. (wks/yr): Enter the number of weeks per year the process is active. (hrs/da): Enter the number of hours per day the process is active. (hrs/yr) : Enter the number of hours per year the process is active.

Item 13

– Confidential Request: Is this information confidential? ( Yes/No )



### Supplemental Information for the Emission Period Form
The following information is for specific data elements in the Emission Period Form and is provided in addition to the Emission Period Form data dictionary. This information will assist you in correctly implementing the noted field s.



### Time

- Using a 24

- hour clock ( i.e., military time), provide the normal time when the Group activities begin for the normal workday over the reporting year. For continuous operations enter a start time of 0000 (12:00 AM) and an end

time of 2400 (to the next midnight) . Use Table 4 to convert Regular Time to Military Time.

Table 4

Regular Time Military

Time Regular Time Military

Time Midnight or

12:00 a.m. 2400 Noon or 12:00

p.m. 1200

1:00 a.m. 0100 1:00 p.m. 1300

2:00 a.m. 0200 2:00 p.m. 1400

3:00 a.m. 0300 3:00 p.m. 1500

4:00 a.m. 0400 4:00 p.m. 1600

5:00 a.m. 0500 5:00 p.m. 1700

6:00 a.m. 0600 6:00 p.m. 1800

7:00 a.m. 0700 7:00 p.m. 1900

8:00 a.m. 0800 8:00 p.m. 2000

9:00 a.m. 0900 9:00 p.m. 2100

10:00 a.m. 1000 10:00 p.m. 2200

11:00 a.m. 1100 11:00 p.m. 2300

ACTUAL THROUGHPUT N UMERIC V ALUE

- As the START DATE and END DATE of the Emission Period Form designates the emissions time period, the ACTUAL THROUGH PUT N UMERIC V ALUE field on the Emission Period Form should be reported as the activity value for the same time period delineated by the Start and End Dates. The

ACTUAL THROUGHPUT N UMERIC V ALUE data reported here should be the annual total for the year taki ng into account the various reporting periods as discussed in I. 9. Identification Numbers (IDs), Their Use and Retirement on pages 6 and 7. When reporting ACTUAL THROUGHPUT N UMERIC V ALUE , the following unit codes must also be reported: UNIT of MEASURE, M ATERIAL, and MATERIAL I/O.

16

### 42 The values reported for the three throughput unit fields should match the values reported for the associated unit fields for

Emission Factor Numeric Value on the Emissions Form.

For example, if the ACTUAL THROUGHPUT unit fi elds reported on the Emission Period Form are as follows:

UNITS of MEASURE = TON; MATERIAL = Coal;

MATERIAL I/O = I

Then the EMISSION FACTOR unit fields reported on the Emission Form should be as follows:

EMISSION FACTOR NUMERIC VALUE = numeric value

E MISSION FACTOR UNIT NUMERATOR = LB; EMISSION FACTOR UNIT DENOMINATOR = TON; MATERIAL = Coal; and MATERIAL I/O = I (for Input)

And the unit code values reported for the EMISSION FACTOR on the Emission Form should be as follows:

FACTOR UNIT NUMERATOR = LB;

FACTOR UNIT DENOMINATOR = EACH

- YR; MATERIAL = Employee (or Person); and MATERIAL I/O = E (existing).

Operating Schedule Parameters may be reported for a facility that differ from the annual average operating schedule

parameters reported for the facility on the Emission Process (EP) record . For example, a facility normally operates 7 days per week and 24 hours per day, but during the summer months (e.g., June through August) only operates 5 days per week and 16 hours per day. The value of 7 days per week and 24 hours per day should be reported in Annual Average Days per Week and Annual Average Hours per Day fields on the Emission Process Form . The seasonal operating schedule of 5 days per week and 16 hours per day should be reported in the Period Days per Week and Period Hours per Day fields on the PE Record , and should also designate the Start Date and End Date for the seasonal period.

How to Enter Seasonal Throughput for Total Annual Emissions Providing the seasonal throughput percentages with process sc hedule data and the total annual emissions is a good way to provide air quality modelers with information needed to determine average day emissions for a specific season of interest. Thus, the Preferred Reporting Method is as follows:

Form Data Element En try Value

Emission Period START DATE YYYY0101 (YYYY = calendar year, i.e. 2010)

END DATE YYYY1231

ACTUAL THROUGHPUT Specify the total activity for the year

Material is the material used that created the pollutants at each process. Depending on the type of source category, material may refer to the type of fuel combusted, raw material processed, product manufactured, or material handled or processed.

Material I/O

- Indicate whether the material above was consumed or used (I), produced (O), or existed (E )

.

17

### 43 3. Emission Process Form Instructions

Sample Emission Process Form

The Emission Process Form is used to record data for emissions

- producing processes. Use the instructions below to complete the Emission Process Form

.



### Please note the following helps

Command Buttons:

MENU

- Select to open the Menu which will show links to other forms, websites and a variety of information needed to submit the emission inventory.

PREVIOUS

- Select to open the Emission Period Form.

NEXT

- This selection will open the Emission Unit Form for a Major or Synthetic Minor Source

. HELP

- Select to open Online Help for instructions in the completion of the emission inventory forms.



### Data Fields

Item 1

- Emissions Unit ID: All the cells in this c olumn are automatically filled based on entries made on the

Emission Period Form.

Item 2

– Emission Release Point ID: All the cells in this column are automatically filled based on entries made on

the Emission Period Form.

Item 3

– Process ID: All the c ells in this column are automatically filled based on entries made on the Emission

Period Form.

Item 4

– SCC Code: All the cells in this column are automatically filled based on entries made on the Emission

Period Form.

Item 5

– Process MACT: Left d oub le

- click in the cell to initiate a code search. Then follow the instructions provided by the onscreen dialog boxes. Select the Maximum Achievable Control Technology (MACT) Code that best applies to your facility from the codes retrieved by the code search. If your facility is not subject to MACT then enter N/A. For

more information see the topic below entitled, “Process MACT Code”.

Item 6

– Emission Process Description: Left double

- click and enter a description of the emission process.

Item 7

– Seasonal Throughput Percentage (S ee the topic below entitled, “How to Enter Seasonal Throughput for Total Annual Emissions”)

Winter : Left double

- click and enter the percentage of the throughput that is processed in Winter. Spring : Left double

- click and enter the percentage of the throughput that is processed in Spring.

Summer : Left double

- click and enter the percentage of the throughput that is processed in Summer.

Fall : Left double

- click and enter the percentage of the throughput that is processed in Fall.

Item 8

– Annual Operation Schedule (da/wk): COLUMN IS AUTO

- FILLED The Annual Operation Periods value that was input for da/wk on the

Emission Period Form has been used here as a default value. If this value is inappropriate then left

- double

- click

and enter t he number of days per week the process is active.

18

### 44 (wks/yr): COLUMN IS AUTO

- FILLED The Annual Operation Periods value that was input for wks/yr on the

Emission Period Form has been used here as a default value. If this value is inappropriate then left

- d ouble

- click

and enter the number of weeks per year the process is active. (hrs/da): COLUMN IS AUTO

- FILLED The Annual Operation Periods value that was input for hrs/da on the

Emission Period Form has been used here as a default value. If this value is ina ppropriate then left

- double

- click

and enter the number of hours per day the process is active. (hrs/yr): COLUMN IS AUTO

- FILLED The Annual Operation Periods value that was input for hrs/yr on the

Emission Period Form has been used here as a default value. If this value is inappropriate then left

- double

- click

and enter the number of hours per year the process is active.

Item 9

– Fuel Data

Heat Content: Left double

- click and enter the number of hours per day the process is active.

Heat Content Units: Left double

- click and enter the heat content of a fuel in million’s of BTU’s per Ton of coal, 1000 Gallons of oil, million SCF of gas and etc.

Ash Content %: Left double

- click and enter the ash content of the burned fuel, expressed as a percentage.

Sulfur Con tent %: Left double

- click and enter the sulfur content of the fuel, expressed as a percentage. Note: The sulfur content for wood and natural gas will normally be negligible.

Item 10

– Process MACT Compliance Status Code: Left double

- click in the cell to initiate a code search. Then follow the instructions provided by the onscreen dialog boxes. Select the MACT Compliance Status Code that best applies to your facility from the codes retrieved by the code search. If your facility is not subject to MACT, ent er N/A. (See the topic below entitled, “Process MACT Compliance Status Code”)

Item 11

– Confidential Request: Is this information confidential?



### Supplemental Information for the Emission Process Form The following information is for specific data element s in the Emission Process Form and is provided in addition to the Emission Process Form data dictionary. This information will assist you in correctly implementing the noted fields.

PROCESS MACT CODE

- M ajor/Area source classification under the CAAA Secti ons 112 & 129. A Maximum Achievable Control Technology (MACT) Code is a 4

- digit code assigned to all MACT categories and

sub

- categories. The MACT code should be reported for all relevant facilities at the process (SCC) level within a MACT category. If MACT codes are not reported, SCHD

- PCS will make default assignments. More information on the MACT source categories and the MACT program is located at www.epa.gov/ttn/uatw/eparules.html

. Should you need assistance call (901) 544

- Select to open the Menu which will show links to other forms, websites and a variety of information needed to submit the emission inventory.

PROCESS MACT COMPLIANCE STATUS provides information on the controls that are in place due to Sections

112 & 129 of the Clean Air Act Amendments (CAAA). Codes are provided for the following:

• Major Sources that are listed under Sections 112 & 129 for which:

 the compliance date has not yet occurred; source is assumed major (>10/25 tons per year) and will be subject to standards under Sections 112 & 1 29, Code value = 01;

 Compliance date has occurred; source is classified major because emission levels are >10/25 tons per year as of initial compliance date, even if emission levels are <10/25 tpy at a later date, Code value = 02.

• Area Sources (<10/25 tpy) that are listed under Sections 112 & 129, and:

 Are subject to Section 112 or 129 standards as regulated area source category, Code value = 03;

 Are not subject to Section 112 or 129 standards as a synthetic minor source (regulated major source category and the source has reduced emissions below major source status before initial compliance date), Code value = 04;

 Are not subject to Section 112 or 129 standards as a true area or natural minor source, Code value =

05.

As annual throughput is reported on the Emission Period Form, the seasonal activity percentages and average annual operating data must be reported on the Emission Process Form in order to enable SCHD

- PCS, EPA, or other NEI users, to disaggregate the reported annual activity and emissions to seas onal activity and emissions and compute emissions for an average season day.

19

### 45 How to Enter Seasonal Throughput for Total Annual Emissions Providing the seasonal throughput percentages with process schedule data and the total annual emissions is a good way to provide air quality modelers with information needed to determine average day emissions for a specific season of interest. Thus, the preferred reporting method is as follows:

Form Data Element Entry Value

Emission Process WINTER THROUGHPUT PCT Whol e number between 0 and 100

SPRING THROUGHPUT PCT Whole number between 0 and 100

SUMMER THROUGHPUT PCT Whole number between 0 and 100

FALL THROUGHPUT PCT Whole number between 0 and 100

ANNUAL AVG DAYS PER WEEK Whole number between 1 and 7

WEEKS PER YEA R Whole number between 1 and 52

20

### 46 4. Emission Unit Form Instructions

Sample Emission Unit Form

The Emission Unit Form reports all the emission units from your facility. Use the instructio ns below to complete the

Emission Unit Form.



### Please note the following helps

Command Buttons:

MENU

- Select to open the Menu which will show links to other forms, websites and a variety of information needed to submit the emission inventory.

PREVIOUS

- S elect to open the Emission Process Form.

NEXT

- This selection will open the Emission Release Point Form for a Major or Synthetic Minor Source

. HELP

- Select to open Online Help for instructions in the completion of the emission inventory forms.



### Data Fiel ds

Item 1

- Emission Unit ID: All the cells in this column are automatically filled based on entries made on the Emission

Period Form.

Item 2

- Process ID: All the cells in this column are automatically filled based on entries made on the Emission Per iod

Form.

Item 3

- ORIS Boiler ID: Left double

- click and enter the “ORIS Boiler ID” number assigned to your facility. This is a Department of Energy (DOE) code exclusive to electrical power production facilities . If this is not available then enter

N/A. For more information see the topic below entitled, “ORIS Boiler ID”. See www.eia.doe.gov EPA assigns/includes

ORIS BOILER ID for EGUs in the NEI.

Item 4

- SIC Code: Left double

- click in the cell to initiate a code search. Then follow the instructions pro vided by the onscreen dialog boxes. Select the 4

- digit Standard Industrial Classification code that best applies to your facility from the codes retrieved by the code search. For more information see the topic below entitled, “SIC Code”.

Item 5

- NAICS Co de: No input is required here . The North American Industrial Classification System (NAICS) code directly corresponds to the Primary SIC. Thus, the NAICS is automatically selected when the Primary SIC is determined. For more information see the topic below entitled, “NAICS Code”.

Item 6

- Design Capacity: Left double

- click and enter the numeric value of the average operational capacity for an

emission unit that is a boiler or turbine. For more information see the topic below entitled, “Design Capacity”. D esign Capacity is the numeric value of average operational capacity for an Emission Unit. Report the value for the design capacity as MMBTUs (Million British Thermal Units).

Item 7

- Design Capacity Numerator Units of Measure: Left double

- click and enter the units in the n umerator of the design capacity

.

21

### 47 Item 8

- Design Capacity Denominator Units of Measure: Left double

- click and enter the units in the denominator of the design capacity.

Item 9

- Max Nameplate Capacity: Left double

- click and enter the rated design capacity at 100% (maximum) operation level. Note, this data field is f or electric generating unit’s (EGU) only. For more information see the topic below entitled, “Max Nameplate Capacity”. Report the value for maximum nameplate capacity in Megawatts (MW).

Item 10

- Max Nameplate Capacity Units of Measure: Left double

- click and enter units of measure for the maximum nameplate capacity in MW.

Item 11

- Emission Unit Description : Left double

- click and enter a description of the emissions u nit.

22

### 48 5. Emission Release Point Form Instructions

Sample Emission Release Point Form

The Emission Release Point Form reports emission point information for your facility. An “emission r elease point” is defined as a stack, pipe, vent, or opening through which a significant percentage of emissions (from one or more processes) are released into the atmosphere (with or without a control device). The physical attributes and the location

coord inates of the emission release point must be reported to identify where emissions are released to the ambient air whether by a stack or non

- stack (e.g., fugitive release). If a non

- stack release, coordinates may be reported for the general location of the emission release point. The height, diameter, longitude and latitude, exit temperature, exit velocity, and gas flow rate must be provided when completing this form. Use the instructions below to complete the

Emission Release Point Form.



### Please note the fo llowing helps

Command Buttons:

MENU

- Select to open the Menu which will show links to other forms, websites and a variety of information needed to submit the emission inventory.

PREVIOUS

- Select to open the Emission Unit Form.

NEXT

- This selection will open the Emission Form for a Major or Synthetic Minor Source

. HELP

- Select to open Online Help for instructions in the completion of the emission inventory forms.



### Data Fields

Item 1

- Emission Release Point ID: All the cells in this column are automat ically filled based on entries made on

the Emission Period Form.

Item 2

- Emission Release Point Type Code: Left double

- click in the cell to initiate a code search. Then follow the instructions provided by the onscreen dialog boxes. Select the Emission R elease Point Type code that best applies to your facility from the codes retrieved by the code search. For more information see the topic below entitled, “Emission Release Point Type”.

Item 3

- Emission Release Point Height: Left double

- click and enter t he Emission Release Point height (in units of feet). Note that the Emission Release Point height is the distance above ground to the discharge point. Thus, for an emission release point located on the roof of a building, the height equals the sum of the he ight of the building plus the length of the Emission Release Point . For example, the Emission Release Point height of a 10

- foot Emission Release

Point atop of a 30

- foot building is 40 feet.

Item 4

- Emission Release Point Diameter : Left double

- click and enter the Emission Release Point Diameter (in feet).

The Emission Release Point Diameter is the inside measurement of the stack at the discharge point. If the Emission Release Point Diameter is not circular, calculate the equivalent diameter (De) using, D e = 2(H * W)/(H + W). Where H is the height and W is the width of the cross sectional area of the flow. Note: This field is equipped with an Equivalent Diameter Calculator. To access it:

• right

- click Emission Release Point Diameter data field

• enter the heig ht (H) and the width (W) into the appropriate input box

23

### 49 • select “Calculate Equivalent Diameter” to calculate the equivalent diameter using the equation given above

• select “Enter Value”

Item 5

- Emission Release Point Fenceline Distance: Left double

- cli ck and enter the distance from fenceline to the facility in feet (ft)

.

Item 6

- Exit Gas Temperature: Left double

- click and enter the temperature of the exit gas (in degrees Fahrenheit

--

° F). Note, quantify the amount, DO NOT enter “Ambient” in this fie ld.

Item 7

- Exit Gas Velocity: Left double

- click and enter the velocity of the exit gas (in feet per second

-- ft/s).

Item 8

- Exit Gas Flow Rate (a calculated field): the flow rate of the exit gas stream is automatically calculated. However, this cal culation is only performed when data has been input to the Stack Diameter field and then the Exit Gas Velocity field. The flow rate at actual exhaust gas temperature and normal atmospheric pressure is determined and the value is expressed in units of actua l cubic feet per second (ACFS). The following equation is used,

ACFS = SCFS x (Ta + 460)/(Ts + 460) Where; Ta = actual exhaust gas temperature (degrees F) Ts = temperature at standard conditions (normally 70 degrees F)

Should you need assistance call ( 901) 222

- 9571.

Item 9

- X Coordinate (Longitude): Left double

- click and enter the longitude coordinate in decimal degrees . This is a negative data point for N. America. Include (

- ) sign. Example: the longitude for the Memphis and Shelby County

Health De partment is

- 90.03315 degrees. For more information see the topic below entitled, “X and Y Coordinates”.

Item 10

- Y Coordinate (Latitude): Left double

- click and enter the latitude coordinate in decimal degrees. This is a positive data point for N. Ameri ca. Include (+) sign. Example: the latitude for the Memphis and Shelby County Health Department is +35.14354. For more information see the topic below entitled, “X and Y Coordinates”.

Item 11

- Horizontal Fugitive Emissions Area: Left double

- click and e nter the horizontal area of the fugitive

emissions in square feet (ft 2 ). For more information see the topic below entitled, “Emission Release Point Type”.

Item 12

- Fugitive Emissions Height: Left double

- click and enter the release height above the terra in of the fugitive

emissions in feet (ft ). For more information see the topic below entitled, “Emission Release Point Type”.

Item 13

- Emission Release Point /Name Description: Left double

- click and enter a description for the equipment or process served by the Emission Release Point(s).



### Supplemental Information for the Emission Release Point Form The following information is for specific data elements in the Emission Release Point Form and is provided in

addition to the Emission Release Point Form data dictionary. This information will assist you in correctly implementing the noted fields.

Special Command Button: The Equivalent Diameter Information command button is located on the Emission Inventory Toolbar. When selected this button will provide a bri ef overview on how to calculate the equivalent diameter

of a non

- circular area. In addition, it provides instructions on how to start the Equivalent Diameter Calculator, which is launched by right

- clicking in the “Diameter” data field. From that point, the equivalent diameter can be calculated by supplying the height and width of the cross sectional area of the flow.

Reporting a Single Process that Goes to Multiple Stacks A very typical scenario is that one emission process vents to one emission release po int. In some instances however, one emission process may vent to several emission release points. In that case, create and report a ‘dummy’ PROCESS ID for each additional EMISSION RELEASE POINT ID. Split the PROCESS ID (and therefore emissions) and create the necessary number of (unique) PROCESS IDs to match the respective number of emission release points.

24

### 50 Example (Record ID)

SITE EMISSION UNIT EMISSION PROCESS EMISSION RELEASE POINT (SITE ID) (EU ID) (PROCESS ID) (ERP ID)

01 B 1 1

01 C 1A 1

01 C 1B 2

01 C 2 2

01 C 3 2

Note: Emission Unit ‘C’ has a process segment 1 that emits through stacks 1 and 2. In this case, Process 1 is divided into PROCESS 1A and PROCESS 1B, creating two unique processes, one for each stack.

X and Y Coordina tes reported as Latitude and Longitude must be reported in decimal degrees . If you need assistance obtaining the latitude and longitude of your facility, please refer to “ 18. How to Find the Latitude and Longitude Coordinates for your facility on the Inter net ”(located on page 9). If you need to convert latitude and longitude coordinates in degrees, minutes, and seconds to decimal degrees, a conversion tool can be accessed at http://www.fcc .gov/mb/audio/bickel/DDDMMSS

- decimal.html

.

Emission Release Point Type When reporting Emission Release Point Type Code = 02, 03, 04, or 05 (all are stack descriptions), physical stack parameters apply and should be reported. Those data elements are: STAC K HEIGHT, STACK DIAMETER, STACK (base/centerline) to FENCELINE DISTANCE, EXIT GAS VELOCITY, EXIT GAS TEMPERATURE, and EXIT GAS

FLOW RATE.

When reporting Emission Release Point Type Code = 01 (fugitive) or 06 (downward

- facing vent), then the stack

paramete rs (listed above) do not apply. However, HORIZONTAL AREA FUGITIVE, RELEASE HEIGHT FUGITIVE, and FUGITIVE DIMENSIONS UNIT must be reported. These dimensional data are used in emission estimation models to predict ambient concentrations of fugitive emissions

.

Equivalent Diameter for Non

- circular Emission Release Points:



### HxW De 28 1

. 1 =

Where: H is the height of the cross

- sectional area in feet (ft)

W is the width of the cross

- sectional area in feet (ft)

Temperature Conversions:



### • Fahrenheit ( ο 

### F

) to Celsius ( ο 

### C ): 

# [ ] 32 9 5

− ° = ° F

C



### • Kelvin ( K ) to Celsius ( ο 

### C ): 15

. 273

− = ° K

C

Exit Velocity of Emission Release Points:



### A Q V =

Where: V is the gas exit velocity in feet per second (ft/s) Q is the volumetric flow rate in cubic feet per sec (ft 3 /s)

A is the cross

- sectional area in square feet (ft 2 )

Calculation of Volumetric Gas Flow Rate for an Emission Release Point:



### VA Q =

Volumetric gas flow rate (ft 3 /s) = [exit velocity (ft/s) x п x (emission release point internal diameter (ft)) 2 ]
25

### 51 6. Emission Form Instructions

Sample Emission Form

The Emission Form reports all the air pollutant data emitted from your facility. Use the instructions below to complete the E m ission

Form.



### Please note the following helps

Command Buttons:

MENU

- Select to open the Menu which will show links to other forms, websites and a variety of information needed to submit the emission inventory.

PREVIOUS

- Select to open the Emission Relea se Point Form.

NEXT

- This selection will open the Control Equipment Form when the “Control Status Code” column indicates “Controlled” for any record. Otherwise it will open the Emission Data Certification

Form for a Major or Synthetic Minor Source

. HELP

- Select to open Online Help for instructions in the completion of the emission inventory forms.



### Data Fields

Item 1

- Emission Unit ID: All the cells in this column are automatically filled based on entries made on the Emission

Period Form.

Item 2

– Emi ssion Process ID: All the cells in this column are automatically filled based on entries made on the

Emission Period Form.

Item 3

– Pollutant: Left double

- click in the cell to initiate a code search. Then follow the instructions provided by the

onscreen dialog boxes. Select the Pollutant Code that best applies to your facility.

Item 4

- SCC Code: All the cells in this column are automatically filled based on entries made on the Emission Period

Form.

Item 5

- Emissions Release Point ID: All the cells in this column are automatically filled based on entries made on the

Emission Period Form.

Item 6

- Start Date: Left double

- click and enter the start date of the period in which reported emissions occur, expressed in units of year month day (yyyymmdd). F or more information see the topics below entitled, “Start Date and End Date” and “How to Enter Seasonal Throughput for Total Annual Emissions”.

Item 7

- End Date: Left double

- click and enter the end date of the period in which reported emissions occur, e xpressed in units of year month day (yyyymmdd). For more information see the topics below entitled, “Start Date and End Date”

and “How to Enter Seasonal Throughput for Total Annual Emissions”.

Item 8

- Start Time: Left double

- click and enter the start ti me of the period in which reported emissions occur, expressed in units of hours and minutes (hhmm).

26

### 52 Item 9

- End Time : Left double

- click and enter the end time of the period in which reported emissions occur, expressed in units of hours and minutes (hh mm).

Item 10

- Emission Numeric Value: Left double

- click and enter the numeric estimate of the emissions released to the

ambient air.

Item 11

- Emission Units of Measure: Left double

- click and enter the unit of measure for each emission, a yearly

total

. For criteria pollutants use tons (TON); and for the HAPS and non

- criteria pollutants use pounds (LB)

.

Item 12

- Emission Type Code: Left double

- click and enter in the cell then follow the instructions provided by the onscreen dialog boxes. Select the E mission Type Code that best applies to your facility from the codes retrieved by the code search. For more information see the topics below entitled, “Emission Type Codes” and “How to Enter Seasonal Throughput for Total Annual Emissions”.

Item 13

- Emissi on Factor Numeric Value: Left double

- click and enter the numeric value of the emissions factor. The value can be up to 10 digits in length.

Item 14

- Emission Factor Numerator Units: Enter the units in the n umerator for each emission factor.

Item 15

- Emissions Factor Denominator Units: Enter the units in the denominator for each emission factor.

Item 16

- Material Codes: THIS COLUMN IS AUTO

- FILLED WITH A DEFAULT VALUE selected based upon the

SCC Code Selection. If this value is inappropriate left do uble

- click in the cell then follow the instructions provided by the onscreen dialog boxes.

Item 17

- Material I/O Code: THIS COLUMN IS AUTO

- FILLED WITH A DEFAULT VALUE selected based upon

the SCC Code Selection. If this value is inappropriate left doubl e

- click in the cell then follow the instructions provided by the Material I/O which is a designation that indicates whether a material is input, output, or existing onscreen dialog boxes. Enter the Material I/O Code that best applies from the codes display ed.

Item 18

- Material Description: THIS COLUMN IS AUTO

- FILLED WITH A DEFAULT VALUE selected based upon the SCC Code Selection. If this value is inappropriate follow the instructions outlined in item 12 above and this value will be replaced with one tha t is more suitable.

Item 19

- Emission Calculation Method Code: Left double

- click and follow the instructions provided by the onscreen dialog boxes. Select the Emission Calculation Method Code that best applies to your facility from the codes retrieved b y the code search.

Item 20

- Control Status Code: Left double

- click and follow the instructions provided by the onscreen dialog boxes. Select the Emission Calculation Method Code that best applies to your facility from the codes retrieved by the code

sea rch.

Item 21

- Emission Data Level Code: Left double

- click and follow the instructions provided by the onscreen dialog

boxes. Select the Emission Calculation Method Code that best applies to your facility from the codes retrieved by the

code search.

Not e: All criteria pollutants should be input in tonnage for the year , while all other pollutants (including HAPs) should be input in poundage per year

. When reporting emissions, do not subtract HAPs from VOC or particulate matter totals. Report HAPs in addi tion to criteria and non

- criteria emissions.



### Supplemental Information for the Emission Form The following information is for specific data elements in the Emission Form and is provided in addition to the Emission Form data dictionary. This information wil l assist you in correctly implementing the noted fields.

Start Date and End Date START DATE and END DATE data on the Emission Form must agree with the START DATE and END DATE data provided on the Emission Period Form. These fields report the time period i n which the reported emissions occur.

27

### 53 Emission Type Code

EMISSION TYPE = code description of the temporal designation of the emissions reported.

Example: EMISSION TYPE = 30, for the emissions within total period designated. These fields report the

te mporal resolution of the emissions within that period.

How to Enter Seasonal Throughput for Total Annual Emissions Providing the seasonal throughput percentages with process schedule data and the total annual emissions is a good way to provide air quality modelers with information needed to determine average day emissions for a specific season of interest. Thus, the preferred reporting method is as follows:

Preferred Reporting Method

Form Data Element Entry Value

Emission START DATE YYYY0101

END DATE YY YY1231

EMISSION TYPE = 30, for entire period*

EMISSION NUMERIC VALUE Total emissions for annual time period specified

* Emission Type = 30 for the annual period Jan

– Dec is the correct method for reporting annual emissions.

28

### 54 7. Control Equipment Form Instructions

Sample Control Equipment Form

The Control Equipment Form reports all the control equipment from your facility. The information in the Control Equipment Form is reported by process an d by pollutant. The Control Equipment Form must be included if control(s) are in place which influence the amount of pollutant emitted from the reported process. If a Control Equipment Form is not reported, SCHD

- PCS assumes no controls are applied to the s pecific process reported. Use the instructions below to
complete the Control Equipment Form.



### Please note the following helps

Command Buttons:

MENU

- Select to open the Menu which will show links to other forms, websites and a variety of information

need ed to submit the emission inventory.

PREVIOUS

- Select to open the Emission Form.

NEXT

- This selection will open the Emission Data Certification Form for a Major or Synthetic Minor

Source

. HELP

- Select to open Online Help for instructions in the completi on of the emission inventory forms.



### Data Fields

Item 1

- Emission Unit ID: All the cells in this column are automatically filled based on entries made on the Emission

Form.

Item 2

- Installation/Modification Date: Left double

- click and enter the date (yyyymmdd) of installation or the most

recent reconstruction of the most recent modification of the identified control device. This is not a date on which routine repair or maintenance was done. Modification means any component of the control device was re placed and the fixed capital cost of the new component(s) was more than half of what it would have cost to purchase or construct a new

control device.

Item 3

- Process ID: All the cells in this column are automatically filled based on entries made on the Emission Form.

Item 4

- Emission Release Point ID: All the cells in this column are automatically filled based on entries made on the

Emission Form.

Item 5

- Pollutant Code: All the cells in this column are automatically filled based on entries made o n the Emission

Form.

Item 6

- Primary Control Efficiency (%): Left double

- click and enter the percent efficiency of the primary control equipment.

Item 7

- Capture Efficiency (%): Left double

- click and enter the numeric value for the percentage capture efficiency of the system. For more information see the topics below entitled, “Capture Efficiency (%)” and “When One Control Device Serves Multiple Process Segments”.

29

### 55 Item 8

- Total Capture/Control Efficiency (%): Left double

- click and enter the aggr egate value for all controls. For more information see the topics below entitled, “Total Capture/Control Efficiency (%)” and “When One Control Device Serves Multiple Process Segments”.

Item 9

- Primary Control Device Type Code: Left double

- click in the c ell to initiate a code search then follow the instructions provided by the onscreen dialog boxes. Select the Primary Control Device Type code for the primary or

first

- in

- line control device that best applies to your facility.

Item 10

- Secondary Control Device Type Code: Left double

- click in the cell to initiate a code search then follow the instructions provided by the onscreen dialog boxes. Select the Secondary Control Device Type code for the secondary or second

- in

- line control device that best applie s to your facility.

Item 11

- Control Device Name or Description: Left double

- click and enter a description of the control device.

Item 12

- Tertiary Control Device Type Code: Left double

- click in the cell to initiate a code search. Then follow the

ins tructions provided by the onscreen dialog boxes. Select the Tertiary Control Device Type code for the tertiary or third

in

- line control device that best applies to your facility.

Item 13

- Quaternary Control Device Type Code: Left double

- click in the cel l to initiate a code search. Then follow the instructions provided by the onscreen dialog boxes. Select the Quaternary Control Device Type code for the quaternary or fourth

- in

- line control device that best applies to your facility.



### Supplemental Informati on for the Control Equipment Form The following information is for specific data elements in the Control Equipment Form and is provided in addition to the Control Equipment Form data dictionary. This information will assist you in correctly implementing th e noted fields.

Capture Efficiency (%) means the weight per unit time of a pollutant entering a capture system and being delivered to a control device divided by the weight per unit time of the total pollutant generated by the source of the pollutant, ex pressed as

a percentage. The capture system includes, but is not limited to, hoods, ducts, fans, booths, ovens, dryers, etc., that contain, collect, and transport an air pollutant to a control device. For emission sources such as combustion devices where t he exhaust system is integral to the equipment, the capture efficiency is 100%.

Total Capture/Control Efficiency (%) is the collective percent efficiency value for all control devices reported, including system percent capture efficiency if known. This f ield is only applicable when there are device types reported in addition to a primary control device. The capture efficiency must be input if total capture/control efficiency is input. I f unknown, consult the supplier of the equipment

When One Control De vice Serves Multiple Process Segments If one control device serves multiple processes, create a Control Equipment record for every process that is controlled, e.g., duplicate the control equipment record for each unique process that shares the control devi ce. In this scenario, the control equipment percentage reported on duplicate control equipment records should be the same unless the control equipment percentage varies by the pollutant being controlled.

Example: Emission Processes 1 and 2 are vented to the same control device, with PRIMARY CONTROL EFFICIENCY equal to 85%.

Record No. Record Type Key Data

1 Emission Process Process ID = 1

2 Emission Process Process ID = 2

3 Control Equipment Process ID = 1 Primary Control Efficiency = 0.85

4 Control Equipment Process ID = 2 Primary Control Efficiency = 0.85

30

### 56 Common Pollution Control Device Efficiencies

In most cases, the control efficiencies for air pollution control devices that are commonly employed throughout industry can be obtaine d by consulting the Emission Inventory Improvement Program (EIIP), Volume II, Chapter 12, entitled “How to Incorporate Effects of Air Pollution Control Device Efficiencies and Malfunctions into Emission Inventory Estimates”. This is an EPA publication that can be obtained at www.epa.gov/ttn/chief/eiip/techreport/volume02/ii12.pdf . A copy of this publication will be available to reference in

our office from 8:00am

– 4:30pm Monday th rough Friday (except on holidays). If this publication does not include the control efficiency information for the control equipment installed at your facility then you should request that the equipment manufacturer or supplier provide it to you. For more information please contact us at (901) 222

- 9571

31

### 57 8. Emission Data Certification Form Instructions

Sample Emission Data Certification Form

The Emission Data Certification Form is used to total the emis sions from your facility. This form consists of two pages. The first page is used to total criteria pollutants, non

- HAPs, and HAPS. The second page, which is a continuation of the first, is used to total more HAPs and it requires the signature of a respons ible company official to affirm the accuracy of the information submitted. The screenshots above are an incomplete representation of each page, however, they are presented here to convey the key data fields that must be addressed in each emission inventory repsonse. Both pages of these forms must be printed and submitted with the emission information for your facility. Use the instructions below to complete the Emission Data Certification Forms

32

### 58 Please note the following helps

Command Buttons:

MENU

- S elect to open the Menu which will show links to other forms, websites and a variety of information needed to submit the emission inventory.

PREVIOUS

- This selection will open the first page of the Emission Data Certification Form for a Major or Synthetic Minor Source (Note: this button does not appear on the first page of this form)

. NEXT

- This selection will open the second page of the Emission Data Certification Form for a Major or Synthetic Minor Source (Note: this button does not appear on the second page of this form)

. HELP

- Select to open Online Help for instructions in the completion of the emission inventory forms. Print 2010 Emission Inventory Questionnaire

- Select to print ALL of the EIQ forms (Note: this button does not appear on the first pag e of this form).

. Data Fields

Item 1

- List of Pollutants: Column 1 is separated into three sections, the “Criteria Pollutants” section, the “Other Pollutants” section, and the “Hazardous Air Pollutants” section (note: the Hazardous Air Pollutants (HAP s) section requires a generous amount of space and it is continued on the second page of these forms). Essentially, all data entered into this column will be used to locate and retrieve the numeric quantities of each pollutant reported on the “Emission For m”. As you can see in the screenshot above, the “Criteria Pollutants” section of this column does not require any data entry because the criteria pollutants are already listed in spaces 1

- 9. Hence, nothing is required of Major and Synthetic Minor Sources i n this section.

On the other hand, to locate and retrieve the numeric quantities of each pollutant reported on the “Emission Form” for the “Other Pollutants” and “Hazardous Air Pollutants” sections, Major and Synthetic Minor Sources must enter the

Chemica l Abstract System numbers (CAS#) into the appropriate spaces provided in this column (note: CAS# should only be entered one time exactly as it appears on the “Emission Form”). Specifically, all non

- HAPs must be entered in

the “Other Pollutants” section in spaces 10a through 10k . And all HAPs must be entered in the “Hazardous Air Pollutants” section in spaces 11a through 11an on page 1 of this form and in spaces 11ao through 11ci on page 2 of this form. Once all CAS#s have been entered, the total amount for each pollutant reported on the “Emission Form” will automatically be entered in both the “Annual Emissions” columns and the “Total Emissions” columns.

Minor Sources need not do anything for 1 through 9 because this information has already been entered. Ho wever, in

both the “Other Pollutants” and “Hazardous Air Pollutants” sections the pollutant CAS# must be entered next to the alphabetic characters in spaces 10 and 11. Again, u se space 10 for non

- HAPs and use 11 exclusively for HAPs.

Item 2

- (Major & Sy nthetic Minor Sources Only) Annual Emissions: Major and Synthetic Minor Sources that have utilized the electronic format to report emissions activity in this questionnaire will find that this information has been

auto

- filled for the criteria pollutants. H owever, for the non

- HAPs and HAPs the CAS#s must entered in the appropriate

spaces.

Item 3

- (Minor Sources Only) Annual Emissions: Left double

- click and enter the annual emission amounts for each pollutant. Express criteria pollutant amounts in tons and hazardous pollutant amounts in pounds

.

Item 4

- Accidental Releases: Left double

- click and enter information pertaining to accidental releases. Express criteria pollutant amounts in tons and hazardous pollutant amounts in pounds

.

Item 5

– Total Emissio ns: No input is required here, however, if CAS#s has not been entered for the non

- HAPs and the HAPs, totals will not appear. This spreadsheet application will automatically sum the pollutant totals. Please make sure that you have expressed the criteria pol lutant in tons and the hazardous and other air pollutants in pounds

. Please verify the accuracy of the totals.

Item 6

- Total Emissions for which Emissions fee has been paid: Left double

- click and enter the emissions amounts for each pollutant that you pa id emissions fees for in your 2010 Emissions Fees Bill.

Item 7

- Does this report contain confidential information?: Please respond Yes or No. Express criteria pollutant

amounts in tons and hazardous pollutant amounts in pounds

.

33

### 59 Item 8

- Source Numb er: No input is required here

. A default value has been selected based upon the Source Number

entered on the General Plant Information Form.

Item 9

- Company Name: No input is required here

. A default value has been selected based upon the Company Name

entered on the General Plant Information Form.

Item 10

- Please Print Your Name Here: Left double

- click and enter the name of the responsible company official

here.

Item 11

- Please Sign Your Name Here: The “Emissions Data Certification Form” must be s igned by an official responsible for attesting to the accuracy of the emission inventory data. This form must be printed, signed and returned with the emission inventory data.

Item 12

- Date: Enter the date.

34

### 60 APPENDIX E 6 : EIQ SCREENSHOTS



## SHELBY COUNTY 2010 EMISSION INVENTORY QUESTIONNAIRE
(with emission inventory code finders shown in screenshots which follow)

Menu

### 61 General Plant Information Form

### 62 General Plan Information Form Row19

- Facility Ca tegory Code Finder

### 63 General Plant Information Form Row21

- SIC and NAICS Code Finder

### 64 General Plant Information Form Row22

- SIC and NAICS Code Finder

### 65 General Plant Information Form Row26

- MACT Compliance Status Finder

### 66 General Plant Informatio n Form Row27

- MACT Code Finder

### 67 Emission Period Form

### 68 Emission Period Form Col umn 7

- Units of Measurement Locator

### 69 Emission Period Form Col umn 8

- Source Classification Code (SCC) Finder

### 70 Emission Process Form

### 71 Emission Process Form Col umn 5

- MACT Code Finder

### 72 Emission Process Form Col umn 9

- Heat Content Units of Measure

### 73 Emission Unit Form

### 74 Emission Unit Form Col umn 4

- SIC and NAICS Code Finder

### 75 Emission Release Point Form

### 76 Emission Release Point Form Col umn 4

- Emission Release Point Type Code Finder

### 77 Emission Form

### 78 Emission Form Col umn 3

- Pollutant Code Finder

### 79 Emission Form Col umn 11

- Units of Measurement Locator

### 80 Emission Form Col umn 12

- Emission Type Code Finder

### 81 Emission Form Col umn 14

- Units of Measurement Locator

### 82 Emission Form Col umn 15

- Units of Measurement Locator

### 83 Emission Form Col umn 19

- Emission Calculation Method Code Finder

### 84 Emission Form Col umn 20

- Control Status Information Request

### 85 Emission Form Col umn 21

- Emission Data Level Code Finder

### 86 Control Equipment Form

### 87 Control Equipment Form Columns 9 , 11, 13, and 15

- Control Equipment Code Finder

### 88 Emission Data Certification Form (page 1)

### 89 Emission Data Certification Form (page 2)