Appendix A 

2008 Base Year Annual 

Carbon Monoxide (CO) Emissions Inventory 

For St. Louis County and St. Louis City 

Missouri Department of Natural Resources 

Division of Environmental Quality 

Air Pollution Control Program 

Jefferson City, Missouri 

Adoption 

March 27, 2014 

Project Number: 1971-CO-5 

 
This page left intentionally blank.
Page 3 

Table of Contents 

TABLE OF CONTENTS 2

LIST OF APPENDICES 5

LIST OF TABLES 6

1.0 INTRODUCTION 7

1.1 PURPOSE 7

1.2 INVENTORY COVERAGE 7

1.2.1 GEOGRAPHY 7

1.2.2 EMISSION YEAR 7

1.2.3 POLLUTANTS 7

1.3 CONTENTS OF REPORT 7

1.4 AUTOMATED SYSTEMS USED 8

1.5 INVENTORY EXCLUSIONS 8

1.6 GUIDANCE AND REFERENCE DOCUMENTS 8

1.7 LIST OF CONTACTS 9

2.0 EMISSIONS SUMMARY 9

2.1 SUMMARY BY COUNTY AND CATEGORY 9

3.0 INVENTORY DOCUMENTATION 10

3.1 POINT SOURCE EMISSIONS 10

3.1.1 PROCEDURES AND METHODOLOGIES 10

3.1.2 EMISSION INVENTORY QUESTIONNAIRE (EIQ) 10

3.1.3 LIST OF FACILITIES AND EMISSIONS 13

3.2 NONPOINT SOURCE EMISSIONS 22

3.2.1 PROCEDURES AND METHODOLOGIES 22

3.2.2 LIST OF SOURCE CATEGORIES AND EMISSIONS 22

3.2.3 SOURCE CATEGORY DOCUMENTATION 40

3.2.3.1 Fossil Fuel Combustion – Residential – Coal Combustion 40

3.2.3.2 Fossil Fuel Combustion – Residential – Distillate Oil 44

3.2.3.3 Fossil Fuel Combustion – Residential - Kerosene 46

3.2.3.4 Fossil Fuel Combustion – Residential – Natural Gas 49

3.2.3.5 Commercial Cooking 52

3.2.3.6 Open Burning – Land Clearing Debris 53

3.2.3.7 Open Burning – Residential Household Waste 58

3.2.3.8 Open Burning – Yard Waste – Leaf and Brush Species 61

3.2.3.9 Fuel Combustion – Industrial and Commercial/Institutional (ICI) 64

3.2.3.10 Fossil Fuel Combustion – Residential – Liquefied Petroleum Gas (LPG) 66

3.2.3.11 Fuel Combustion – Residential- Wood 68

3.2.4 NONPOINT SOURCE EMISSION SUMMARY 68
Page 4 

3.3 MOBILE SOURCE EMISSIONS 69

3.3.1 NONROAD MOBILE SOURCES 69

3.3.1.1 Procedures and Methodologies 69

3.3.1.2 List of Source Categories and Emissions 69

3.3.1.3 Source Category Documentation 70

3.3.1.4 Nonroad Source Emission Summary 70

3.3.2 ONROAD MOBILE SOURCES 70

3.3.2.1 Mobile Model Choice 70

3.3.2.2 Mobile Model Inputs 71

3.3.2.3 On Road Source Emissions Summary 84

4.0 QUALITY ASSURANCE/QUALITY CONTROL 84

4.1 POINT SOURCE QA/QC AND RESULTS 84

4.2 NONPOINT SOURCE QA/QC 86

4.3 MOBILE SOURCE QA/QC 87

4.3.1 NONROAD SOURCE QA/QC 87

4.3.2 ONROAD SOURCE QA/QC 87
Page 5 

LIST OF APPENDICES 

Appendix A-1: List of Statewide Point Source Emissions by Facility 

Appendix A-2: List of On Road Emissions by SCC for St. Louis County and 

St. Louis City 

Appendix A-3: Nonroad 2008 Category Documentation 

Appendix A-4: List of St. Louis County and St. Louis City Nonroad Emissions by 

SCC 

Appendix A-5: Nonpoint Industrial and Commercial/Institutional (ICI) Fuel 

Combustion Documentation 

Appendix A-6: Inspection/Maintenance Input Table Development Protocol for 

MOVES for Counties in the St. Louis Ozone Nonattainment Area 
Page 6 

LIST OF TABLES 

Table 1 Total 2008 CO Emissions for St. Louis City and St. Louis County (tons per year) _____________ 9

Table 2 List of EIQ Forms _____________________________________________________________ 10

Table 3 St. Louis County and City 2008 Point Sources by NAICS _______________________________ 13

Table 4 St. Louis County and City 2008 Point Source CO Emissions by Facility (tons per year) _______ 16

Table 5 Statewide Point Source Emissions by Category (tons per year) __________________________ 19

Table 6 Statewide Point Emissions by County (tons per year) __________________________________ 20

Table 7 Nonpoint 2008 Emission Records for St. Louis County and City (tons per year) _____________ 23

Table 8 Nonpoint Category Overview of Methodology _______________________________________ 27

Table 9 Nonpoint CO Emissions for St. Louis City and St. Louis County (tons per year) _____________ 68

Table 10 St. Louis County and City 2008 Nonroad Emissions (excluding Marine and Rail Emissions) __ 70

Table 11 St. Louis County and City 2008 Marine and Rail Emissions ____________________________ 70

Table 12 St. Louis County and City Total 2008 Nonroad Mobile Source Emissions _________________ 70

Table 13 2008 Vehicle Miles Traveled by County ___________________________________________ 72

Table 14 Missouri Registration Distribution _______________________________________________ 74

Table 15 2008 Source Type Population ___________________________________________________ 75

Table 16 2008 Annual VMT by HPMS Vehicle Type, County, and Year __________________________ 75

Table 17 Age Distribution by Source Type _________________________________________________ 76

Table 18 Inspection and Maintenance Data for 2008 ________________________________________ 77

Table 19 Fuel Formulation for 2008 _____________________________________________________ 78

Table 20 2008 Fuel Supply _____________________________________________________________ 79

Table 21 Average Monthly Temperatures by Hour of the Day for St. Louis County in Fahrenheit ______ 80

Table 22 Average Monthly Percent Relative Humidity by Hour of the Day for St. Louis County _______ 81

Table 23 Average Monthly Temperatures by Hour of the Day for St. Louis City in Fahrenheit ________ 82

Table 24 Average Monthly Percent Relative Humidity by Hour of the Day for St. Louis City __________ 83

Table 25 On Road Mobile CO Emissions for St. Louis City and St. Louis County (tons per year) ______ 84
Page 7 

1.0 Introduction 

1.1 Purpose 

This document meets the nonattainment plan provisions under the Clean Air Act Section 172 

(c)(3): 

“Such plan provisions shall include a comprehensive, accurate, current inventory of

actual emissions from all sources of the relevant pollutant or pollutants in such area,

including such periodic revisions as the Administrator may determine necessary to assure

that the requirements of this part are met.”

Missouri’s limited maintenance plan for the 8-hour CO National Ambient Air Quality Standard 

(NAAQS) requires a base year emissions inventory for 2008. The inventory is comprehensive in 

its inclusion of multiple source categories (point, nonpoint or area, and mobile sources), it is 

accurate based on the quality assurance steps outlined in Section 4, contains current 2008 actual 

emissions for CO, and can be updated through the triennial National Emissions Inventory (NEI). 

Emissions are documented for both the statewide inventory and the St. Louis Nonclassifiable CO 

Maintenance Area. 

1.2 Inventory Coverage 

1.2.1 Geography 

The inventory covers St. Louis County and the City of St. Louis. Several summaries of 

statewide Missouri totals are also included for reference. There are no inventory components 

provided by local or tribal agencies. 

1.2.2 Emission Year 

Emission year 2008 is the base year. 

1.2.3 Pollutants 

The only pollutant covered in the inventory is the criteria pollutant CO. 

1.3 Contents of Report 

This report documents the 2008 inventory in detail, from its creation, quality assurance, and final 

summaries. It also details the qualifications and limitations of the inventory. The document is 

arranged by purpose, emission summaries, documentation, quality assurance, and detailed 

appendices with lengthy emissions data tables and EPA provided category documentation. 
Page 8 

1.4 Automated Systems Used 

The 2008 emission inventory is maintained across multiple computing systems. Point source 

inventories are compiled from facility-supplied information in the Missouri Emissions Inventory 

System (MoEIS) database. Point sources are allowed to submit their inventory data via the 

MoEIS web interface or on hardcopy paper forms which are data entered to the electronic 

system. Nonpoint emissions are calculated using Microsoft® Excel spreadsheet and Access 

database tools. Mobile emissions are estimated using EPA’s Motor Vehicle Emissions Simulator 

(MOVES), and the National Mobile Inventory Model (NMIM) which incorporates the 

NONROAD2008 model. 

1.5 Inventory Exclusions 

This 2008 inventory does not include biogenic or geogenic emissions. The inventory does not 

include the nonpoint categories for wildfire, prescribed, or agricultural burning, agricultural 

tilling, plus others described in section 3.2.2. This inventory does not include hazardous air 

pollutant (HAP) inventories as they are not relevant pollutants for the Carbon Monoxide 

Maintenance plan. The HAP inventory is documented in Missouri’s 2008 National Emissions 

Inventory Documentation and is available on EPA’s NEI page at 

http://www.epa.gov/ttn/chief/net/2008inventory.html. Point emissions data is summarized at the 

facility level in this document, though facility operational data and emission process data is 

collected and submitted to the NEI. 

1.6 Guidance and Reference Documents 

This document is completed with the following references: 

 Emissions Inventory Guidance for Implementation of Ozone and Particulate matter 

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

(August 2005, EPA-454/R-05-001, 

http://www.epa.gov/ttnchie1/eidocs/eiguid/index.html) 

 Emission Inventory Improvement Plan (EIIP) (July 1997, 

http://www.epa.gov/ttn/chief/eiip/index.html) 

 2008 National Emissions Inventory Data version 1.5 and documentation (May 2011, 

http://www.epa.gov/ttn/chief/net/2008inventory.html) 

 Air Emission Reporting Rule (Dec 2008, http://www.epa.gov/ttn/chief/aerr/) 

 AP-42, Compilation of Air Pollutant Emission Factors 

(http://www.epa.gov/ttn/chief/ap42/index.html) 

 MOVES Technical Guidance, Policy Memos, etc at 

(http://www.epa.gov/otaq/models/moves/index.htm) 

 National Mobile Inventory Model (NMIM) (http://www.epa.gov/oms/nmim.htm) 
Page 9 

1.7 List of Contacts 

The emission inventory is compiled by Stacy Allen, Environmental Specialist IV and Emission 

Inventory/Data Management Unit Chief with the Missouri Department of Natural Resources. 

Specific contacts for other portions of the inventory are: 

Point and Nonpoint Emissions: Stacy Allen, stacy.allen@dnr.mo.gov

Mobile (Onroad and Nonroad) Emissions: Nathan O’Neil, nathan.o’neil@dnr.mo.gov

2.0 Emissions Summary 

2.1 Summary by County and Category 

Table 1 Total 2008 CO Emissions for St. Louis City and St. Louis County 

Area Source Category 2008 CO Emissions 

(tons/year) 

St. Louis County Point Sources 4,995.09

St. Louis County Area Sources 8,752.71

St. Louis County On Road Mobile Sources 132,855.83

St. Louis County Off Road Mobile Sources 76,069.44

St. Louis County subtotal 222,673.07

St. Louis City Point Sources 1,319.83

St. Louis City Area Sources 3,086.57

St. Louis City On Road Mobile Sources 34,576.81

St. Louis City Off Road Mobile Sources 15,573.38

St. Louis City subtotal 54,556.59

Total (St. Louis City and County) Point Sources 6,314.92

Total (St. Louis City and County) Area Sources 11,839.28

Total (St. Louis City and County) On Road Mobile Sources 167,432.64

Total (St. Louis City and County) Off Road Mobile Sources 91,642.82

Total (St. Louis City and County) Total 277,229.66

 
Page 10 

3.0 Inventory Documentation 

3.1 Point Source Emissions 

3.1.1 Procedures and Methodologies 

The point source inventory is based on information collected on Emissions Inventory 

Questionnaires (EIQs). Facilities with a construction or operating permit from the Air Pollution 

Control Program are required to submit an EIQ on an annual basis per 10 CSR 10-6.110. The 

EIQ details the amount of air pollution emitted and other operational data for the previous 

calendar year. 

2008 point sources include those with Part 70 and Intermediate operating permits. The EIQ 

solicitation was mailed to facilities in January 2009. The due date for 2008 reporting was June 1, 

2009, and all point source reports were received and included in this document summary. 

3.1.2 Emission Inventory Questionnaire (EIQ) 

All point source emissions data for the State of Missouri is contained in a database called the 

Missouri Emissions Inventory System (MoEIS). Emission reports may be submitted either 

directly via the MoEIS web interface, a user-friendly, online portal linked directly to the MoEIS 

database, or they may be submitted on the hardcopy EIQ forms. Hardcopy EIQ submittals are 

then data entered into the MoEIS database by EI unit staff members. As a result, the MoEIS 

database is updated yearly with the most current emissions data for the State of Missouri. 

Hardcopy EIQ forms are described in Table 2. All hardcopy forms have an electronic 

counterpart in the MoEIS web interface system. In general, forms beginning with number one 

(1) provide general information about a facility, forms beginning with a two (2) provide the 

detailed annual emission calculations, including activity or throughput, emission factors, 

emissions, and operational characteristics. More information on EIQ forms and instructions and 

MoEIS is available at http://www.dnr.mo.gov/env/apcp/moeis/emissionsreporting.htm

Table 2 List of EIQ Forms 

FORM NAME FORM DESCRIPTION FORM 

NUMBER

FORM 1.0

GENERAL PLANT 

INFORMATION

GENERAL PLANT INFORMATION, PLANT-WIDE EMISSIONS 

TOTALS, SIGNATURE SECTION CERTIFYING SUBMITTED 

INFORMATION IS ACCURATE AND COMPLETE

780-1431 

FORM 1.1 PROCESS 

FLOW DIAGRAM

DIAGRAM IDENTIFYING AND LINKING ALL EMISSION 

UNITS, PROCESSES, AIR POLLUTION CONTROL DEVICES,

AND EMISSION RELEASE POINTS FOR A FACILITY. SUBMIT 

ONLY IF THERE HAVE BEEN CHANGES. 

780-1619 
Page 11 

FORM NAME FORM DESCRIPTION FORM 

NUMBER

FORM 1.2

SUMMARY OF 

EMISSION UNITS 

AND RELATED 

PROCESSES

LIST OF ALL EMISSION UNITS AND ASSOCIATED PROCESSES 

AND THE STATUS OF EACH (ACTIVE, INSIGNIFICANT,

DISMANTLED) 

780-1620 

FORM 2.0

EMISSION UNIT 

INFORMATION

MAIN EMISSIONS REPORTING FORM; SEPARATE FORM 2.0

REQUIRED FOR EACH PROCESS FOR WHICH EMISSIONS ARE 

BEING REPORTED (I.E., FORM 2.0 NOT REQUIRED FOR 

EMISSIONS BELOW REPORTING THRESHOLDS)

780-1621 

FORM 2.0C

CONTROL DEVICE 

INFORMATION

CONTROL DEVICE INFORMATION WHEN THERE IS A 

CONTROL DEVICE OPERATIVE AT AN EMISSION UNIT;

SEPARATE FORM 2.0C REQUIRED FOR EACH CONTROL 

DEVICE

780-1434 

FORM 2.0K

CHARCOAL KILN 

INFORMATION

DETAILS THE OPERATIONS AND CHARACTERISTICS OF 

CHARCOAL KILNS

780-1530 

FORM 2.0L

LANDFILL 

INFORMATION

FORM FOR REPORTING EMISSIONS FROM LANDFILLS 780-1583 

FORM 2.0P

PORTABLE 

EQUIPMENT 

INFORMATION

DETAILS THE LOCATIONS AND OPERATIONS FOR 

PORTABLE EQUIPMENT OPERATIONS INCLUDING 

QUARRIES, ASPHALT PLANTS, AND CONCRETE BATCH 

PLANTS

780-1433 

FORM 2.0S

STACK/VENT 

INFORMATION

STACK INFORMATION FOR EMISSION UNITS WHERE 

EMISSIONS FROM A PROCESS ENTER THE AMBIENT AIR 

THROUGH ONE OR MORE STACKS/VENTS

780-1435 

FORM 2.0Z OZONE 

SEASON 

INFORMATION 

FORM

CALCULATION OF OZONE SEASON DAY EMISSIONS OF 

VOC, NOX, OR CO; REQUIRED FROM FACILITIES LOCATED 

IN ST. LOUIS, ST. CHARLES, FRANKLIN AND JEFFERSON 

COUNTIES AND ST. LOUIS CITY WITH 10 TONS OR MORE OF 

VOC, NOX OR CO ANNUAL EMISSIONS. 

780-1452 

FORM 2.1 FUEL 

COMBUSTION 

WORKSHEET

INFORMATION RELATED TO COMBUSTION EQUIPMENT,

FUEL USAGE, AND THE CALCULATIONS ASSOCIATED WITH 

COMBUSTION PROCESSES 

780-1436 

FORM 2.2

INCINERATOR 

WORKSHEET

INFORMATION RELATED TO THE INCINERATOR, WASTE 

MATERIAL(S) INCINERATED, AND THE ANNUAL WASTE 

MATERIAL THROUGHPUT

780-1438 

FORM 2.3 VOC

PROCESS MASSBALANCE 

WORKSHEET

CALCULATES A VOC MASS BALANCE EMISSION FACTOR 780-1440 
Page 12 

FORM NAME FORM DESCRIPTION FORM 

NUMBER

FORM 2.4

VOLATILE 

ORGANIC LIQUID 

LOADING 

WORKSHEET

CALCULATES AN EMISSION FACTOR FOR PETROLEUM 

LIQUID LOADING INTO TANK TRUCKS, RAIL CARS, AND 

BARGES BASED ON AP-42 

780-1625 

FORM 2.5L

GENERAL LIQUID 

STORAGE TANK 

INFORMATION

INFORMATION ABOUT STORAGE TANKS 780-1444 

FORM 2.7 HAUL 

ROAD FUGITIVE 

EMISSIONS 

WORKSHEET

CALCULATES AN EMISSION FACTOR FOR UNPAVED HAUL 

ROADS BASED ON AP-42 FORMULA

780-1445 

FORM 2.8

STORAGE PILE 

WORKSHEET

CALCULATES EMISSION FACTORS FOR ACTIVITY AND 

WIND EROSION FROM STORAGE PILES BASED ON AP-42

FORMULAS

780-1446 

FORM 2.9 STACK 

TEST/CONTINUOUS 

EMISSION 

MONITORING 

WORKSHEET

DOCUMENTATION FOR EMISSION FACTORS DERIVED FROM 

STACK TESTS OR CEM DEVICES

780-1447 

FORM 2.T

HAZARDOUS AIR 

POLLUTANT 

WORKSHEET

INFORMATION ON HAP CHEMICALS EMITTED AT THE 

PROCESS LEVEL; SEPARATES INDIVIDUAL HAPS FROM 

THOSE INCLUDED IN VOC/PM EMISSIONS

780-1448 

FORM 3.0

EMISSION FEE 

CALCULATION

SUMMARY TABLE SHOWING EMISSIONS FROM ALL 

PROCESSES 

780-1509 

FORM 3.0CK

EMISSION FEE 

CALCULATION FOR 

CHARCOAL KILNS

SUMMARY TABLE SHOWING EMISSIONS FROM CHARCOAL 

KILN OPERATIONS

780-1508 

DRY CLEANER –

NONCHLORINATED 

AND PETROLEUM 

BASED SOLVENTS

EMISSIONS CALCULATIONS FOR DRY CLEANERS USING 

NON-CHLORINATED SOLVENT AND WITH COMBINED 

DRYER CAPACITY OF 84 POUNDS OR MORE

780-1954 

FORM 4.0

FINANCIAL COST 

ESTIMATE

ESTIMATE THE COST OF COMPLYING WITH AIR POLLUTION 

REGULATION

780-1622 

Point source EIQ data received via hard copy forms is data entered to the MoEIS emissions 

database by emission inventory staff. During this step, process-level emissions and operational 

information are checked for consistency between the hardcopy forms and database calculations, 

and inconsistencies are flagged for review. Problems include, but are not limited to: 

 Incorrect Source Classification Codes (SCCs) 

Emission unit numbering changes 
Page 13 

Calculation errors 

Missing or incomplete records 

Transposition errors 

If no errors are found during data entry, and the emissions reported on the hardcopy full EIQ 

match what is calculated by the MoEIS database, then the emission report is considered complete 

and data entered. 

EIQs with inconsistencies are moved from emission inventory data entry staff to a member of the 

technical review team. The technical review team will address the problems encountered during 

data entry by identifying the specific issue(s) and possible causes and contacting the facility to 

resolve those issues. Other issues may also be addressed during the review, including the 

appropriate use of emission estimation methods, documentation of source data, and consistency 

with permit emission calculations. Supplemental EIQ information may be collected by staff via 

telephone or email contact with the facility in question. Information collected in this manner will 

be recorded on the EIQ for reference, tracking and QA auditing. If the facility is requested to 

submit follow up verification or additional information in writing, a statement pertaining to this 

request will also be recorded on the EIQ. The information recorded will include the date of the 

call or contact, staff person’s name, contact person’s name, and written documentation of the 

call. 

After the submission deadline of June 1 has passed, a list of unsubmitted EIQs is generated and 

sent to the compliance and enforcement section of the Air Pollution Control Program. With all 

emissions data contained in the MoEIS database, further quality assurance steps are completed as 

described in Section 4. 

3.1.3 List of Facilities and Emissions 

There are 139 facilities in the point source inventory for the Missouri counties of the St. Louis 

nonattainment area. Their primary economic activity described by their North American 

Industry Classification System (NAICS) code is listed in Table 3 for St. Louis City and St. Louis 

County. The emissions of each facility in tons per year are listed in Table 4. 

Table 3 St. Louis County and City 2008 Point Sources by NAICS 

Primary Economic Activity Description 

St. Louis 

County 

St. Louis 

City 

Adhesive Manufacturing 1 1

Administration of Air and Water Resource and Solid Waste Management Programs 1

Air-Conditioning and Warm Air Heating Equipment and Commercial and Industrial 

Refrigeration Equipment Manufacturing 

Aircraft Manufacturing 1 

All Other Basic Organic Chemical Manufacturing 1

All Other Miscellaneous Textile Product Mills 1

All Other Rubber Product Manufacturing 1

Asphalt Paving Mixture and Block Manufacturing 6 1

Automobile Manufacturing 2 

Biological Product (except Diagnostic) Manufacturing 1

Breweries 1

Carburetor, Piston, Piston Ring, and Valve Manufacturing 1 
Page 14 

Primary Economic Activity Description 

St. Louis 

County 

St. Louis 

City 

Cement Manufacturing 

Coated and Laminated Packaging Paper Manufacturing 1 

Coffee and Tea Manufacturing 1

Colleges, Universities, and Professional Schools 1 1

Commercial and Industrial Machinery and Equipment (except Automotive and 

Electronic) Repair and Maintenance 1 

Commercial and Institutional Building Construction 1

Commercial Bakeries 1

Commercial Flexographic Printing 1 

Commercial Lithographic Printing 2 2

Crushed and Broken Limestone Mining and Quarrying 3 

Dry Pasta Manufacturing 1

Electronic Coil, Transformer, and Other Inductor Manufacturing 

Electroplating, Plating, Polishing, Anodizing, and Coloring 

Fabric Coating Mills 

Fabricated Structural Metal Manufacturing 

Farm Supplies Merchant Wholesalers 1

Flour Milling 2

Folding Paperboard Box Manufacturing 

Fossil Fuel Electric Power Generation 1 1

General Medical and Surgical Hospitals 5 3

General Warehousing and Storage 1

Glass Container Manufacturing 

Glass Product Manufacturing Made of Purchased Glass 1 

Grain and Field Bean Merchant Wholesalers 1

Heating Equipment (except Warm Air Furnaces) Manufacturing 1

Industrial Sand Mining 1 

Industrial Valve Manufacturing 

Inorganic Dye and Pigment Manufacturing 1 1

Institutional Furniture Manufacturing 1 

Iron and Steel Pipe and Tube Manufacturing from Purchased Steel 

Laminated Aluminum Foil Manufacturing for Flexible Packaging Uses 1

Leather and Hide Tanning and Finishing 1

Machine Tool (Metal Cutting Types) Manufacturing 1 

Manifold Business Forms Printing 1

Metal Can Manufacturing 

Metal Coating, Engraving (except Jewelry and Silverware), and Allied Services to 

Manufacturers 2

Motor Vehicle Body Manufacturing 

Motor Vehicle Seating and Interior Trim Manufacturing 

National Security 1

Natural Gas Distribution 1

Natural Gas Liquid Extraction 2

Newspaper Publishers 1 1

Offices of Physicians (except Mental Health Specialists) 1

Other Aircraft Parts and Auxiliary Equipment Manufacturing 1 

Other Metal Container Manufacturing 1 
Page 15 

Primary Economic Activity Description 

St. Louis 

County 

St. Louis 

City 

Other Metal Valve and Pipe Fitting Manufacturing 1

Paint and Coating Manufacturing 3

Pesticide and Other Agricultural Chemical Manufacturing 1 

Petrochemical Manufacturing 1 2

Petroleum Bulk Stations and Terminals 1 

Pharmaceutical Preparation Manufacturing 3 

Plastics Material and Resin Manufacturing 1 

Polystyrene Foam Product Manufacturing 1 

Primary Smelting and Refining of Nonferrous Metal (except Copper and Aluminum) 

Railroad Rolling Stock Manufacturing 

Research and Development in the Physical, Engineering, and Life Sciences 1 

Rubber and Plastics Hoses and Belting Manufacturing 1 

Secondary Smelting and Alloying of Aluminum 1

Semiconductor and Related Device Manufacturing 

Sewage Treatment Facilities 3 

Ship Building and Repairing 

Sign Manufacturing 

Soap and Other Detergent Manufacturing 2

Solid Waste Landfill 4 

Spice and Extract Manufacturing 1

Steel Foundries (except Investment) 

Steel Investment Foundries 

Toy and Hobby Goods and Supplies Merchant Wholesalers 1

Truck Trailer Manufacturing 1 

Unlaminated Plastics Profile Shape Manufacturing 

Wired Telecommunications Carriers 1

Total Number of Facilities 52 49
Page 16 

Table 4 St. Louis County and City 2008 Point Source CO Emissions by Facility (tons per year) 

Area Site ID Facility Name 

CO 

Emissions 

St. Louis County 0002 Chrysler Assembly Plant 1-Fenton 21.86 

St. Louis County 0010 Amerenue-Meramec Plant 3,811.99 

St. Louis County 0017 Fred Weber Inc-North Stone 

St. Louis County 0019 Fred Weber Inc-South Stone 

St. Louis County 0020 Monsanto World Headquarters-Lindbergh Blvd 10.33 

St. Louis County 0021 U S Silica Company-Pacific 3.51 

St. Louis County 0025 Dana Corporation-Perfect Circle Division 0.87 

St. Louis County 0032 Pharmacia-Chesterfield Village 14.82 

St. Louis County 0035 Rockwood Pigments Na Inc-E Hoffmeister 8.27 

St. Louis County 0042 Washington University-Millbrook Blvd 18.42 

St. Louis County 0057 St Louis Post-Dispatch-Dunlap Ind Dr 0.16 

St. Louis County 0064 Sunnen Products Company-Maplewood 1.01 

St. Louis County 0065 St Louis Airport Authority-Lambert International Blvd 9.38 

St. Louis County 0111 Simpson Construction Materials Llc-West Lake Quarry & Material Co 15.71 

St. Louis County 0141 Energy Petroleum Company-Kienlen 

St. Louis County 0208 Printpack Inc-Hazelwood Plant 3.45 

St. Louis County 0217 Metropolitan St Louis Sewer District-Lemay Waste Water Treatment Plant 321.07 

St. Louis County 0226 Nesco Container Corp-Fenton 1.07 

St. Louis County 0230 McDonnell Douglas Corp /Boeing Company-Lindbergh Plant 20.96 

St. Louis County 0231 Chrysler Corp-North Plant 65.23 

St. Louis County 0238 St Louis Lithographing Company-Heege Avenue 

St. Louis County 0242 Multiplex Display Fixture-Fenton 0.49 

St. Louis County 0275 Bussen Quarries Inc-Bussen Road 

St. Louis County 0276 Ruprecht Quarry-Paule Rd 

St. Louis County 0281 BFI Missouri Pass Landfill-Maryland Heights 30.58 

St. Louis County 0282 Color Art Inc-Crestwood 1.01 

St. Louis County 0308 Fred Weber Inc Sanitary Landfill-St Louis County 130.13 

St. Louis County 0310 Onyx Oak Ridge Landfill Inc-(West County) 44.89 

St. Louis County 0312 Bridgeton Landfill Authority-Bridgeton 244.28 

St. Louis County 0315 Flex-O-Lite Inc-Fenton - 

St. Louis County 0317 Pro-Tect Mfg Inc-Ferguson Ave 

St. Louis County 0318 St Marys Health Center-Richmond Heights 6.74 

St. Louis County 0327 Camie-Campbell Inc-Watson Industrial Park 

St. Louis County 1012 Belt Service Corp-Earth City 0.47 

St. Louis County 1015 Kv Pharmaceutical Company-Brentwood - 

St. Louis County 1029 Depaul Health Center-Bridgeton 6.05 

St. Louis County 1047 Kv Pharmaceutical Company-Schuetz Rd 1.22 

St. Louis County 1052 Veterans Admin Medical Center-Jefferson Barracks Drive - 

St. Louis County 1097 Reichhold Chemicals Inc-Valley Park 4.40 

St. Louis County 1101 St Luke'S Hospital-Woods Mill Road 5.24 
Page 17 

Area Site ID Facility Name 

CO 

Emissions 

St. Louis County 1156 St Joseph Hospital-Kirkwood 2.99 

St. Louis County 1192 Pan-Glo St Louis-Trenton Avenue 

St. Louis County 1204 Whitmire Microgen Research Laboratory-Kirkwood 

St. Louis County 1205 Metropolitan St Louis Sewer District-Mo River Wasterwater Treatment Plant 7.10 

St. Louis County 1210 Metropolitan St Louis Sewer District-Coldwater Creek Sewage Treatment Plant 50.69 

St. Louis County 1226 Simpson Construction Materials Llc-Valley Park 20.28 

St. Louis County 1248 Fred Weber Inc-South Asphalt 24.49 

St. Louis County 1249 Fred Weber Inc-North Asphalt H & B 37.15 

St. Louis County 1250 Fred Weber Inc-North Asphalt B & G 37.42 

St. Louis County 1489 Gkn Aerospace Services Inc-Berkeley 11.36 

St. Louis County 1520 F & S Real Eastate Inc-St Louis 

St. Louis County 1538 KV PHARMACEUTICAL-BRIDGETON - 

St. Louis County Total 4,995.09 

St. Louis City 0003 Anheuser-Busch Inc-St Louis 145.98 

St. Louis City 0017 Mallinckrodt Inc 77.49 

St. Louis City 0027 Precoat Metals 5.10 

St. Louis City 0031 ADM Gromark River Systems-St Louis 0.00 

St. Louis City 0038 Trigen-St Louis Energy Corp-Ashley Street Station 46.27 

St. Louis City 0040 Washington Univ Medical School-Boiler Plant 28.23 

St. Louis City 0047 Fred Weber Inc-Asphalt Plant 9.56 

St. Louis City 0053 Metropolitan St Louis Sewer District-Bissel Plant 552.29 

St. Louis City 0057 Procter & Gamble-Procter & Gamble 9.89 

St. Louis City 0063 Dial Corp-Dial Corp 8.39 

St. Louis City 0066 Elementis Specialties Inc 6.78 

St. Louis City 0070 Astaris Llc-Carondelet Plant 27.07 

St. Louis City 0096 P D George Co (The) 3.73 

St. Louis City 0097 U S Paint Div Of Grow Group-U S Paint Div Of Grow Group 

St. Louis City 0118 Alumax Foils Inc-Alcoa Foil Products/Alumax Foils Inc 14.02 

St. Louis City 0159 ADM/TPC Milling Co-Pillsbury Company - 

St. Louis City 0161 Poly One Corporation-St Louis 

St. Louis City 0162 Marquette Tool & Die 

St. Louis City 0175 St Louis Metallizing-St Louis 0.08 

St. Louis City 0179 Italgrani Elevator 3.22 

St. Louis City 0200 St Alexius Hospital-St Louis 0.33 

St. Louis City 0204 Bjc Health System-Pavillion 1.51 

St. Louis City 0269 Sensient Colors Inc-Baldwin Plant 2.41 

St. Louis City 0391 Hermann Oak Leather Co - 

St. Louis City 0468 Lange-Stegmann Co 0.00 

St. Louis City 0697 Sigma - Aldrich Co 3.14 

St. Louis City 0808 Chemisphere Corporation-Chemisphere 

St. Louis City 0809 PQ Corporation (The)-St Louis 9.65 
Page 18 

Area Site ID Facility Name 

CO 

Emissions 

St. Louis City 0938 Interstate Brands Corp-Interstate Brands Corp 1.27 

St. Louis City 1055 Goodwin Printing Co -St Louis 

St. Louis City 1077 Mid-West Industrial Chemical - 

St. Louis City 1093 Brenntag Mid-South Inc 0.00 

St. Louis City 1123 U S Ringbinder Corp-Loose Leaf Metals 

St. Louis City 1280 St Louis Post Dispatch 0.44 

St. Louis City 1370 National Geospatial-Intelligence Agency 1.38 

St. Louis City 1396 Sigma - Aldrich Co-Sigma Chemical Company 4.92 

St. Louis City 1407 Southern Metal Processing 2.17 

St. Louis City 1423 Ashland Distribution Company-St Louis Plant 

St. Louis City 1460 Allied Health Care Products - 

St. Louis City 1505 Energy Center (The)-St Louis Univ Health Sciences Center 9.43 

St. Louis City 1519 Permacel St Louis Inc-Permacel St Louis Inc 2.30 

St. Louis City 1556 Connector Castings 0.00 

St. Louis City 1642 J S Alberici Construction - 

St. Louis City 2300 Superior Solvent & Chemical-St Louis 

St. Louis City 2378 Laclede Tower Associates Llc-Laclede Gas Building 320.75 

St. Louis City 2433 New World Pasta- Marceau Facility-New World Pasta 4.59 

St. Louis City 2545 Southwestern Bell Telephone Company 6.68 

St. Louis City 2711 St Louis University-Facilities Svcs 9.70 

St. Louis City 2833 WASHINGTON UNIVERSITY-HILLTOP CAMPUS 1.06 

St. Louis City Total 1,319.83 

St. Louis County and St. Louis City Combined 6,314.92 
Page 19 

Table 5 Statewide Point Source Emissions by Category (tons per year) 

Category Description

Number of

Facilities

CO

Emissions

Fossil Fuel Electric Power Generation 76 22,142

Primary Smelting and Refining of Nonferrous Metal (except Copper and 

Aluminum) 2 23

Cement Manufacturing 6 11,122

Steam and Air-Conditioning Supply 3 94

Petrochemical Manufacturing 2 121

Primary Aluminum Production 1 24,771

Pesticide and Other Agricultural Chemical Manufacturing 5 173

Lime Manufacturing 2 11,843

Pipeline Transportation of Natural Gas 10 1,350

Sewage Treatment Facilities 4 931

Nitrogenous Fertilizer Manufacturing 1 

Breweries 1 146

Secondary Smelting, Refining, and Alloying of Nonferrous Metal (except 

Copper and Aluminum) 1 13,391

Lead Ore and Zinc Ore Mining 2 0

Medicinal and Botanical Manufacturing 2 3

Automobile Manufacturing 2 159

Soybean Processing 4 34

Motor Vehicle Body Manufacturing 9 16

All Other Categories 435 5,959

Statewide Total 568 92,278
Page 20 

Table 6 Statewide Point Emissions by County (tons per year) 

State County FIPS Code County Name CO Emissions 

29001 Adair 0.05 

29003 Andrew 8.66 

29007 Audrain 237.83 

29009 Barry 31.17 

29011 Barton 125.64 

29013 Bates 1.58 

29017 Bollinger 161.20 

29019 Boone 1,143.44 

29021 Buchanan 220.11 

29023 Butler 220.70 

29025 Caldwell 

29027 Callaway 51.94 

29029 Camden 1.61 

29031 Cape Girardeau 8,724.64 

29033 Carroll 4.10 

29037 Cass 109.64 

29039 Cedar 8.20 

29041 Chariton 

29047 Clay 105.47 

29049 Clinton - 

29051 Cole 112.87 

29053 Cooper 75.60 

29055 Crawford 

29061 Daviess 1.34 

29063 DeKalb 3.86 

29065 Dent 38.34 

29069 Dunklin 32.55 

29071 Franklin 2,496.24 

29073 Gasconade 1.58 

29075 Gentry - 

29077 Greene 1,828.54 

29079 Grundy 3.69 

29081 Harrison 19.60 

29083 Henry 519.94 

29087 Holt 7.54 

29091 Howell 1,034.81 

29093 Iron 13,390.58 

29095 Jackson 4,257.40 

29097 Jasper 980.35 

29099 Jefferson 1,683.83 

29101 Johnson 81.04 

29105 Laclede 38.55 

29107 Lafayette 7.84 

29109 Lawrence 21.75 

29111 Lewis 

29113 Lincoln 6.22 

29115 Linn 0.04 

29117 Livingston 1.38 
Page 21 

State County FIPS Code County Name CO Emissions 

29119 McDonald 52.65 

29121 Macon 120.37 

29123 Madison 194.01 

29125 Maries 22.89 

29127 Marion 150.36 

29131 Miller 0.05 

29133 Mississippi 0.92 

29137 Monroe 0.04 

29139 Montgomery 82.34 

29143 New Madrid 25,872.19 

29145 Newton 43.28 

29147 Nodaway 380.16 

29151 Osage 78.95 

29155 Pemiscot 4.25 

29157 Perry 5.39 

29159 Pettis 418.53 

29161 Phelps 23.80 

29163 Pike 1,792.34 

29165 Platte 652.80 

29167 Polk - 

29169 Pulaski 9.45 

29171 Putnam 0.01 

29173 Ralls 84.78 

29175 Randolph 4,493.43 

29179 Reynolds - 

29183 St. Charles 900.69 

29186 Ste. Genevieve 11,853.64 

29187 St. Francois 45.81 

29189 St. Louis 4,995.08 

29195 Saline 114.08 

29201 Scott 375.52 

29203 Shannon 19.55 

29205 Shelby 82.31 

29207 Stoddard 118.32 

29209 Stone 

29213 Taney 29.80 

29215 Texas 17.62 

29217 Vernon 31.19 

29219 Warren 6.68 

29221 Washington 4.55 

29225 Webster 0.31 

29229 Wright 39.63 

29510 St. Louis city 1,319.86 

Missouri Total 92,239.10 

 
Page 22 

3.2 Nonpoint Source Emissions 

3.2.1 Procedures and Methodologies 

The nonpoint (also known as area) source categories with published methods of estimation are 

too numerous to calculate county-level inventories given current resources. The EPA, in 

conjunction with the Eastern Region Technical Advisory Committee (ERTAC), will complete 

inventory documentation and calculation for most nonpoint source categories using national 

defaults. Several categories are then improved with state-level information or with point-source 

subtraction. 

Missouri prepared inventories for 18 categories that required point source subtraction or statespecific data. These categories are listed in the Missouri Category Summary section below. 

Documentation of the calculation methodology and data sources is included in Table . 

Categories that did not require point source subtraction that were calculated by EPA are listed in 

the EPA Category Summary section. 

3.2.2 List of Source Categories and Emissions 

Table 8 includes a list of all area source categories and the 2008 emissions from each category 

for St. Louis City and St. Louis County..
Table 7 Nonpoint 2008 Emission Records for St. Louis County and City (tons per year) 

Area SCC SCC Level One SCC Level Two SCC Level Three SCC Level Fou

St. Louis County 2102001000 Stationary Source Fuel Combustion Anthracite Coal Industrial Total: All Boiler Types St. Louis County 2102002000 Stationary Source Fuel Combustion Bituminous/Subbitumin ous Coal Industrial Total: All Boiler Types St. Louis County 2102004000 Stationary Source Fuel Combustion Distillate Oil Industrial Total: Boilers and IC Engines St. Louis County 2102005000 Stationary Source Fuel Combustion Residual Oil Industrial Total: All Boiler Types St. Louis County 2102006000 Stationary Source Fuel Combustion Natural Gas Industrial Total: Boilers and IC Engines St. Louis County 2102007000 Stationary Source Fuel Combustion Liquified Petroleum Gas (LPG) Industrial Total: All Boiler Types St. Louis County 2102008000 Stationary Source Fuel Combustion Wood Industrial Total: All Boiler Types St. Louis County 2102011000 Stationary Source Fuel Combustion Kerosene Industrial Total: All Boiler Types St. Louis County 2103001000 Stationary Source Fuel Combustion Anthracite Coal Commercial/Institutional Total: All Boiler Types St. Louis County 2103002000 Stationary Source Fuel Combustion Bituminous/Subbitumin ous Coal Commercial/Institutional Total: All Boiler Types St. Louis County 2103004000 Stationary Source Fuel Combustion Distillate Oil Commercial/Institutional Total: Boilers and IC Engines St. Louis County 2103005000 Stationary Source Fuel Combustion Residual Oil Commercial/Institutional Total: All Boiler Types St. Louis County 2103006000 Stationary Source Fuel Combustion Natural Gas Commercial/Institutional Total: Boilers and IC Engines St. Louis County 2103007000 Stationary Source Fuel Combustion Liquified Petroleum Gas (LPG) Commercial/Institutional Total: All Combustor Types St. Louis County 2103008000 Stationary Source Fuel Combustion Wood Commercial/Institutional Total: All Boiler Types St. Louis County 2103011000 Stationary Source Fuel Combustion Kerosene Commercial/Institutional Total: All Combustor Types St. Louis County 2104002000 Stationary Source Fuel Combustion Bituminous/Subbitumin ous Coal Residential Total: All Combustor Types St. Louis County 2104004000 Stationary Source Fuel Combustion Distillate Oil Residential Total: All Combustor Types St. Louis County 2104006000 Stationary Source Fuel Combustion Natural Gas Residential Total: All Combustor Types St. Louis County 2104007000 Stationary Source Fuel Combustion Liquified Petroleum Gas (LPG) Residential Total: All Combustor Types 
Area SCC SCC Level One SCC Level Two SCC Level Three SCC Level Fou

St. Louis County 2104008100 Stationary Source Fuel Combustion Wood Residential Fireplace: general St. Louis County 2104008210 Stationary Source Fuel Combustion Wood Residential Woodstove: fireplace inserts; non-EPSt. Louis County 2104008220 Stationary Source Fuel Combustion Wood Residential Woodstove: fireplace inserts; EPA ceSt. Louis County 2104008230 Stationary Source Fuel Combustion Wood Residential Woodstove: fireplace inserts; EPA ceSt. Louis County 2104008310 Stationary Source Fuel Combustion Wood Residential Woodstove: freestanding, non-EPA cSt. Louis County 2104008320 Stationary Source Fuel Combustion Wood Residential Woodstove: freestanding, EPA certifiSt. Louis County 2104008330 Stationary Source Fuel Combustion Wood Residential Woodstove: freestanding, EPA certifiSt. Louis County 2104008400 Stationary Source Fuel Combustion Wood Residential Woodstove: pellet-fired, general (freeSt. Louis County 2104008510 Stationary Source Fuel Combustion Wood Residential Furnace: Indoor, cordwood-fired, nonSt. Louis County 2104008610 Stationary Source Fuel Combustion Wood Residential Hydronic heater: outdoor St. Louis County 2104009000 Stationary Source Fuel Combustion Firelog Residential Total: All Combustor Types St. Louis County 2104011000 Stationary Source Fuel Combustion Kerosene Residential Total: All Heater Types St. Louis County 2302002100 Industrial Processes Commercial Cooking - Charbroiling Food and Kindred Products: SIC 20 Conveyorized Charbroiling St. Louis County 2302002200 Industrial Processes Commercial Cooking - Charbroiling Food and Kindred Products: SIC 20 Under-fired Charbroiling St. Louis County 2302003000 Industrial Processes Commercial Cooking - Frying Food and Kindred Products: SIC 20 Deep Fat Fying St. Louis County 2302003100 Industrial Processes Commercial Cooking - Frying Food and Kindred Products: SIC 20 Flat Griddle Frying St. Louis County 2302003200 Industrial Processes Commercial Cooking - Frying Food and Kindred Products: SIC 20 Clamshell Griddle Frying St. Louis County Total St. Louis City 2102001000 Stationary Source Fuel Combustion Anthracite Coal Industrial Total: All Boiler Types St. Louis City 2102002000 Stationary Source Fuel Combustion Bituminous/Subbitumin ous Coal Industrial Total: All Boiler Types 
Area SCC SCC Level One SCC Level Two SCC Level Three SCC Level Fou

St. Louis City 2102004000 Stationary Source Fuel Combustion Distillate Oil Industrial Total: Boilers and IC Engines St. Louis City 2102005000 Stationary Source Fuel Combustion Residual Oil Industrial Total: All Boiler Types St. Louis City 2102006000 Stationary Source Fuel Combustion Natural Gas Industrial Total: Boilers and IC Engines St. Louis City 2102007000 Stationary Source Fuel Combustion Liquified Petroleum Gas (LPG) Industrial Total: All Boiler Types St. Louis City 2102008000 Stationary Source Fuel Combustion Wood Industrial Total: All Boiler Types St. Louis City 2102011000 Stationary Source Fuel Combustion Kerosene Industrial Total: All Boiler Types St. Louis City 2103001000 Stationary Source Fuel Combustion Anthracite Coal Commercial/Institutional Total: All Boiler Types St. Louis City 2103002000 Stationary Source Fuel Combustion Bituminous/Subbitumin ous Coal Commercial/Institutional Total: All Boiler Types St. Louis City 2103004000 Stationary Source Fuel Combustion Distillate Oil Commercial/Institutional Total: Boilers and IC Engines St. Louis City 2103005000 Stationary Source Fuel Combustion Residual Oil Commercial/Institutional Total: All Boiler Types St. Louis City 2103006000 Stationary Source Fuel Combustion Natural Gas Commercial/Institutional Total: Boilers and IC Engines St. Louis City 2103007000 Stationary Source Fuel Combustion Liquified Petroleum Gas (LPG) Commercial/Institutional Total: All Combustor Types St. Louis City 2103008000 Stationary Source Fuel Combustion Wood Commercial/Institutional Total: All Boiler Types St. Louis City 2103011000 Stationary Source Fuel Combustion Kerosene Commercial/Institutional Total: All Combustor Types St. Louis City 2104002000 Stationary Source Fuel Combustion Bituminous/Subbitumin ous Coal Residential Total: All Combustor Types St. Louis City 2104004000 Stationary Source Fuel Combustion Distillate Oil Residential Total: All Combustor Types St. Louis City 2104006000 Stationary Source Fuel Combustion Natural Gas Residential Total: All Combustor Types St. Louis City 2104007000 Stationary Source Fuel Combustion Liquified Petroleum Gas (LPG) Residential Total: All Combustor Types St. Louis City 2104008100 Stationary Source Fuel Combustion Wood Residential Fireplace: general St. Louis City 2104008210 Stationary Source Fuel Combustion Wood Residential Woodstove: fireplace inserts; non-EP
Area SCC SCC Level One SCC Level Two SCC Level Three SCC Level Fou

St. Louis City 2104008220 Stationary Source Fuel Combustion Wood Residential Woodstove: fireplace inserts; EPA ceSt. Louis City 2104008230 Stationary Source Fuel Combustion Wood Residential Woodstove: fireplace inserts; EPA ceSt. Louis City 2104008310 Stationary Source Fuel Combustion Wood Residential Woodstove: freestanding, non-EPA cSt. Louis City 2104008320 Stationary Source Fuel Combustion Wood Residential Woodstove: freestanding, EPA certifiSt. Louis City 2104008330 Stationary Source Fuel Combustion Wood Residential Woodstove: freestanding, EPA certifiSt. Louis City 2104008400 Stationary Source Fuel Combustion Wood Residential Woodstove: pellet-fired, general (freeSt. Louis City 2104008510 Stationary Source Fuel Combustion Wood Residential Furnace: Indoor, cordwood-fired, nonSt. Louis City 2104008610 Stationary Source Fuel Combustion Wood Residential Hydronic heater: outdoor St. Louis City 2104009000 Stationary Source Fuel Combustion Firelog Residential Total: All Combustor Types St. Louis City 2104011000 Stationary Source Fuel Combustion Kerosene Residential Total: All Heater Types St. Louis City 2302002100 Industrial Processes Commercial Cooking - Charbroiling Food and Kindred Products: SIC 20 Conveyorized Charbroiling St. Louis City 2302002200 Industrial Processes Commercial Cooking - Charbroiling Food and Kindred Products: SIC 20 Under-fired Charbroiling St. Louis City 2302003000 Industrial Processes Commercial Cooking - Frying Food and Kindred Products: SIC 20 Deep Fat Fying St. Louis City 2302003100 Industrial Processes Commercial Cooking - Frying Food and Kindred Products: SIC 20 Flat Griddle Frying St. Louis City 2302003200 Industrial Processes Commercial Cooking - Frying Food and Kindred Products: SIC 20 Clamshell Griddle Frying St. Louis City Total St. Louis Nonclassifiable Maintenance Area Total 
Table 8 Nonpoint Category Overview of Methodology 

SCC Category Name

Number

of SCCs

Pollutants

Included

Point

Source

Subtraction

Category

Submitted by

Missouri ‐ 

Calculation

Method

Category

Submitted by

EPA ‐ 

Calculation

Method

Emission Fact

Source

21030* and

21020*

Industrial and

Commercial

Institutional Fuel

Combustion 16 CAP Yes

EPA/CENRAPTemplateincludingenergyintensity per

sector NAICS Huntley 2009 6

2401005000 Automobile Refinishing 1

VOC and 5

HAPS No

EPA Template ‐ 

emissionsbased on

employment

SolventDocumentatio

4

2401015000

Wood and Flat Stock

(Factory Finished

Wood) 1

VOC and 6HAPs Yes

EPA Template ‐ 

emissionsbased on

employment

SolventDocumentatio

4

2401020000 Wood Furniture 1 VOC only Yes

EPA Template ‐ 

emissionsbased on

employment

SolventDocumentatio

4

2401025000 Metal Furniture 1

VOC and 6

HAPs Yes

EPA Template ‐ 

emissionsbased on

employment

SolventDocumentatio

4
SCC Category Name

Number

of SCCs

Pollutants

Included

Point

Source

Subtraction

Category

Submitted by

Missouri ‐ 

Calculation

Method

Category

Submitted by

EPA ‐ 

Calculation

Method

Emission Fact

Source

2401030000 Paper Film Foil 1

VOC and 6

HAPs Yes

EPA Template ‐ 

emissionsbased on

employment

SolventDocumentatio

4

2401040000 Metal Cans 1

VOC and 6

HAPs Yes

EPA Template ‐ 

emissionsbased on

employment

SolventDocumentatio

4

2401045000 Metal Coil Only 1

VOC and 6

HAPs No

EPA Template ‐ 

emissionsbased on

employment

SolventDocumentatio

4

2401050000

Metal Sheet Strip and

Coil 1

VOC and 6

HAPs Yes

EPA Template ‐ 

emissionsbased on

employment,HAPs notincluded in

template werecreated byMODNR

SolventDocumentatio

4
SCC Category Name

Number

of SCCs

Pollutants

Included

Point

Source

Subtraction

Category

Submitted by

Missouri ‐ 

Calculation

Method

Category

Submitted by

EPA ‐ 

Calculation

Method

Emission Fact

Source

2401055000

Machinery and

Equipment 1

VOC and 6

HAPs Yes

EPA Template ‐ 

emissionsbased on

employment

SolventDocumentatio

4

2401060000 Appliances 1

VOC and 6

HAPs No

EPA Template ‐ 

emissionsbased on

employment

SolventDocumentatio

4

2401065000

Electronic and other

special coatings 1

VOC and 6

HAPs Yes

EPA Template ‐ 

emissionsbased on

employment

SolventDocumentatio

4

2401070000 Motor Vehicles 1

VOC and 6

HAPs Yes

EPA Template ‐ 

emissionsbased on

employment,HAPs notincluded in

template werecreated byMODNR

SolventDocumentatio

4
SCC Category Name

Number

of SCCs

Pollutants

Included

Point

Source

Subtraction

Category

Submitted by

Missouri ‐ 

Calculation

Method

Category

Submitted by

EPA ‐ 

Calculation

Method

Emission Fact

Source

2401075000 Aircraft 1

VOC and 6HAPs Yes

EPA Template ‐ 

emissionsbased on

employment,HAPs notincluded in

template werecreated by

MODNR

SolventDocumentatio

4

2401085000 Railroads 1

VOC and 6HAPs Yes

EPA Template ‐ 

emissionsbased on

employment

Solvent

Documentatio

4

2401080000 Marine Coatings 1

VOC and 6

HAPs Yes

EPA Template ‐ 

emissionsbased on

employment,HAPs notincluded in

template werecreated by

MODNR

SolventDocumentatio

4
SCC Category Name

Number

of SCCs

Pollutants

Included

Point

Source

Subtraction

Category

Submitted by

Missouri ‐ 

Calculation

Method

Category

Submitted by

EPA ‐ 

Calculation

Method

Emission Fact

Source

2401090000 Misc Manufacturing 1

VOC and 6

HAPs Yes

EPA Template ‐ 

emissionsbased on

employment,HAPs notincluded in

template werecreated byMODNR

SolventDocumentatio

4

2415000000 Degreasing 1

VOC and 1

HAP Yes

EPA Template ‐ 

emissionsbased on

employment

SolventDocumentatio

4

2420000000 Dry Cleaning 1 VOC only No

EPA Template ‐ 

emissionsbased on

employment

SolventDocumentatio

4

2425000000 Graphic Arts 1

VOC and 5

HAPs Yes

EPA Template ‐ 

emissionsbased on

employment

SolventDocumentatio

4
SCC Category Name

Number

of SCCs

Pollutants

Included

Point

Source

Subtraction

Category

Submitted by

Missouri ‐ 

Calculation

Method

Category

Submitted by

EPA ‐ 

Calculation

Method

Emission Fact

Source

2401001000 Architectural Coatings 1

VOC and 5HAPs No

Template ‐ populationbasedemissions

SolventDocumentatio

4

2401008000 Traffic Paints 1

VOC and 4

HAPs No

Template ‐ emissionsbased on

2006 highwaymiles

SolventDocumentatio

4

2401100000

Industrial Maintenance

Coatings 1

VOC and 6HAPs No

Template ‐ populationbasedemissions

SolventDocumentatio

4

2401200000

Other Special Purpose

Coatings 1

VOC and 6

HAPs No

Template ‐ populationbasedemissions

SolventDocumentatio

4

2460100000 Personal Care Products 1

VOC and 2

HAPs No

Template ‐ populationbasedemissions

SolventDocumentatio

4
SCC Category Name

Number

of SCCs

Pollutants

Included

Point

Source

Subtraction

Category

Submitted by

Missouri ‐ 

Calculation

Method

Category

Submitted by

EPA ‐ 

Calculation

Method

Emission Fact

Source

2460200000

Cleaning Products:

household 1

VOC and 2

HAPs No

Template ‐ populationbasedemissions

SolventDocumentatio

4

2460400000

AutomotiveAftermarket 1

VOC and 2HAPs No

Template ‐ populationbasedemissions

SolventDocumentatio

4

2460500000

Coatings and Related

Products 1

VOC and 2HAPs No

Template ‐ populationbasedemissions

SolventDocumentatio

4

2460600000 Adhesives and Sealants 1

VOC and 2

HAPs No

Template ‐ populationbasedemissions

Solvent

Documentatio

4

2460800000

FIFRA RegulatedProducts 1

VOC and 2

HAPs No

Template ‐ populationbasedemissions

SolventDocumentatio

4
SCC Category Name

Number

of SCCs

Pollutants

Included

Point

Source

Subtraction

Category

Submitted by

Missouri ‐ 

Calculation

Method

Category

Submitted by

EPA ‐ 

Calculation

Method

Emission Fact

Source

2460900000 Misc Products 1

VOC and 2

HAPs No

Template ‐ populationbasedemissions

SolventDocumentatio

4

2501050120 Bulk Terminal 1

VOC and 8HAPs Yes

EPA Template ‐ 

point sourceemissionssubtracted byNAICS and

county

No emissionfactor, scaled 

1998 VOC

emission from

MACT analysis

2501055120 Bulk Plants 1

VOC and 8

HAPs Yes

EPA Template ‐ 

point sourceemissionssubtracted byNAICS and

county

From Gas

distributionMACTstandards8

2505040120 Petroleum Pipeline 1

VOC and 8HAPs No EPA Template

No emissionfactor, scaled 

1998 VOC

emission from

MACT analysis

2501060201

Gasoline Stage 1Underground Storage

Tanks 1

VOC and 8

HAPs No EPA Template EIIP 2001 9
SCC Category Name

Number

of SCCs

Pollutants

Included

Point

Source

Subtraction

Category

Submitted by

Missouri ‐ 

Calculation

Method

Category

Submitted by

EPA ‐ 

Calculation

Method

Emission Fact

Source

2505030120

Gasoline Stage 1 Trucks

in Transit 1

VOC and 8

HAPs No EPA Template EIIP 2001 9

250106005*

Gasoline Service

Station Loading

(submerg, splash, and

balanced fill) 3

VOC and 8HAPs No EPA Template

AP‐42 Section

5.211

2501060100

Gasoline Distribution:Stage II 1

VOC and 8

HAPs No EPA Template

AP‐42 Section5.211

21040*

Residential Fuel

Combustion (multiplefuel types) 16 CAPs No

EPATemplatesandResidentialWoodCombustionTool25 AP‐42 

2280002*

Mobile Sources ‐ 

Marine Vessels ‐ port

and underway

emissions 2 CAP No

2002estimatesadjusted for

2008 activity

EPA's Office of

Transportationand Air Quality

(OTAQ) CAP,

SEPA HAP

speciation13
SCC Category Name

Number

of SCCs

Pollutants

Included

Point

Source

Subtraction

Category

Submitted by

Missouri ‐ 

Calculation

Method

Category

Submitted by

EPA ‐ 

Calculation

Method

Emission Fact

Source

2294000000

and

2296000000

Paved and UnpavedRoads 2

PM10FIL/PRI,PM25FIL/PRI No

AP‐42Equation with

state or

regionalconstants

AP‐42 Section

13.2.2

230200* Commerical Cooking 5

CAP andHAP No

Template ‐ populationbasedemissions

2002 emissiondivided by

population tocreate percaptia factors

23110*

Construction Dust

(residential,industrial/commercial,roadway) 3

PM10 PRI,

PM25 PRI No

Residentialactivity by

county used,allocatenationalroadway by

employment

EPAdocumentatio

246102*

Asphalt (cutback and

emulsified) 2

CAP andHAP No

Nationalusageallocated tocounty by

paved road

VMT EIIP 2001 17

2501011*

Residential Portable

Fuel Container 5

VOC And

HAP No

Linear fit

between 2002

and 2010emissionestimates EPA18
SCC Category Name

Number

of SCCs

Pollutants

Included

Point

Source

Subtraction

Category

Submitted by

Missouri ‐ 

Calculation

Method

Category

Submitted by

EPA ‐ 

Calculation

Method

Emission Fact

Source

2501012*

Commercial Portable

Fuel Container 5

VOC andHAP No

Linear fit

between 2002

and 2010emissionestimates EPA18

2501080*

Aviation Petroleum

Product use (Stage 1

and 2) 2

VOC andHAP No

National useallocated byregions and

2008 landingand take‐off

activity

Four EPAdocuments

26100*

Waste Disposal ‐ Open

Burning 4

VOC andHAP No

Per capita

emissionsincludingcontrols

EPAdocumentatioEF based on2007 report

2630020000

Waste Disposal Public

Treatment 1

VOC andNH3 No

Calculatenationalemissions,allocate tocounties by

population EPA23,24 report

2801700* Fertilizer Application 14 NH3 No

Activity usedin CMUAmmoniaModel

CMU Ammoni

Model
SCC Category Name

Number

of SCCs

Pollutants

Included

Point

Source

Subtraction

Category

Submitted by

Missouri ‐ 

Calculation

Method

Category

Submitted by

EPA ‐ 

Calculation

Method

Emission Fact

Source

28050*

Animal Husbandry (by

animal and manure

system) 42 NH3 No

CMUAmmoniaModel

CMU AmmoniModel

1 EIA SEDS ‐ Energy Information Administration ‐ State Energy Data System http://www.eia.doe.gov/emeu/states/_seds.html2 Employment US Census Bureau County Business Patterns http://www.census.gov/epcd/cbp/download/06_data/index.html3 Population from US Census http://factfinder.census.gov4 Solvent Documentation, Table 2 and Table 35 FHWA HPMS ‐ Federal Highway Administration Highway Performance Monitoring System http://www.fhwa.dot.gov/policy/ohpi/h6Huntley, Roy 2009, Criteria Pollutant Emission Factors for ICI Combustion Area Source Categories7DOE  ‐ Department of Energy Energy Information Administration Petroleum Supply Annual 2008, Volume 1, Table 28 "Gasoline Distribution Industry (Stage 1) ‐ Background Information for Proposed Standards," EPA‐453/R94‐002a, OAQPS, Jan 1994 

Distribution Industry (Stage 1) ‐ Background Information for Promulgated Standards," EPA‐453/R94‐002b, OAQPS, Nov 1994

9 EIIP, Emission Inventory Improvement Program "Volume III: Chapter 11, Gasoline Marketing (Stage I and Stage II), Revised Final", J10 EIA Energy Information Administration Petroleum Navigator ‐ Product Supplied from

http://tonto.eia.doe.gov/dnav/pet/pet_cons_psup_dc_nus_mbblpd_a.htm

11AP‐42 Section 5.2 "Transportation and Marketing of Petroleum Liquids"12 2007 Census of Agriculture, US Department of Agriculture, http://www.agcensus.usda.gov/13 SEPA ‐ Swedish Environmental Protection Agency report 2004‐02‐02

http://westcoastcollaborative.org/files/sector‐marine/SMED%20Methodology%20for%20Calculating%20Emissions%20from%

14 Federal Highway Administration 2007 Highway Statistics http://www.fhwa.dot.gov/policyinformation/statistics/2007/.15 Annual Value of Construction http://www.census.gov/const/www/ototpage.html16 Asphalt Institute 2008 Survey http://www.asphaltinstitute.org/.17 EIIP, Emission Inventory Improvement Program Volume III – Area Sources, Chapter 17, “Asphalt Paving,” 2001
SCC Category Name

Number

of SCCs

Pollutants

Included

Point

Source

Subtraction

Category

Submitted by

Missouri ‐ 

Calculation

Method

Category

Submitted by

EPA ‐ 

Calculation

Method

Emission Fact

Source

18 EPA Document Estimating Emissions from Portable Fuel Containers (PFCs) http://www.epa.gov/otaq/regs/toxics/420r07001.pdf19 EIA 2008 Petroleum Annual Supply,

http://www.eia.doe.gov/oil_gas/petroleum/data_publications/petroleum_supply_annual/psa_volume1/psa_volume1.html

20 EPA Municipal Solid Waste in the United States: 2007 Facts and Figures, EPA530‐R‐08‐010,

http://www.epa.gov/epawaste/nonhaz/municipal/pubs/msw07‐rpt.pdf

21Assn of American Plant Food Control Officials with The Fertilizer Institute, Commercial Fertilizers 2002 and Commercial Fertilizers 2

http://www.aapfco.org/aapfcopubs.html

22 Biosolids Generation, Use, and Disposal in the United States, Table A‐8 EPA530‐R‐99‐009, September 199923 EPA EIIP Emission Inventory Improvement Program, April 2004, Estimating Ammonia Emissions from Anthropogenic Nonagricultu

Final Report

24 VOC Emissions from Wastewater Treatment Plants: Characterization, Control, and Compliance, Lewis Publishers, 2003, p. 26125 Residential Wood Combustion Tool, http://www.epa.gov/ttn/chief/net/2008inventory.html
Page 40 

3.2.3 Source Category Documentation 

The following documentation covers nonpoint categories that were prepared with guidance from 

EPA and CENRAP. The documentation files include methodologies to be applied nationally, 

and include Missouri-specific updates and information. 

3.2.3.1 Fossil Fuel Combustion – Residential – Coal Combustion 

a. Source Category Description 

Residential Coal Combustion is coal that is burned to heat residential housing. 

The general approach to calculating emissions for these two SCCs is to take State Coal 

Consumption from the EIA and allocate it to the county level using methods described below. 

County-level coal consumption is multiplied by the emission factors to calculate emissions. 

For this source category, the following SCCs were assigned: 

SCC Descriptor 1 Descriptor 3 Descriptor 6 Descriptor 8 

2104001000 Stationary Source 

Fuel Combustion 

Residential Anthracite Coal All Boiler Types 

2104002000 Stationary Source 

Fuel Combustion 

Residential Bituminous/ 

Subbituminous Coal 

All Boiler Types 

b. Activity Data 

The mass of coal consumed by residential combustion in the U.S. was used to estimate 

emissions. Coal consumption by energy use sector is presented in State Energy Data 2006 

Consumption tables published by the Energy Information Administration (EIA).1 Year 2006 

consumption data were used as a surrogate for 2008 emissions because year 2006 data were the 

latest data available when this inventory was prepared. 

EIA data do not distinguish between anthracite and bituminous coal consumption estimates. The 

EIA table “Domestic Distribution of U.S. Coal by Destination State, Consumer, Origin and 

Method of Transportation,” provides state-level residential coal distribution data for 2006 that 

was used to estimate anthracite and bituminous coal consumption. The amount of anthracite 

distributed to each state and the total coal delivered to each state were used to estimate the 

proportion of anthracite and bituminous coal consumption.2

 The 2006 ratio of anthracite (and 

bituminous) coal consumption to total coal consumption was used to distribute the EIA’s total 

residential sector coal consumption data by coal type. Table 1 presents the 2006 anthracite and 

bituminous coal ratios for each state. 

State-level coal consumption was allocated to each county using the US Census Bureau’s 2000 

Census Detailed Housing Information.3 These data include the number of housing units using a 

specific type of fuel for residential heating. State coal consumption was allocated to each county 

using the ratio of the number of houses burning coal in each county to the total number of houses 

burning coal in the State. 
Page 41 

c. Control Factors 

No controls were assumed for this category 

d. Emission Factors 

CO emissions were calculated by multiplying the total coal consumed in each county per year by 

an emission factor. The emission factor is from AP-42.5

 Table 2 presents the CO emission 

factors for residential anthracite coal combustion (SCC 2104001000) and residential bituminous 

coal combustion (SCC 2104002000). 

e. Sample Calculations 

Annual emissions are calculated for each county using emission factors and activity as: 

 Ex,p = FCx × (1 - CEx,p) × EFx,p

where: 

 Ex,p = annual emissions for fuel type x and pollutant p (ton/year), 

 FCx = annual fuel consumption for fuel type x, 

 CEx,p = control efficiency for fuel type x and pollutant p, and 

EFx,p = emission factor for fuel type x and pollutant p. 

County level fuel consumption is calculated using: 

FCx = AState x RatioAnth, Bit x RatioCounty houses

where: 

 AState = total tons of coal reported by the EIA, 

 RatioAnth, Bit = ratio reported in Table 1, and 

 RatioCounty houses = county allocation ratio based on number of houses burning coal. 

Example: 

Using Allegheny County, PA as an example: 

The State of Pennsylvania had a reported use of 49,935 tons of coal in the residential sector in 

2006. 

Statewide Anthracite coal use is calculated using the ratio of Anthracite to Bituminous in Table 1 

for PA: 80.64%. Allegheny County, PA had 183 houses out of the state total of 67,986 that use 

coal as the primary heating fuel. This equates to a share of 0.27% of the coal used for residential 

heating in the state. 

The emission factor for PM2.5-PRI (See Table 4) is 0.6 × state-specific % ash content + 0.08 

lbs/ton× state-specific % ash content. The ash content is 13.38%, (See Table 2) so the emission 

factor is 9.09 lbs/ton. 
Page 42 

FCAllegheny, anth = 49,935 × 0.8064 × 0.0027 = 109 tons anthracite coal 

EmisAllegheny, anth, PM2.5-PRI = 109 tons Coal × 9.09 lbs PM2.5-PRI per ton coal 

 = 990 lbs PM2.5-PRI 

f. References 

1. U.S. Department of Energy, Energy Information Administration (EIA). State Energy 

Data 2006 Consumption. Washington, DC 2008. Internet Address: 

http://www.eia.doe.gov/emeu/states/sep_use/total/csv/use_all_phy.csv accessed 

November 2008. 

2. EIA, 2008. U.S. Department of Energy, Energy Information Administration, “Domestic 

Distribution of U.S. Coal by Destination State, Consumer, Origin and Method of 

Transportation”, 2006. Available from: 

http://www.eia.doe.gov/cneaf/coal/page/coaldistrib/coal_distributions.html, accessed 

December 2008. 

3. U.S. Census Bureau. "Table H40. House Heating Fuel Type", Census 2000: Summary 

File 3. Internet address: 

http://factfinder.census.gov/servlet/DatasetMainPageServlet?_program=DEC&_submenu

Id=&_lang=en&_ts=, accessed July 2009. 

4. U.S. Environmental Protection Agency. Emission Factor and Inventory Group. Final 

Summary of the Development and Results of a Methodology for Calculating Area Source 

Emissions from Residential Fuel Combustion. Prepared by Pacific Environmental 

Services, Inc. Research Triangle Park, NC. September 2002. Internet address: 

http://www.epa.gov/ttn/chief/eiip/techreport/volume03/draft1999_ 

residfuel_inven_apr2003.zip accessed November 2004. 

5. U.S. Environmental Protection Agency. Compilation of Air Pollutant Emission Factors, 

5th Edition, AP-42, Volume I: Stationary Point and Area Sources. Research Triangle 

Park, North Carolina. 1996. 

6. U.S. Environmental Protection Agency. Emission Inventory Improvement Program. 

Estimating Ammonia Emissions from Anthropogenic Sources, Draft Final Report. 

Prepared by E.H. Pechan and Associates, Inc. Research Triangle Park, NC. April 2004. 
Page 43 

Table 1. 2006 Anthracite and Bituminous Coal Distribution for the 

Residential and Commercial Sectors

State 

Ratio of 

Bituminous 

Ratio of 

Anthracite State 

Ratio of 

Bituminous 

Ratio of 

Anthracite

Alabama 1.0000 0.0000 Montana 1.0000 0.0000 

Alaska 1.0000 0.0000 Nebraska 1.0000 0.0000 

Arizona 0.8140 0.1860 Nevada 1.0000 0.0000 

Arkansas 0.8140 0.1860 

New 

Hampshire 0.0000 1.0000 

California 1.0000 0.0000 New Jersey 0.0000 1.0000 

Colorado 0.9962 0.0038 New Mexico 1.0000 0.0000 

Connecticut 0.0000 1.0000 New York 0.6000 0.4000 

Delaware 0.8140 0.1860 

North 

Carolina 1.0000 0.0000 

Dist. 

Columbia 1.0000 0.0000 North Dakota 1.0000 0.0000 

Florida 0.8140 0.1860 Ohio 0.8727 0.1273 

Georgia 1.0000 0.0000 Oklahoma 0.9167 0.0833 

Hawaii 1.0000 0.0000 Oregon 1.0000 0.0000 

Idaho 0.9792 0.0208 Pennsylvania 0.1936 0.8064 

Illinois 0.9981 0.0019 Rhode Island 0.0000 1.0000 

Indiana 0.9474 0.0526 

South 

Carolina 0.9972 0.0028 

Iowa 0.9992 0.0008 South Dakota 1.0000 0.0000 

Kansas 1.0000 0.0000 Tennessee 0.9939 0.0061 

Kentucky 0.9981 0.0019 Texas 0.8140 0.1860 

Louisiana 1.0000 0.0000 Utah 1.0000 0.0000 

Maine 0.0000 1.0000 Vermont 0.0000 1.0000 

Maryland 0.9286 0.0714 Virginia 0.9630 0.0370 

Massachusetts 0.5000 0.5000 Washington 1.0000 0.0000 

Michigan 0.6667 0.3333 West Virginia 0.9048 0.0952 

Minnesota 0.9973 0.0027 Wisconsin 0.9914 0.0086 

Mississippi 1.0000 0.0000 Wyoming 1.0000 0.0000 

Missouri 1.0000 0.0000 

Table 2. CO Emission Factor for Residential Anthracite Coal Combustion (SCC 

2104001000) and Residential Bituminous Coal Combustion (SCC 2104002000): 

Not Adjusted for Point Source Fuel Consumption

SCC

Pollutant

Code Pollutant Code Description

Factor

Numeric

Value

Factor

Unit

Numerator

Factor Unit

Denominator

2104001000 CO CARBON MONOXIDE 275 LB TON

2104002000 CO CARBON MONOXIDE 275 LB TON
Page 44 

3.2.3.2 Fossil Fuel Combustion – Residential – Distillate Oil

a. Source Category Description

Residential Distillate Oil Combustion is oil that is burned in residential housing

The general approach to calculating emissions for this SCC is to take State Distillate Oil 

Consumption from the EIA and allocate it out to the county level using methods described 

below. County-level oil consumption is multiplied by the emission factors to calculate 

emissions. 

For this source category, the following SCCs were assigned: 

SCC Descriptor 1 Descriptor 3 Descriptor 6 Descriptor 8 

2104004000 Stationary Source 

Fuel Combustion 

Residential Distillate Oil Total Boilers and 

IC Engines 

b. Activity Data 

The state-level volume of distillate oil consumed by residential combustion in the U.S. was used 

to estimate emissions. Distillate oil consumption by energy use sector is presented in State 

Energy Data 2006 Consumption tables published by the Energy Information Administration 

(EIA).1 Year 2006 consumption data were used as a surrogate for 2008 emissions because year 

2006 data were the latest data available when this inventory was prepared. 

State-level distillate oil consumption was allocated to each county using the US Census Bureau’s 

2000 Census Detailed Housing Information.2 These data include the number of housing units 

using a specific type of fuel for residential heating. State distillate oil consumption was allocated 

to each county using the ratio of the number of houses burning distillate oil in each county to the 

total number of houses burning distillate oil in the State. 

c. Control Factors 

No control measures are assumed for this category. 

d. Emission Factors 

The CO emission factor for distillate oil is from AP-42. 3 For all counties in the United States, 

the distillate oil consumed by commercial/institutional combustion is assumed to be No. 2 fuel 

oil with a heating value of 140,000 Btu per gallon. 

e. Sample Calculations 

Emissions are calculated for each county using emission factors and activity as: 

 Ex,p = FCx × EFx,p
Page 45 

where: 

 Ex,p = annual emissions for fuel type x and pollutant p 

 FCx = annual fuel consumption for fuel type x 

 EFx,p = emission factor for fuel type x and pollutant p 

And FCx = AState x (Hcounty / HState) 

where : 

 AState = State activity data from EIA 

 HCounty = number of houses in the county using distillate oil as the primary heating fuel 

 HState = number of houses in the state using distillate oil as the primary heating fuel 

Example: 

Using Allegheny County, PA as an example: 

The State of Pennsylvania had a reported use of 16,902 thousand barrels of distillate oil in the 

residential sector in 2006. Allegheny County, PA had 8,123 houses out of the state total of 

1,217,155 that use distillate oil as the primary heating fuel. This equates to a share of 0.67% of 

the distillate oil used for residential heating in the state. From Table 5, the emission factor for 

CO is 5 lb/thousand gallons. Because the emission factor is in lbs/thousand gallons, a 

conversion factor of 42 gallons per barrel is applied. 

AAlegheny = 16,902 thousand barrels × 8,123 houses / 1,217,155 houses) 

 × 42 gal / barrel 

 = 4,737.6 thousand gallons 

EmisAlegheny, CO = = 4,737.6 thousand gallons × 5 lb CO/ thousand gallons 

 = 23,688 lbs CO or 11.8 tons CO 

f. References 

1. U.S. Department of Energy, Energy Information Administration (EIA). State Energy 

Data 2006 Consumption. Washington, DC 2008. Internet Address: 

http://www.eia.doe.gov/emeu/states/sep_use/total/csv/use_all_phy.csv, accessed 

November 2008. 

2. U.S. Census Bureau. "Table H40. House Heating Fuel Type", Census 2000: Summary 

File 3. Internet address: 

http://factfinder.census.gov/servlet/DatasetMainPageServlet?_program=DEC&_submenu

Id=&_lang=en&_ts=, accessed July 2009. 

3. U.S. Environmental Protection Agency. Compilation of Air Pollutant Emission 

Factors, 5th Edition, AP-42, Volume I: Stationary Point and Area Sources. 

Research Triangle Park, North Carolina. 1996. 
Page 46 

4. U.S. Environmental Protection Agency. Emission Factor and Inventory Group. 

Final Summary of the Development and Results of a Methodology for Calculating 

Area Source Emissions from Residential Fuel Combustion. Prepared by Pacific 

Environmental Services, Inc. Research Triangle Park, NC. September 2002. 

Internet address: http://www.epa.gov/ttn/chief/eiip/techreport/volume03/draft1999_ 

residfuel_inven_apr2003.zip accessed November 2004. 

5. U.S. Environmental Protection Agency, Office of Air Quality Planning and 

Standards. “Documentation of Emissions Estimation methods for Year 2000 and 

2001 Mobile Source and Nonpoint Source Dioxin Inventories.” Prepared by E.H. 

Pechan & Associates, Inc., Durham, NC. May 2003. 

6. U.S. Environmental Protection Agency, Emission Factors and Inventory Group. 

“Documentation for the 1999 Base Year Nonpoint Area Source National Emission 

Inventory for Hazardous Air Pollutants.” Prepared by Eastern Research Group, Inc. 

Morrisville, NC. September 2002. 

7. U.S. Environmental Protection Agency. Emission Factor and Inventory Group. 

Final Summary of the Development and Results of a Methodology for Calculating 

Area Source Emissions from Residential Fuel Combustion. Prepared by Pacific 

Environmental Services, Inc. Research Triangle Park, NC. September 2002. 

Internet address: http://www.epa.gov/ttn/chief/eiip/techreport/volume03/draft1999_ 

residfuel_inven_apr2003.zip accessed November 2004. 

8. U.S. Environmental Protection Agency. Emission Factor and Inventory Group. 

Estimating Ammonia Emissions from Anthropogenic Sources, Draft Report. Prepared by 

E.H. Pechan and Associates, Inc. Research Triangle Park, NC. September 2003. 

Table 1. National Emission Factors for Residential Distillate Oil Combustion

Code Pollutant Emission 

Factor 

Emission Factor 

Numerator 

Emission Factor 

Denominator 

CO Carbon Monoxide 5 LB E3GAL 

3.2.3.3 Fossil Fuel Combustion – Residential - Kerosene 

a. Source Category Description 

Residential Kerosene Combustion is kerosene that is burned in residential housing. Common 

uses of energy associated with this sector include space heating, water heating, cooking, and 

running a wide variety of other equipment. 
Page 47 

The general approach to calculating emissions for this SCC is to take State Kerosene 

Consumption from the EIA and allocate it to the county level using methods described below. 

County-level kerosene consumption is multiplied by the emission factors to calculate emissions. 

For this source category, the following SCC was assigned: 

SCC Descriptor 1 Descriptor 3 Descriptor 6 Descriptor 8 

2104011000 Stationary Source 

Fuel Combustion 

Residential Kerosene Total: All Combustor Types

b. Activity Data 

The volume of kerosene consumed by residential combustion in the U.S. was used to estimate 

emissions. Kerosene consumption by energy use sector is presented in State Energy Data 2006 

Consumption tables published by the Energy Information Administration (EIA).1 Year 2006 

consumption data were used as a surrogate for 2008 emissions because year 2006 data were the 

latest data available when this inventory was prepared. 

State-level kerosene consumption was allocated to each county using the US Census Bureau’s 

2000 Census Detailed Housing Information.2

 These data include the number of housing units 

using a specific type of fuel for residential heating. State kerosene consumption was allocated to 

each county using the ratio of the number of houses burning kerosene in each county to the total 

number of houses burning kerosene in the State. 

c. Control Factors 

No control measures are assumed for this category. 

d. Emission Factors 

Emission factors for distillate oil were used for kerosene, but the distillate oil emission factors 

were multiplied by a factor of 135/140 to convert them for this use. This factor is based on the 

ratio of the heat content of kerosene (135,000 Btu/gallon) to the heat content of distillate oil 

(140,000 Btu/gallon).3

 The CO emission factor is from AP-42. 4 

e. Sample Calculations 

Emissions are calculated for each county using emission factors and activity as: 

 Ex,p = FCx × EFx,p

where: 

 Ex,p = annual emissions for fuel type x and pollutant p, 

 FCx = annual fuel consumption for fuel type x, 

 EFx,p = emission factor for fuel type x and pollutant p, 

And FCx = AState x (Hcounty / HState) 
Page 48 

where : 

 AState = State activity data from EIA 

 HCounty = number of houses in the county using kerosene as the primary heating fuel 

 HState = number of houses in the state using kerosene as the primary heating fuel 

Example: 

Using Allegheny County, PA as an example: 

The State of Pennsylvania had a reported use of 1,419.7 thousand barrels of kerosene in the 

residential sector in 2006. Allegheny County, PA had 8,123 houses out of the state total of 

1,217,155 that used kerosene as the primary heating fuel. This equates to a share of 0.67% of the 

kerosene used for residential heating in the state. From Table 1, CO Emission factor is 202.5 

lb/thousand barrels. 

ECO = 1,419.7 thousand barrels × (8,123 houses / 1,217,155 houses) 

× 202.5 lb/thousand barrels 

 = 1,918.6 lbs CO or 0.96 tons CO 

f. References 

1. U.S. Department of Energy, Energy Information Administration (EIA). State Energy 

Data 2006 Consumption. Washington, DC 2008. Internet address: 

http://www.eia.doe.gov/emeu/states/sep_use/total/csv/use_all_phy.csv, accessed November 

2008. 

2. U.S. Census Bureau. "Table H40. House Heating Fuel Type", Census 2000: Summary 

File 3. Internet address: 

http://factfinder.census.gov/servlet/DatasetMainPageServlet?_program=DEC&_submenuId=&_l

ang=en&_ts=, accessed July 2009. 

3. U.S. Environmental Protection Agency. Compilation of Air Pollutant Emission Factors, 

5th Edition, AP-42, Volume I: Stationary Point and Area Sources. Research Triangle Park, 

North Carolina. 1996. 

4. U.S. Environmental Protection Agency. Emission Factor and Inventory Group. Final 

Summary of the Development and Results of a Methodology for Calculating Area Source 

Emissions from Residential Fuel Combustion. Prepared by Pacific Environmental Services, Inc. 

Research Triangle Park, NC. September 2002. Internet address: 

http://www.epa.gov/ttn/chief/eiip/techreport/volume03/draft1999_ residfuel_inven_apr2003.zip 

accessed November 2004. 

5. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. 

“Documentation of Emissions Estimation methods for Year 2000 and 2001 Mobile Source and 

Nonpoint Source Dioxin Inventories.” Prepared by E.H. Pechan & Associates, Inc., Durham, 

NC. May 2003. 
Page 49 

6. U.S. Environmental Protection Agency, Emission Factors and Inventory Group. 

“Documentation for the 1999 Base Year Nonpoint Area Source National Emission Inventory for 

Hazardous Air Pollutants.” Prepared by Eastern Research Group, Inc. Morrisville, NC. 

September 2002. 

7. U.S. Environmental Protection Agency. Emission Factor and Inventory Group. Final 

Summary of the Development and Results of a Methodology for Calculating Area Source 

Emissions from Residential Fuel Combustion. Prepared by Pacific Environmental Services, Inc. 

Research Triangle Park, NC. September 2002. Internet address: 

http://www.epa.gov/ttn/chief/eiip/techreport/volume03/draft1999_ residfuel_inven_apr2003.zip, 

accessed November 2004. 

Table 1. National Emission Factors for Residential Kerosene Combustion

Pollutant

Code Pollutant Code Description

Factor

Numeric

Value

Factor

Unit

Numerator

Factor Unit

Denominator

CO CARBON MONOXIDE 202.5 LB E3BBL

3.2.3.4 Fossil Fuel Combustion – Residential – Natural Gas

a. Source Category Description 

Residential Natural Gas Combustion is natural gas that is burned to heat residential housing as 

well as in grills, hot water heaters, and dryers. 

The general approach to calculating emissions for this SCC is to take State Natural Gas 

Consumption from the EIA and allocate it to the county level using the methods described 

below. County level natural gas consumption is multiplied by the emission factors to calculate 

emissions. 

For this source category, the following SCC was assigned: 

SCC Descriptor 1 Descriptor 3 Descriptor 6 Descriptor 8 

2104006000 Stationary Source 

Fuel Combustion 

Residential Natural Gas Total: Boilers and IC 

Engines 

b. Activity Data 

The state-level volume of natural gas consumed by residential combustion in the United States 

was used to estimate emissions. Natural gas consumption by energy use sector was obtained 

from the State Energy Data 2006 Consumption tables published by the EIA.1

 Year 2006 
Page 50 

consumption data were used as a surrogate for 2008 emissions because these data were the latest 

data available when this inventory was prepared. 

State-level natural gas consumption was allocated to each county using the US Census Bureau’s 

2000 Census Detailed Housing Information.2

 These data include the number of housing units 

using a specific type of fuel for residential heating. State natural gas consumption was allocated 

to each county using the ratio of the number of houses burning natural gas in each county to the 

total number of houses burning natural gas in the State. 

c. Control Factors 

No control measures are assumed for this category. 

d. Emission Factors 

The CO emission factor for natural gas is from AP-42. 3 According to AP-42 (maximum value 

provided) 2, natural gas has a heat content of 1,050 million BTU per million cubic feet. This 

value was required to convert those emission factors originally given in units “pounds per 

million Btu” to units “pounds per million cubic feet.” Some emission factors were revised based 

on recommendations by an ERTAC advisory panel composed of state and EPA personnel. 

County-level CO emissions were calculated by multiplying the total natural gas consumed in 

each county per year by an emission factor. Table 1 provides a summary of the CO emissions 

factor for residential combustion of natural gas. 

e. Sample Calculations 

Emissions are calculated for each county using emission factors and activity as: 

 Ex,p = FCx × EFx,p

where: 

 Ex,p = annual emissions for fuel type x and pollutant p, 

 FCx = annual fuel consumption for fuel type x, 

 EFx,p = emission factor for fuel type x and pollutant p, 

And FCx = AState x (Hcounty / HState) 

where : 

 AState = State activity data from EIA 

 HCounty = number of houses in the county using natural gas as the primary heating fuel 

 HState = number of houses in the state using natural gas as the primary heating fuel 

Example: 

Using Allegheny County, PA as an example: 
Page 51 

The State of Pennsylvania had a reported use of 205,812 million cubic feet of natural gas in the 

residential sector in 2006. Allegheny County, PA had 474,292 houses out of the state total of 

2,452,941 that use natural gas as the primary heating fuel. This equates to a share of 19.34% of 

the natural gas used for residential heating in the state. From Table 1, CO emission factor is 40 

lb/million ft3

.

ECO= 205,812 million ft3

 × (474,292 houses / 2,452,941 houses) × 40 lb CO/ million ft3 

= 1,591,803 lb CO or 795.9 ton CO 

f. References 

1. U.S. Department of Energy, Energy Information Administration (EIA). State Energy 

Data 2006 Consumption. Washington, DC 2008. Internet address: 

http://www.eia.doe.gov/emeu/states/sep_use/total/csv/use_all_phy.csv, accessed November 

2008. 

2. U.S. Census Bureau. "Table H40. House Heating Fuel Type", Census 2000: Summary 

File 3. Internet address: 

http://factfinder.census.gov/servlet/DatasetMainPageServlet?_program=DEC&_submenuId=&_l

ang=en&_ts=, accessed July 2009. 

3. U.S. Environmental Protection Agency. Compilation of Air Pollutant Emission Factors, 

5th Edition, AP-42, Volume I: Stationary Point and Area Sources. Research Triangle Park, 

North Carolina. 1996. 

4. U.S. Environmental Protection Agency. Emission Inventory Improvement Program. 

Estimating Ammonia Emissions from Anthropogenic Sources, Draft Final Report. Prepared by 

E.H. Pechan and Associates, Inc. Research Triangle Park, NC. April 2004. 

5. U.S. Environmental Protection Agency, Emission Factors and Inventory Group. 

“Documentation for the 1999 Base Year Nonpoint Area Source National Emission Inventory for 

Hazardous Air Pollutants.” Prepared by Eastern Research Group, Inc. Morrisville, NC. 

September 2002. 

6. U.S. Environmental Protection Agency. Emission Factor and Inventory Group. Final 

Summary of the Development and Results of a Methodology for Calculating Area Source 

Emissions from Residential Fuel Combustion. Prepared by Pacific Environmental Services, Inc. 

Research Triangle Park, NC. September 2002. Internet address: 

http://www.epa.gov/ttn/chief/eiip/techreport/volume03/draft1999_ residfuel_inven_apr2003.zip, 

accessed November 2004. 
Page 52 

Table 1. National Criteria Pollutant and HAP Emission Factors for Residential 

Natural Gas Combustion

Pollutant

Code Pollutant Code Description

Factor

Numeric

Value

Factor Unit

Numerator

Factor Unit

Denominator

CO CARBON MONOXIDE 40 LB E6FT3

3.2.3.5 Commercial Cooking

a. Source Category Description 

Commercial Cooking emissions are for 5 source categories based on equipment type. Emissions 

estimates are for all types of meat cooked in a particular piece of equipment. Deep fat frying of 

french fries was also included. 

For this source category, the following SCCs were assigned: 

Source

Classification Code SCC Level One SCC Level Two SCC Level Three SCC Level Four

2302002100 Industrial

Processes

Food and Kindred

Products: SIC 20

Commercial Cooking ‐ 

Charbroiling

Conveyorized

Charbroiling

2302002200 Industrial

Processes

Food and Kindred

Products: SIC 20

Commercial Cooking ‐ 

Charbroiling

Under‐fired

Charbroiling

2302003000 Industrial

Processes

Food and Kindred

Products: SIC 20

Commercial Cooking ‐ 

Frying

Deep Fat Frying

2302003100 Industrial

Processes

Food and Kindred

Products: SIC 20

Commercial Cooking ‐ 

Frying

Flat Griddle Frying

2302003200 Industrial

Processes

Food and Kindred

Products: SIC 20

Commercial Cooking ‐ 

Frying

Clamshell Griddle

Frying

b. Activity Data 

Activity data was collected from the US Census Bureau’s county level population estimates for 

July 1, 2008.1

 

c. Control Factors 

No controls were assumed for this category. 

d. Emission Factors 

Emission factors were developed and reviewed by an ERTAC advisory panel composed of state 

and EPA personnel (Contact: Roy Huntley, huntley.roy@epa.gov). They were created by taking 

2002 emissions in the NEI and dividing by the 2002 population to develop per capita emission 

factors. These emission factors are listed in Table 1. 
Page 53 

e. Sample Calculations 

Emissions are calculated for each county using emission factors and activity as: 

 Ex,p = Ax × EFx,p

where: 

 Ex,p = annual emissions for category x and pollutant p; 

 Ax = population data associated with category x; 

 EFx,p = emission factor for category x and pollutant p. 

Example: 

Using conveyorized charbroiling in Allegheny County, PA as an example: 

According to the US Census Bureau, population on July 1, 2008 is 1,215,103 

The emission factor for VOC is 0.01205 lb/person 

 EVOC= 1,215,103 people × 0.01205 lb VOC/ person

 = 14,650 lb VOC or 7.3 ton VOC 

f. References 

1. DOC, 2008: U.S. Department of Commerce, Bureau of the Census, 2008 Population 

Estimates Program GCT-T1: Population Estimates, Washington, DC. 

Table 1: Commercial Cooking Emission Factors Developed by ERTAC 

SCC SCC description

Pollutant

Code

Factor

Numeric

Value

Factor Unit

Numerator

Factor Unit

Denominator

2302002100 Conveyorized Charbroiling CO 4.245E‐02 LB EACH

2302002200 Under‐fired Charbroiling CO 1.350E‐01 LB EACH

2302003000 Deep Fat Flying CO 0.000E+00 LB EACH

2302003100 Flat Griddle Frying CO 1.269E‐02 LB EACH

2302003200 Clamshell Griddle Frying CO 0.000E+00 LB EACH

3.2.3.6 Open Burning – Land Clearing Debris 

a. Source Category Description 

Open burning of land clearing debris is the purposeful burning of debris, such as trees, shrubs, 

and brush, from the clearing of land for the construction of new buildings and highways. CO 

emission estimates from open burning of land clearing debris are a function of the amount of 

material or fuel subject to burning per year. 
Page 54 

For this source category, the following SCC was assigned: 

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

2610000500 Waste Disposal, 

Treatment, and Recovery 

Open Burning All Categories Land Clearing Debris 

(use 28-10-005-000 

for Logging Debris 

Burning) 

b. Activity Data 

The amount of material burned was estimated using the county-level total number of acres 

disturbed by residential, non-residential, and road construction. County-level weighted loading 

factors were applied to the total number of construction acres to convert acres to tons of available 

fuel. 

Acres Disturbed from Residential Construction 

The US Census Bureau has 2008 data for Housing Starts - New Privately Owned Housing Units 

Started1 which provides regional level housing starts based on the groupings of 1 unit, 2-4 units, 

5 or more units. A consultation with the Census Bureau in 2002 gave a breakdown of 

approximately 1/3 of the housing starts being for 2 unit structures, and 2/3 being for 3 and 4 unit 

structures. The 2-4 unit category was divided into 2-units, and 3-4 units based on this ratio. To 

determine the number of structures for each grouping, the 1 unit category was divided by 1, the 2 

unit category was divided by 2, and the 3-4 unit category was divided by 3.5. The 5 or more unit 

category may be made up of more than one structure. New Privately Owned Housing Units 

Authorized Unadjusted Units2 gives a conversion factor to determine the ratio of structures to 

units in the 5 or more unit category. For example if a county has one 40 unit apartment building, 

the ratio would be 40/1. If there are 5 different 8 unit buildings in the same project, the ratio 

would be 40/5. Structures started by category are then calculated at a regional level. The table 

Annual Housing Units Authorized by Building Permit3

 has 2007 data at the county level to 

allocate regional housing starts to the county level. This results in county level housing starts by 

number of units. The following surface areas were assumed disturbed for each unit type: 

Table 1: Surface Acres Disturbed per Unit Type 

1-Unit 1/4 acre/structure

2-Unit 1/3 acre/structure

Apartment 1/2 acre/structure 

The 3-4 unit and 5 or more unit categories were considered to be apartments. Multiplication of 

housing starts to surface acres disturbed results in total number of acres disturbed for each unit 

category. 

Acres Disturbed from Non-Residential Construction 

Annual Value of Construction Put in Place in the U.S4 has the 2008 National Value of Nonresidential construction. The national value of non-residential construction put in place (in 

millions of dollars) was allocated to counties using county-level non-residential construction 

(NAICS Code 2362) employment data obtained from County Business Patterns5

 (CBP). Because 

some counties employment data was withheld due to privacy concerns, the following procedure 

was adopted: 
Page 55 

1. State totals for the known county level employees were subtracted from the number of 

employees reported in the state level version of CBP. This results in the total number of 

withheld employees in the state. 

2. A starting guess of the midpoint of the range code was used (so for instance in the 1-19 

employees range, a guess of 10 employees would be used) and a state total of the 

withheld counties was computed. 

3. A ratio of guessed employees (Step 2) to withheld employees (Step 1) was then used to 

adjust the county level guesses up or down so the state total of adjusted guesses should 

match state total of withheld employees (Step 1) 

In 1999 a figure of 2 acres/$106

 was developed. The Bureau of Labor Statistics Producer Price 

Index6 lists costs of the construction industry from 1999-2007. 

 2007 acres per $106

 = 1999 acres per $106 x (1999 PPI / 2007 PPI) 

 = 2 acres/$106 (132.9 / 204.3) 

 = 1.301 acres per $106 

Acres Disturbed by Road Construction 

The Federal Highway Administration has Highway Statistics, Section IV - Highway Finance, 

Table SF-12A, State Highway Agency Capital Outlay7 for 2006 which outlines spending by state 

in several different categories. For this SCC, the following columns are used: New Construction, 

Relocation, Added Capacity, Major Widening, and Minor Widening. These columns are also 

differentiated according to the following six classifications: 

1. Interstate, urban 

2. Interstate, rural 

3. Other arterial, urban 

4. Other arterial, rural 

5. Collectors, urban 

6. Collectors, rural 

The state expenditure data are then converted to new miles of road constructed using $/mile 

conversions obtained from the North Carolina Department of Transportation (NCDOT) in 2000. 

A conversion of $4 million/mile was applied to the interstate expenditures. For expenditures on 

other arterial and collectors, a conversion factor of $1.9 million/mile was applied, which 

corresponds to all other projects. 

The new miles of road constructed are used to estimate the acreage disturbed due to road 

construction. The total area disturbed in each state was calculated by converting the new miles 

of road constructed to acres using an acres disturbed/mile conversion factor for each road type as 

given in Table 2 below: 

 
Page 56 

Table 2: Spending per Mile and Acres Disturbed per Mile by Highway Type 

Road Type

Thousand 

Dollars per 

mile

Acres 

Disturbed per 

mile 

Urban Areas, Interstate 4000 15.2

Rural Areas, Interstate 4000 15.2

Urban Areas, Other Arterials 1900 15.2

Rural Areas, Other Arterials 1900 12.7

Urban Areas, Collectors 1900 9.8

Rural Areas, Collectors 1900 7.9

Residential building starts are used to allocate the state-level acres disturbed by road construction 

to the county.3

 A ratio of the number of building starts in each county to the total number of 

building starts in each state was applied to the state-level acres disturbed to estimate the total 

number of acres disturbed by road construction in each county. 

Converting Acres Disturbed to Tons of Land Clearing Debris Burned 

Version 2 of the Biogenic Emissions Land cover Database (BELD2) within EPA’s Biogenic 

Emission Inventory System (BEIS) was used to identify the acres of hardwoods, softwoods, and 

grasses in each county. Table 3 presents the average fuel loading factors by vegetation type. 

The average loading factors for slash hardwood and slash softwood were adjusted by a factor of 

1.5 to account for the mass of tree that is below the soil surface that would be subject to burning 

once the land is cleared.8 Weighted average county-level loading factors were calculated by 

multiplying the average loading factors by the percent contribution of each type of vegetation 

class to the total land area for each county. 

Table 3. Fuel Loading Factors by Vegetation Type

Vegetation Type 

Unadjusted Average Fuel Loading 

Factor (Ton/acre) 

Adjusted Average Fuel Loading 

Factor 

(Ton/acre) 

Hardwood 66 99 

Softwood 38 57 

Grass 4.5 Not Applicable 

The total acres disturbed by all construction types was calculated by summing the acres disturbed 

from residential, non-residential, and road construction. The county-level total acres disturbed 

were then multiplied by the weighted average loading factor to derive tons of land clearing 

debris in 2008. 

c. Controls 
Page 57 

Controls for land clearing debris burning are generally in the form of a ban on open burning of 

waste in a given municipality or county. Counties that were more than 80% urban were assumed 

not to practice any open burning. Therefore, CO emissions from open burning of land clearing 

debris are zero in these counties. In addition, the State of Colorado implemented a state-wide 

ban on open burning. Emissions from open burning of land clearing debris in all Colorado 

counties were assumed to be zero. 

d. Emission Factors 

Emission factors are reported in Table 4 below. The emission factor for CO was developed by 

the U.S. Environmental Protection Agency (EPA) in consultation with the Eastern Regional 

Technical Advisory Committee and based primarily on the AP-42 report.9,10

e. Emissions 

County-level CO emissions (in lb/year) were calculated by multiplying the total mass of land 

clearing debris burned per year by an emission factor. 

f. Example Calculations 

VOC emissions in Autauga County, Alabama from open burning of land clearing debris: 

Rural fraction of Autauga County population = 0.448, so no emission controls 

Acres disturbed by residential, non-residential, and road construction in Autauga County 

= 434.26 

Weighted average fuel loading factor for Autauga County = 65.48 tons/acre 

Mass of land clearing debris burned = 434.26 acres * 65.48 tons/acre = 28,437 tons 

VOC emission factor = 11.6 lbs/ton 

Factor to convert from lbs to tons = 1/2000 

VOC emissions = tons of land clearing debris burned * VOC emission factor 

VOC emissions from land clearing debris burning = 28,437 tons * 11.6 lbs/ton * 

1 ton/2000 lbs 

VOC emissions from land clearing debris burning in Autauga County in 2008 = 165 tons 

g. References 

1. U.S. Census Bureau, “New Privately Owned Housing Units Started for 2008 ( Not 

seasonally adjusted),” available at http://www.census.gov/const/startsua.pdf

2. U.S. Census Bureau, “Table 2au. New Privately Owned Housing Units Authorized 

Unadjusted Units for Regions, Divisions, and States, Annual 2007” available at 

http://www.census.gov/const/C40/Table2/tb2u2007.txt
Page 58 

3. Annual Housing Units Authorized by Building Permits CO2007A, purchased from US 

Department of Census 

4. U.S. Census Bureau, “Annual Value of Construction Put in Place,” available at 

http://www.census.gov/const/www/ototpage.html

5. U.S. Census Bureau, “County Business Patterns,” available at 

http://www.census.gov/econ/cbp/index.html

6. Bureau of Labor Statistics, Producer Price Index, Table BMNR, available at 

http://www.bls.gov/data/ 

7. Federal Highway Administration, 2006 Highway Spending, available at 

http://www.fhwa.dot.gov/policy/ohim/hs06/xls/sf12a.xls

8. Ward, D.E., C.C. Hardy, D.V. Sandberg, and T.E. Reinhardt. “Mitigation of Prescribed 

Fire Atmospheric Pollution through Increased Utilization of Hardwoods, Piled Residues, 

and Long-Needled Conifers.” Final Report. USDA Forest Service, Pacific Northwest 

Research Station, Fire and Air Resource Management. 1989. 

9. Huntley, Roy, U.S. Environmental Protection Agency, “state_comparison ERTAC 

SS_version7_3 Oct 20 2009 [electronic file],” November 5, 2009. 

10. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. 

Compilation of Air Pollutant Emission Factors, AP-42, Fifth Edition, Volume I: 

Stationary Point and Area Sources, Section 2.5 Open Burning. Research Triangle Park, 

NC. October 1992. 

11. U.S. Environmental Protection Agency, “Evaluation of Emissions from the Open 

Burning of Household Waste in Barrels, EPA-600/R-97-134a,” Control Technology 

Center. November 1997. 

12. Gullet, B.K. and T. Abderrahmne, “PCDD/F Emissions from Forest Fire Simulations,” 

Atmospheric Environment, Vol. 37, No. 6, pp. 803-813. February 2003. 

3.2.3.7 Open Burning – Residential Household Waste 

a. Source Category Description 

Open burning of residential municipal solid waste (MSW) is the purposeful burning of MSW in 

outdoor areas. Criteria air pollutant (CAP) and hazardous air pollutant (HAP) emission estimates 

for MSW burning are a function of the amount of waste burned per year. 

For this source category, the following SCC was assigned: 

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

2610030000 Waste Disposal, 

Treatment, and Recovery 

Open Burning Residential Household Waste 

(use 26-10-000-xxx 

for Yard Wastes) 
Page 59 

b. Activity Data 

The amount of household MSW burned was estimated using data from EPA’s report Municipal 

Solid Waste in the United States: 2007 Facts and Figures.

1

 The report presents the total mass of 

waste generated in the United States by type of waste for the calendar year 2007. This 

information was used to calculate a daily estimate of the per capita household waste subject to 

burning, 3.40 lbs/person/day. Non-combustible waste, such as glass and metals, was not 

considered to be waste subject to burning. Burning of yard waste is included in SCC 

2610000100 and SCC 2610000400; therefore, it is not part of residential MSW. Approximately 

25 to 32 percent of all waste that is subject to open burning is actually burned.2 A median value 

of 28 percent is assumed to be burned in all counties in the United States. 

Since open burning is generally not practiced in urban areas, only the rural population of each 

county was assumed to practice open burning. The ratio of urban to rural population was 

obtained from 2000 U.S. Census data.3

 This ratio was then multiplied by the 2008 U.S. Census 

Bureau estimate of the population in each county to obtain the county-level rural population for 

2008.4

 The county-level rural population was then multiplied by the per capita household waste 

subject to burning to determine the amount of rural household MSW generated in each county in 

2008. 

c. Controls 

Controls for residential MSW burning are generally in the form of a ban on open burning of 

waste in a given municipality or county. Counties that were more than 80% urban were assumed 

not to practice any open burning. Therefore, criteria pollutant and HAP emissions from 

residential municipal solid waste burning are zero in these counties. In addition, the State of 

Colorado implemented a state-wide ban on open burning. Emissions from open burning of 

residential waste in all Colorado counties were assumed to be zero. 

d. Emission Factors 

Emission factors are reported in Table 1 below. Emission factors for CAPs were developed by 

the U.S. Environmental Protection Agency (EPA) in consultation with the Eastern Regional 

Technical Advisory Committee and based primarily on the AP-42 report.5, 6 Emission factors for 

HAPs are from an EPA Control Technology Center report and emission factors for 17 dioxin 

congeners were obtained from an EPA dioxin report.7,8

e. Emissions 

County-level CO emissions were calculated by multiplying the total amount of residential 

municipal solid waste burned per year by an emission factor. 

 

f. Example Calculations 

VOC emissions in Autauga County, Alabama from open burning of residential MSW: 

Population of Autauga County in 2008 = 50,364 

Rural fraction of Autauga County population = 0.448 

Per capita MSW waste generated (lb/person/day) = 3.40 
Page 60 

Fraction of rural population that burns MSW = 0.28 

Number of days in a year = 365 

Factor to convert from lbs to tons = 1/2000 

2008 MSW burning activity in Autauga County = 50,364 * 0.448 * 3.40 * 0.28 * 365 * 

1/2000 

2008 leaf burning activity in Autauga County = 3,921 tons 

VOC emissions = tons of leaves burned * VOC emission factor 

VOC emission factor = 8.56 lb/ton 

VOC emissions from leaf burning in Autauga County in 2008 = 3,921 tons * 8.56 lbs/ton 

* 1 ton/2000 lbs 

VOC emissions from leaf burning in Autauga County in 2008 = 16.78 tons 

g. References 

1. U.S. Environmental Protection Agency, Municipal Solid Waste in the United States: 

2007 Facts and Figures, EPA530-R-08-010, Office of Solid Waste and Emergency 

Response. November 2008. Available at 

http://www.epa.gov/epawaste/nonhaz/municipal/pubs/msw07-rpt.pdf 

2. U.S. Environmental Protection Agency, Region V. “Emission Characteristics of Burn 

Barrels.” Prepared by Two Rivers Regional Council of Public Officials and Patrick 

Engineering, Inc. June 1994. 

3. U.S. Census Bureau, Decennial Censuses, 2000 Census: SF1, Table P2 

4. U.S. Census Bureau. Annual Estimates of the Resident Population for the United States, 

Regions, States, and Puerto Rico: April 1, 2000 to July 1, 2008 (NST-EST2008-01).

Available at http://www.census.gov/popest/states/NST-ann-est.html 

5. Huntley, Roy, U.S. Environmental Protection Agency, “state_comparison ERTAC 

SS_version7_3 Oct 20 2009 [electronic file],” November 5, 2009. 

6. United States Environmental Protection Agency, Office of Air Quality Planning and 

Standards. Compilation of Air Pollutant Emission Factors, AP-42, Fifth Edition, Volume 

I: Stationary Point and Area Sources, Section 2.5 Open Burning. Research Triangle 

Park, NC. October 1992. 

7. U.S. Environmental Protection Agency, Control Technology Center. “Evaluation of 

Emissions from the Open Burning of Household Waste in Barrels.” EPA-600/R-97-134a. 

November 1997. 

8. United States Environmental Protection Agency, Office of Research and Development. 

Exposure and Human Health Reassessment of 2,3,7,8-Tetrachlorodibenzeno-p-Dioxin 
Page 61 

(TCCD) and Related Compounds. Part I: Estimating Exposure to Dioxin-Like 

Compounds. Volume 2: Sources of Dioxin-Like Compounds in the United States. 

EPA/600/P-00/001Ab. Washington D.C. March 2001. 

Table 1. Emission Factors for Open Burning of Residential MSW (2610030000)

Pollutant Pollutant Code Emission Factor 

 (lb/ton) 

Emission Factor 

Reference 

CO CO 8.50E+01 Reference 5 

Table 2. Emission Factors for Open Burning of Land Clearing Debris (SCC 2610000500)

Pollutant Pollutant Code Emission Factor

(lb/ton) 

Emission 

Factor 

Reference 

CO CO 1.69E+02 Reference 9 

3.2.3.8 Open Burning – Yard Waste – Leaf and Brush Species 

a. Source Category Description 

Open burning of yard waste is the purposeful burning of leaf and brush species in outdoor areas. 

CO emission estimates for leaf and brush waste burning are a function of the amount of waste 

burned per year. 

For this source category, the following SCCs were assigned: 

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

2610000100 Waste Disposal, 

Treatment, and Recovery

Open Burning All Categories Yard Waste – Leaf 

Species Unspecified

2610000400 Waste Disposal, 

Treatment, and Recovery

Open Burning All Categories Yard Waste – Brush 

Species Unspecified

b. Activity Data 

The amount of leaf and brush waste burned was estimated using data from EPA’s report 

Municipal Solid Waste in the United States: 2007 Facts and Figures.1

 The report presents the 

total mass of waste generated in the United States by type of waste, including yard waste, for the 

calendar year 2007. This information was used to calculate a daily estimate of the per capita 

yard waste, 0.59 lbs/person/day. Of the total amount of yard waste generated, the yard waste 

composition was assumed to be 25 percent leaves, 25 percent brush, and 50 percent grass by 

weight.2

 

Open burning of grass clippings is not typically practiced by homeowners, and as such only 

estimates for leaf burning and brush burning were developed. Approximately 25 to 32 percent of 

all waste that is subject to open burning is actually burned.2

 A median value of 28 percent is 

assumed to be burned in all counties in the United States. 
Page 62 

The per capita estimate was then multiplied by the 2008 population in each county that is 

expected to burn waste. Since open burning is generally not practiced in urban areas, only the 

rural population of each county was assumed to practice open burning. The ratio of urban to 

rural population was obtained from 2000 U.S. Census data.3 This ratio was then multiplied by 

the 2008 U.S. Census Bureau estimate of the population in each county to obtain the countylevel rural population for 2008.4

The percentage of forested acres from Version 2 of BELD2 within BEIS was used to adjust for 

variations in vegetation. The percentage of forested acres per county (including rural forest and 

urban forest) was then determined. To better account for the native vegetation that would likely 

be occurring in the residential yards of farming States, agricultural land acreage was subtracted 

before calculating the percentage of forested acres. Table 1 presents the ranges that were used to 

make adjustments to the amount of yard waste that is assumed to be generated per county. All 

municipios in Puerto Rico and counties in the U.S. Virgin Islands, Hawaii, and Alaska were 

assumed to have greater than 50 percent forested acres. 

Table 1. Adjustment for Percentage of Forested Acres

Percent Forested Acres 

per County 

Adjustment for 

Yard Waste Generated 

< 10% 0% generated 

>= 10%, and < 50% 50% generated 

>= 50% 100% generated 

c. Controls 

Controls for yard waste burning are generally in the form of a ban on open burning of waste in a 

given municipality or county. Counties that were more than 80% urban were assumed not to 

practice any open burning. Therefore, CO emissions from residential municipal solid waste 

burning are zero in these counties. In addition, the State of Colorado implemented a state-wide 

ban on open burning. Emissions from open burning of residential waste in all Colorado counties 

were assumed to be zero. 

d. Emission Factors 

Emission factors are specific to yard waste type and are reported in Tables 2 and 3 below. 

Emission factors for CAPs were developed by the U.S. Environmental Protection Agency (EPA) 

in consultation with the Eastern Regional Technical Advisory Committee.5

 Emission factors for 

HAPs are from AP-42 and an EPA Control Technology Center report.6, 7

e. Emissions 

County-level CO emissions were calculated by multiplying the total amount of yard waste (either 

leaf or brush) burned per year by an emission factor. Emissions for leaves and residential brush 

were calculated separately, since emission factors vary by yard waste type. Tons of debris 

burned were converted to kilograms (kg) by multiplying by 907.18474. 
Page 63 

f. Example Calculations 

VOC emissions in Autauga County, Alabama from open burning of leaf waste: 

Population of Autauga County in 2008 = 50,364 

Rural fraction of Autauga County population = 0.448 

Per capita waste yard waste generated (lb/person/day) = 0.59 

Leaf fraction of waste = 0.25 

Fraction of rural population that burns yard waste = 0.28 

Adjustment factor based on % forested acres = 1 

Number of days in a year = 365 

Factor to convert from lbs to tons = 1/2000 

2008 leaf burning activity in Autauga County = 50,364 * 0.448 * 0.59 * 0.25 * 0.28 * 1 * 

365 * 1/2000 

2008 leaf burning activity in Autauga County = 170.11 tons 

VOC emissions = tons of leaves burned * VOC emission factor 

VOC emission factor = 28 lb/ton 

VOC emissions from leaf burning in Autauga County in 2008 = 170.11 tons * 28 lbs/ton 

* 1 ton/2000 lbs 

VOC emissions from leaf burning in Autauga County in 2008 = 2.38 tons 

g. References 

1. U.S. Environmental Protection Agency, Municipal Solid Waste in the United States: 2007 

Facts and Figures, EPA530-R-08-010, Office of Solid Waste and Emergency Response. 

November 2008. Available at http://www.epa.gov/epawaste/nonhaz/municipal/pubs/msw07-

rpt.pdf 

2. Two Rivers Regional Council of Public Officials and Patrick Engineering, Inc. “Emission 

Characteristics of Burn Barrels,” prepared for the U.S. Environmental Protection Agency, 

Region V. June 1994. 

3. U.S. Census Bureau, Decennial Censuses, 2000 Census: SF1, Table P2 

4. U.S. Census Bureau. Annual Estimates of the Resident Population for the United States, 

Regions, States, and Puerto Rico: April 1, 2000 to July 1, 2008 (NST-EST2008-01). Available 

at http://www.census.gov/popest/states/NST-ann-est.html 

5. Huntley, Roy, U.S. Environmental Protection Agency, “state_comparison ERTAC 

SS_version7_3 Oct 20 2009 [electronic file],” November 5, 2009. 

6. U.S. Environmental Protection Agency, Compilation of Air Pollutant Emission Factors, 

AP-42, Fifth Edition, Volume I: Stationary Point and Area Sources, Section 2.5 Open 

Burning,, Tables 2.5-5 and 2.5-6. October 1992. 
Page 64 

7. U.S. Environmental Protection Agency, Evaluation of Emissions from the Open Burning of 

Household Waste in Barrels, EPA-600/R-97-134a, Control Technology Center. November 

1997. 

8. Gullet, B.K. and T. Abderrahmne, “PCDD/F Emissions from Forest Fire Simulations,”

Atmospheric Environment, Vol. 37, No. 6, pp. 803-813. February 2003. 

Table 2. Emission Factors for Open Burning of Leaf Species (SCC 2610000100)

Pollutant Pollutant Code Emission Factor 

(lb/ton) 

Emission 

Factor 

Reference 

CO CO 112 Reference 5

Table 3. Emission Factors for Open Burning of Brush Species (SCC 2610000400)

Pollutant Pollutant Code Emission Factor 

(lb/ton) 

Emission 

Factor 

Reference

CO CO 140 Reference 5

3.2.3.9 Fuel Combustion – Industrial and Commercial/Institutional (ICI) 

The Central States Regional Planning Association (CENRAP) contracted with Pechan to provide 

an updated methodology to calculate ICI fuel combustion emissions for 2002, and make the 

methodology updatable for future inventory projects. Appendix A-5 is documentation of the ICI 

methodology and describes how it is applied to a revised 2002 inventory. 

Statewide emissions are calculated using the fuel activity and emission factors, then statewide 

point source emission contributions are subtracted, and finally the emissions are allocated to 

counties. The Energy Information Administration’s (EIA’s) State Energy Data System (SEDS) 

provides total energy consumption by sector, but the values have to be adjusted by energy not 

used for combustion and nonroad equipment use. EIA’s 2002 Manufacturing Energy 

Consumption Survey (MECS) was used to get regional sectoral energy consumption that is not 

used for combustion. A run of the NONROAD model for 2006 provided the diesel and LPG 

quantity to subtract for commercial sector nonroad equipment. Emission factors from Roy 

Huntley of the EPA, the Emission Inventory improvement Plan (EIIP), and AP-42 cover the 

various fuel types for criteria pollutants. Emissions from coal combustion require the use of 

Missouri-specific coal sulfur content from the Energy Information Administration Quarterly 

Coal Report. Statewide point source emission contributions are subtracted by compiling the 

sector’s CO emissions by Source Classification Code (SCC), which is fuel specific, backcalculating using AP-42 emission factors to a fuel throughput, and subtracting that fuel 

throughput from the statewide total. Before allocating the remaining nonpoint emissions to 

Missouri counties, an energy-intensity adjustment is done to account for the variation of energy 
Page 65 

used per employee for each industrial manufacturing NAICS code. County Business Patterns

(CBP) published annually by the US Census Bureau outlines employment by NAICS codes and 

the energy-intensity per employee by NAICS code derived from EIA’s 2002 Annual Energy 

Outlook. Emissions are then allocated to individual counties based on commercial/institutional 

employment by county and based on energy intensity and employment for the industrial sector. 

Appendix A-5 outlines the activity data used, emission factors, and the calculation template 

spreadsheets for the categories below. 

SCC SCC Description 

2102001000 

Stationary Source Fuel Combustion; Industrial; Anthracite Coal; Total: All Boiler 

Types 

2102002000 

Stationary Source Fuel Combustion; Industrial; Bituminous/Subbituminous Coal; 

Total: All Boiler Types 

2102004000 

Stationary Source Fuel Combustion; Industrial; Distillate Oil; Total: Boilers and IC 

Engines 

2102005000 

Stationary Source Fuel Combustion; Industrial; Residual Oil; Total: All Boiler 

Types 

2102006000 

Stationary Source Fuel Combustion; Industrial; Natural Gas; Total: Boilers and IC 

Engines 

2102007000 

Stationary Source Fuel Combustion; Industrial; Liquid Petroleum Gas; Total: All 

Boiler Types 

2102008000 Stationary Source Fuel Combustion; Industrial; Wood; Total: All Boiler Types 

2102011000 Stationary Source Fuel Combustion; Industrial; Kerosene; Total: All Boiler Types 

2103001000 

Stationary Source Fuel Combustion; Commercial/Institutional; Anthracite Coal; 

Total: All Boiler Types 

2103002000 

Stationary Source Fuel Combustion; Commercial/Institutional; 

Bituminous/Subbituminous Coal; Total: All Boiler Types 

2103004000 

Stationary Source Fuel Combustion; Commercial/Institutional; Distillate Oil; Total: 

Boilers and IC Engines 

2103005000 

Stationary Source Fuel Combustion; Commercial/Institutional; Residual Oil; Total: 

All Boiler Types 

2103006000 

Stationary Source Fuel Combustion; Commercial/Institutional; Natural Gas; Total: 

Boilers and IC Engines 

2103007000 

Stationary Source Fuel Combustion; Commercial/Institutional; Liquid Petroleum 

Gas; Total: All Combustor Types 

2103008000 

Stationary Source Fuel Combustion; Commercial/Institutional; Wood; Total: All 

Boiler Types 

2103011000 

Stationary Source Fuel Combustion; Commercial/Institutional; Kerosene; Total: All 

Combustor Types 

 
Page 66 

3.2.3.10 Fossil Fuel Combustion – Residential – Liquefied Petroleum Gas (LPG)

a. Source Category Description 

Residential LPG Combustion is liquefied propane gas that is burned in residential housing. 

Common uses of energy associated with this sector include space heating, water heating, and 

cooking. 

The general approach to calculating emissions for this SCC is to take State LPG Consumption 

from the EIA and allocate it to the county level using methods described below. County level 

LPG consumption is multiplied by the emission factors to calculate emissions. 

For this source category, the following SCC was assigned: 

SCC Descriptor 1 Descriptor 3 Descriptor 6 Descriptor 8 

2104007000 Stationary Source 

 Fuel Combustion 

Residential Liquefied 

Petroleum Gas 

(LPG) 

Total: All 

Combustion Types 

b. Activity Data 

Residential liquefied petroleum gas (LPG) combustion emissions were calculated using the 

volume of LPG consumed in the United States. State-level LPG consumption by sector is 

available from the Energy Information Administration (EIA).1 Year 2006 consumption data 

were used as a surrogate for 2008 emissions because these were the latest data available when 

this inventory was prepared. 

State-level LPG consumption was allocated to each county using the US Census Bureau’s 2000 

Census Detailed Housing Information.2 These data include the number of housing units using a 

specific type of fuel for residential heating. State LPG consumption was allocated to each county 

using the ratio of the number of houses burning LPG in each county to the total number of 

houses burning LPG in the State. 

c. Control Factors 

No control measures are assumed for this category. 

d. Emission Factors 

Pollutant emission factors for residential LPG are based on the residential natural gas emission 

factors.3,4,5 For all counties in the United States, the natural gas consumed by residential 

combustion is assumed to have a heating value of 1,020 Btu per cubic foot and a sulfur content 

of 2,000 grains per million cubic feet.3 Those natural gas emission factors originally presented 

in the units “pounds per million cubic feet” were converted to energy-based units using the 1,020 

Btu/cubic foot conversion factor. Once all the natural gas emission factors were converted to 

energy-based units, the natural gas emission factors were converted to LPG emission factors by 
Page 67 

multiplying by 96,750 Btu/gallon. Some emission factors were revised based on 

recommendations by an ERTAC advisory panel composed of state and EPA personnel. 

e. Sample Calculations 

Emissions are calculated for each county using emission factors and activity as: 

 Ex,p = FCx × EFx,p

where: 

 Ex,p = annual emissions for fuel type x and pollutant p, 

 FCx = annual fuel consumption for fuel type x, 

 EFx,p = emission factor for fuel type x and pollutant p, 

And FCx = AState x (Hcounty / HState) 

where : 

 AState = State activity data from EIA 

 HCounty = number of houses in the county using LPG as the primary heating fuel 

 HState = number of houses in the state using LPG as the primary heating fuel. 

Example: 

Using Allegheny County, PA as an example: 

The State of Pennsylvania had a reported use of 4,743 thousand barrels of LPG in the residential 

sector in 2006. Allegheny County, PA had 4,317 houses out of the state total of 145,254 that use 

LPG as the primary heating fuel. This equates to a share of 2.97% of the LPG used for residential 

heating in the state. From Table 1, CO emission factor is 159.6 lb/thousand barrels. 

ECO = 4,743 thousand barrels × (4,317 houses / 145,254 houses) 

× 159.6 lb/thousand barrels 

= 22,498 lb CO or 11.25 tons CO 

f. References 

1. U.S. Department of Energy, Energy Information Administration (EIA). State Energy 

Data 2006 Consumption. Washington, DC 2008. Internet address: 

http://www.eia.doe.gov/emeu/states/sep_use/total/csv/use_all_phy.csv, accessed November 

2008. 

2. U.S. Census Bureau. "Table H40. House Heating Fuel Type", Census 2000: Summary 

File 3. Internet address: 

http://factfinder.census.gov/servlet/DatasetMainPageServlet?_program=DEC&_submenuId=&_l

ang=en&_ts=, accessed July 2009. 
Page 68 

3. U.S. Environmental Protection Agency. Compilation of Air Pollutant Emission Factors, 

5th Edition, AP-42, Volume I: Stationary Point and Area Sources. Research Triangle Park, 

North Carolina. 1996. 

4. U.S. Environmental Protection Agency, Emission Factors and Inventory Group. 

“Documentation for the 1999 Base Year Nonpoint Area Source National Emission Inventory for 

Hazardous Air Pollutants.” Prepared by Eastern Research Group, Inc. Morrisville, NC. 

September 2002. 

5. U.S. Environmental Protection Agency. Emission Factor and Inventory Group. Final 

Summary of the Development and Results of a Methodology for Calculating Area Source 

Emissions from Residential Fuel Combustion. Prepared by Pacific Environmental Services, Inc. 

Research Triangle Park, NC. September 2002. Internet address: 

http://www.epa.gov/ttn/chief/eiip/techreport/volume03/draft1999_ residfuel_inven_apr2003.zip 

accessed, November 2004. 

Table 1. National CO Emission Factor for Residential LPG Combustion

Pollutant

Code Pollutant Code Description

Factor Numeric

Value

Factor Unit

Numerator

Factor Unit

Denominator

CO CO 159.6 LB E3BBL

3.2.3.11 Fuel Combustion – Residential- Wood 

EPA created the Residential Wood Combustion tool to assist states with compiling the 2005 

NEI, and has updated the tool with new SCCs to reflect new equipment (certified/ non-certified 

inserts, outdoor hydronic heaters, wood pellet stoves), revised equipment population based on 

regional surveys and American Housing Survey (US Census) data, and wood use ratios. 

The tool is a Microsoft Access database with data input tables for appliance types and 

population, fuel inputs, burn temporal profiles, and emission factors. Missouri had no statespecific updates to input files, so the EPA defaults for Missouri were used to calculate emissions. 

A specific query is run that performs the calculation and outputs the emission table for the state 

or counties of interest. 

3.2.4 Nonpoint Source Emission Summary 

Table 9 Nonpoint CO Emissions for St. Louis City and St. Louis County (tons per year) 

County Name CO Emissions 

St. Louis County 8,752.71 

St. Louis City 3,086.57 

Totals 11,839.27 

 
Page 69 

3.3 Mobile Source Emissions 

3.3.1 Nonroad Mobile Sources 

Nonroad categories include recreational marine and land-based vehicles, farm and construction 

machinery, industrial, commercial, logging, and lawn and garden equipment, and railway 

maintenance equipment. These types of equipment are powered by compression-ignition 

engines which are typically diesel-fueled, as well as spark-ignition (gasoline-fueled) engines. 

Compressed natural gas (CNG) and liquefied petroleum gas (LPG) engines may also power 

certain types of nonroad equipment. 

3.3.1.1 Procedures and Methodologies 

For nonroad gasoline, diesel, LPG and CNG sources, EPA’s National Mobile Inventory Model 

(NMIM), incorporating the NONROAD2008 model, was used to calculate nonroad emissions. 

The annual CO emissions data generated by EPA for the 2008 off-road mobile source emissions 

for the St. Louis City and St. Louis County are summarized in Table . 

For aircraft, EPA ran the Federal Aviation Administration (FAA) Emissions and Dispersion 

Modeling System (EDMS) using Bureau of Transportation Statistics (BTS) T-100 Landing and 

Takeoff (LTO) and Terminal Area Forecast (TAF) data. The state of Missouri did not provide 

alternate emissions or input data, so EPA calculations were accepted. 

For commercial marine vehicles, EPA’s Office of Transportation and Air Quality (OTAQ) 

provided emission estimates based on grown 2002 emissions and 2008 Locomotive and Marine 

federal rule making. Again, EPA emission estimates were accepted. 

For locomotives, the Eastern Regional Technical Advisory Committee (ERTAC Rail) provided 

emission estimates based on fuel use data from the American Association of Railroads (AAR), 

Surface Transportation Board (STB) Annual Reports, and railroad provided fleet and activity 

information. These estimates were accepted by Missouri. 

EPA generates emissions data for commercial marine and locomotive sources using a method 

similar to the way emissions are generated for non-point sources. Therefore, 2008 NEI data for 

commercial marine and locomotive emissions, which are listed as nonpoint emissions in the NEI 

data, need to be added to the nonroad mobile source category. See Section 3.3.1.4 for emission 

totals. 

3.3.1.2 List of Source Categories and Emissions 

The list of source categories and emissions in St. Louis City and St. Louis County is provided in 

Appendix A-4. EPA’s NONROAD 2008a model was used to generate the nonroad emission 

summary listed in table 10. 
Page 70 

3.3.1.3 Source Category Documentation 

EPA’s NONROAD 2008a model was used to generate the nonroad emission summary listed in 

table 10; this does not include emissions from locomotive and marine engines. The methodology 

for calculating locomotive and marine engines can be found in Appendix A-3. The emissions for 

these two source categories are listed in Table 11, and the total annual nonroad CO emissions for 

St. Louis City and St. Louis County are listed in Table 12. 

3.3.1.4 Nonroad Source Emission Summary 

Table 10 St. Louis County and City 2008 Nonroad Emissions (excluding Marine,Rail,andAir Emissions) 

Area CO Emissions (tons/year) 

St. Louis County 75,892.69 

St. Louis City 14,001.59 

Totals 89,894.28 

Table 11 St. Louis County and City 2008 Marine, Rail, and Air Emissions 

Area CO Emissions (tons/year) 

St. Louis County 1,548.15 

St. Louis City 1,581.52 

Totals 3,129.67 

Table 12 St. Louis County and City Total 2008 Nonroad Mobile Source Emissions 

Area CO Emissions (tons/year) 

St. Louis County 77,440.84 

St. Louis City 15,583.11 

Totals 93,023.95 

3.3.2 Onroad Mobile Sources 

Onroad emission sources are also known as highway sources. They include vehicles used on 

roads for transportation of passengers or freight. The emissions from internal combustion 

engines in these vehicles are included in this category. 

3.3.2.1 Mobile Model Choice 

EPA released the Mobile Vehicle Emission System (MOVES) in December of 2010, and 

MOVES is now the official model to use for mobile emissions modeling. MOVES was chosen 

because it is the official model for future inventories and to ensure that grown emissions and 

budgets will be calculated consistently. 2008 mobile emissions were initially created using 

Mobile6.2 via NMIM for the St. Louis nonattainment area for the purpose of submitting state 

wide emissions data for EPA’s 2008 National Emissions Inventory (NEI). The NMIM NCD 

input data was updated with Missouri specific information. Local VMT data, vehicle registration 
Page 71 

distributions, and meteorology data from the updated NCD were converted to MOVES 

formatting using EPA provided conversion workbooks. 

MOVES is a completely redesigned model, not just an updated version of the previous Mobile 

model. The way MOVES calculates emissions has changed to reflect EPA’s more current 

understanding of the emissions produced by vehicles and the various factors that affect the 

emissions. 

3.3.2.2 Mobile Model Inputs 

Local VMT data was gathered from East-West Gateway at the county level. This data is listed in 

Table 13. 

The road type distribution in the baseyearvmt table from the NCD was used to distribute the 

county level VMT to road type. EPA’s VMT converter workbook was then used to produce 

MOVES input tables. 

An age distribution for light duty vehicles was created from a list of Vehicle Identification 

Numbers (VINs) contained in vehicle registration records from the Missouri Department of 

Revenue. The VINs were decoded into model year and MOBILE6 vehicle classes by ESP Data 

Solutions, Inc, a private contractor. A specific registration distribution was created for the five 

county Missouri portion of the St. Louis Nonattainment area. This data updated the 

BaseYearVMT Table and the CountyYear Table. The vehicle distribution was converted to 

MOVES age distribution table using EPA’s VMT converter workbook. The registration data was 

also used to create the MOVES vehicle population input tables. Vehicle counts were converted 

from Mobile 6.2 vehicle classes to MOVES source types using the source type fractions from the 

Source Type Pop Fractions table in EPA’s VMT converter workbook. The vehicle distribution is 

listed in Table 14. 

St. Louis City and St. Louis County both participate in the Gateway Vehicle Inspection Program 

(GVIP). For counties subject to Emission Inspection/Maintenance (I/M) Programs, MOVES 

allows for an I/M input table to be created. An I/M input table was created to describe the GVIP 

for St. Louis City and St. Louis County. Development of the table was in accordance with EPA 

technical guidance on appropriate input assumptions and sources of data for the use of MOVES 

2010 in State Implementation Plans (http://www.epa.gov/otaq/models/moves/420b10023.pdf). 

Documentation for the development protocol for the I/M input table can be found in Appendix 

A-6. 

MOVES base data was used for all other inputs, after reviewing the data to ensure accuracy. The 

base fuel supply tables in MOVES were used for the runs, as they already took into account the 

reformulated gasoline used in the St. Louis nonattainment area. A separate input database was 

created for each county, using county specific data where possible. The MOVES input tables, 

other than default EPA templates, are included in Table 15 through Table . 

 
Page 72 

Table 13 2008 Vehicle Miles Traveled by County 

County

FIPS

  

County_Name

VMT* in

Million Miles

County

FIPS

  

County_Name

VMT* in Million

Miles

1 Adair County 159.4784    121 Macon County 242.8909

3 Andrew County 319.5966    123 Madison County 138.1476

5 Atchison County 196.4741    125 Maries County 122.7927

7 Audrain County 240.2153    127 Marion County 354.5883

9 Barry County 356.2431    129 Mercer County 52.8821

11 Barton County 228.2903    131 Miller County 348.3599

13 Bates County 276.5227    133 Mississippi County 241.8438

15 Benton County 213.8250    135 Moniteau County 141.0637

17 Bollinger County 117.7653    137 Monroe County 91.6368

19 Boone County 1,484.7484    139 Montgomery County 381.1052

21 Buchanan County 751.9344    141 Morgan County 221.8110

23 Butler County 488.9247    143 New Madrid County 483.9027

25 Caldwell County 154.1807    145 Newton County 791.7511

27 Callaway County 913.0340    147 Nodaway County 188.0544

29 Camden County 491.0100    149 Oregon County 151.1144

31

Cape Girardeau

County 722.6664    151 Osage County 176.1925

33 Carroll County 96.9629    153 Ozark County 115.5051

35 Carter County 122.2928    155 Pemiscot County 491.2463

37 Cass County 947.9729    157 Perry County 299.3293

39 Cedar County 113.8193    159 Pettis County 406.5007

41 Chariton County 85.0137    161 Phelps County 711.2055

43 Christian County 721.9733    163 Pike County 276.9507

45 Clark County 139.0347    165 Platte County 1,363.4685

47 Clay County 2,256.7113    167 Polk County 355.0242

49 Clinton County 320.3453    169 Pulaski County 537.7921

51 Cole County 618.3292    171 Putnam County 52.0246

53 Cooper County 479.2263    173 Ralls County 202.9427

55 Crawford County 491.5010    175 Randolph County 289.3356

57 Dade County 77.8041    177 Ray County 190.6346

59 Dallas County 193.3356    179 Reynolds County 88.8169

61 Daviess County 267.3748    181 Ripley County 110.1861

63 DeKalb County 199.1815    183 St. Charles County 2,727.9563

65 Dent County 149.0151    185 St. Clair County 182.8044

67 Douglas County 127.5733    186 Ste. Genevieve County 398.6384

69 Dunklin County 317.1931    187 St. Francois County 548.1491

71 Franklin County 1,636.7261    189 St. Louis County 11,925.1835

73 Gasconade County 156.4525    195 Saline County 463.6895

75 Gentry County 58.3613    197 Schuyler County 62.0992

77 Greene County 2,404.9309    199 Scotland County 51.6444

79 Grundy County 80.0101    201 Scott County 471.9991

81 Harrison County 274.5483    203 Shannon County 119.4785

83 Henry County 310.2750    205 Shelby County 99.2628

85 Hickory County 97.5059    207 Stoddard County 363.2309

87 Holt County 259.7343    209 Stone County 312.0035

89 Howard County 99.7101    211 Sullivan County 65.6205

91 Howell County 470.7985    213 Taney County 642.9550
Page 73 

County

FIPS

  

County_Name

VMT* in

Million Miles

County

FIPS

  

County_Name

VMT* in Million

Miles

93 Iron County 126.2972    215 Texas County 322.3266

95 Jackson County 6,713.6034    217 Vernon County 345.9822

97 Jasper County 1,067.1157    219 Warren County 524.8759

99 Jefferson County 1,884.7099    221 Washington County 220.3597

101 Johnson County 499.5025    223 Wayne County 183.2741

103 Knox County 57.7446    225 Webster County 662.7641

105 Laclede County 652.5356    227 Worth County 18.6762

107 Lafayette County 692.2315    229 Wright County 278.1377

109 Lawrence County 656.1909    510 St. Louis City 3,450.4882

111 Lewis County 166.5792    

113 Lincoln County 495.2502    *From MoDOT except for Cass, Clay, Jackson, and Platte

(MARC) and Franklin, Jefferson, St. Charles, St. Louis, and St.

Louis City (East‐West Gateway)

115 Linn County 153.6966   

117 Livingston County 170.1267   

119 McDonald County 330.7242    
Page 74 

Table 14 Missouri Registration Distribution 

Vehicle 

Class 

Vehicle Model Year Population Percentage Per Vehicle Classification 

2008 2007 2006 2005 2004 2003 2002 2001 2000 1999 1998 1997 1996 

LDV 0.0248 0.0564 0.0666 0.0649 0.0653 0.0632 0.0633 0.0679 0.0675 0.0652 0.0604 0.0501 0.0488 

LDT1 0.0130 0.0345 0.0103 0.0666 0.0759 0.0255 0.0713 0.0780 0.0859 0.0487 0.0474 0.0398 0.0379 

LDT2 0.0179 0.0593 0.0700 0.0750 0.0840 0.0759 0.0728 0.0808 0.0671 0.0640 0.0563 0.0522 0.0427 

LDT3 0.0161 0.0734 0.0630 0.0760 0.0785 0.0842 0.0838 0.0728 0.0624 0.0539 0.0561 0.0365 0.0328 

LDT4 0.0153 0.0843 0.1358 0.0771 0.0953 0.1119 0.0736 0.0461 0.0564 0.0549 0.0715 0.0395 0.0342 

HDV2b 0.0078 0.0468 0.0483 0.0729 0.0660 0.0808 0.0871 0.0713 0.0773 0.0671 0.0642 0.0310 0.0519 

HDV3 0.0066 0.0628 0.0602 0.0961 0.0876 0.0681 0.0715 0.0613 0.0774 0.0669 0.0734 0.0272 0.0331 

HDV4 0.0040 0.0200 0.0638 0.0404 0.0338 0.0366 0.0385 0.0413 0.0653 0.0781 0.0821 0.0383 0.0630 

HDV5 0.0187 0.1207 0.0664 0.0804 0.0535 0.0639 0.0560 0.0450 0.0578 0.0951 0.0899 0.0465 0.0572 

HDV6 0.0311 0.0355 0.1005 0.0865 0.0529 0.0268 0.0212 0.0199 0.0840 0.0765 0.0685 0.0572 0.0591 

HDV7 0.0182 0.0324 0.1250 0.1080 0.1033 0.0772 0.0847 0.0669 0.0285 0.0427 0.0285 0.0253 0.0281 

HDV8a 0.0136 0.0110 0.0524 0.0497 0.0565 0.0513 0.0420 0.0301 0.0426 0.0791 0.0570 0.0386 0.0354 

HDV8b 0.0189 0.0726 0.2263 0.0348 0.0639 0.0957 0.0899 0.0552 0.0522 0.1363 0.0697 0.0305 0.0203 

HDBS 0.0343 0.0556 0.0925 0.0556 0.1004 0.0587 0.0623 0.0351 0.0489 0.0657 0.0669 0.0678 0.0426 

HDBT 0.0060 0.0045 0.0132 0.0144 0.0138 0.0291 0.0378 0.0258 0.0249 0.0390 0.0351 0.0309 0.0351 

MC 0.0190 0.0646 0.1035 0.1096 0.1172 0.0874 0.0922 0.0713 0.0610 0.0435 0.0360 0.0255 0.0208 

 1995 1994 1993 1992 1991 1990 1989 1988 1987 1986 1985 1984 

LDV 0.0390 0.0420 0.0313 0.0274 0.0213 0.0184 0.0138 0.0121 0.0083 0.0065 0.0049 0.0106 

LDT1 0.0443 0.0211 0.0168 0.0210 0.0189 0.0193 0.0184 0.0363 0.0582 0.0433 0.0250 0.0426 

LDT2 0.0292 0.0287 0.0266 0.0215 0.0157 0.0149 0.0096 0.0096 0.0076 0.0054 0.0042 0.0090 

LDT3 0.0322 0.0423 0.0338 0.0207 0.0181 0.0106 0.0112 0.0104 0.0070 0.0067 0.0058 0.0117 

LDT4 0.0201 0.0158 0.0145 0.0101 0.0074 0.0055 0.0052 0.0063 0.0074 0.0045 0.0014 0.0059 

HDV2b 0.0350 0.0393 0.0244 0.0196 0.0151 0.0122 0.0124 0.0154 0.0097 0.0062 0.0102 0.0280 

HDV3 0.0266 0.0340 0.0223 0.0165 0.0122 0.0126 0.0134 0.0118 0.0126 0.0096 0.0098 0.0264 

HDV4 0.0504 0.0723 0.0647 0.0308 0.0247 0.0243 0.0238 0.0270 0.0198 0.0121 0.0128 0.0321 

HDV5 0.0517 0.0217 0.0147 0.0083 0.0067 0.0110 0.0113 0.0125 0.0080 0.0012 0.0000 0.0018 

HDV6 0.0557 0.0389 0.0134 0.0152 0.0093 0.0162 0.0292 0.0196 0.0184 0.0240 0.0062 0.0342 

HDV7 0.0253 0.0321 0.0174 0.0202 0.0158 0.0166 0.0139 0.0226 0.0162 0.0178 0.0103 0.0230 

HDV8a 0.0333 0.0786 0.0447 0.0381 0.0239 0.0228 0.0291 0.0360 0.0277 0.0261 0.0163 0.0641 

HDV8b 0.0087 0.0015 0.0015 0.0029 0.0044 0.0044 0.0029 0.0044 0.0000 0.0000 0.0015 0.0015 

HDBS 0.0489 0.0327 0.0185 0.0146 0.0106 0.0095 0.0114 0.0173 0.0024 0.0035 0.0032 0.0410 

HDBT 0.0830 0.0836 0.0492 0.0441 0.0267 0.0399 0.0609 0.0333 0.0558 0.0540 0.0351 0.1248 

MC 0.0189 0.0171 0.0122 0.0119 0.0073 0.0063 0.0063 0.0064 0.0054 0.0068 0.0097 0.0401 

 
Table 15 2008 Source Type Population 

Source Type Population by County 

YearID SourceTypeName SourceTypeID St Louis County St Louis City 

2008 Motorcycle 11 19,243 31042008 Passenger Car 21 527,148 125,7762008 Passenger Truck 31 303,295.72 59,405.612008 Light Commercial Truck 32 97,845.28 20,194.392008 Refuse Truck 41 93.5 69.52008 Single Unit Short-haul Truck 42 280.5 208.52008 Single Unit Long-haul Truck 43 2,709.24 6612008 Motor Home 51 50.14 16.252008 School Bus 52 3,623.55 1,249.22008 Transit Bus 53 270.27 92.62008 Intercity Bus 54 378.69 143.452008 Combination Short-haul Truck 61 791.19 247.52008 Combination Long-haul Truck 62 544.92 160

Table 16 2008 Annual VMT by HPMS Vehicle Type, County, and Year 

HPMSBaseYearVMT by County 

HPMSVtypeID HPMSVtypeName YearID St. Louis St. Louis City 

10 Motorcycles 2008 91,989,970 26,665,06320 Passenger Cars 2008 5,115,865,231 1,477,495,62130 Other 2 axle-4 tire vehicles 2008 5,875,722,138 1,702,465,53340 Buses 2008 35,928,481 10,469,86250 Single Unit Trucks 2008 207,228,073 59,856,11960 Combination Trucks 2008 598,448,609 173,536,046
Table 17 Age Distribution by Source Type 

Source Type ID 

AgeID 11 21 31 32 41 42 43 51 52 53 

0 0.019 0.0248 0.016038 0.015215 0.006 0.006 0.03372 0.019407 0.022549 0.022677 1 0.0646 0.0564 0.059034 0.058508 0.0045 0.0045 0.054157 0.048521 0.039325 0.03937 2 0.1035 0.0666 0.063189 0.062229 0.0132 0.0132 0.092687 0.158149 0.129508 0.130555 3 0.1096 0.0649 0.073971 0.073529 0.0144 0.0144 0.057163 0.057986 0.082002 0.084645 4 0.1172 0.0653 0.081725 0.079405 0.0138 0.0138 0.098055 0.068814 0.07432 0.076743 5 0.0874 0.0632 0.072225 0.07206 0.0291 0.0291 0.05743 0.075516 0.060754 0.062113 6 0.0922 0.0633 0.075227 0.075017 0.0378 0.0378 0.060728 0.071294 0.059753 0.061551 7 0.0713 0.0679 0.075731 0.074101 0.0258 0.0258 0.034794 0.048222 0.045101 0.04668 8 0.061 0.0675 0.069095 0.069315 0.0249 0.0249 0.049567 0.050551 0.053801 0.053336 9 0.0435 0.0652 0.059343 0.060606 0.039 0.039 0.065329 0.101607 0.075238 0.074281 

10 0.036 0.0604 0.056546 0.058019 0.0351 0.0351 0.065952 0.060365 0.052757 0.052173 11 0.0255 0.0501 0.045379 0.044021 0.0309 0.0309 0.066337 0.035034 0.038694 0.038608 12 0.0208 0.0488 0.040069 0.041299 0.0351 0.0351 0.042714 0.030037 0.038252 0.038379 13 0.0189 0.039 0.031719 0.032547 0.083 0.083 0.048635 0.022609 0.033622 0.033505 14 0.0171 0.042 0.029341 0.030746 0.0836 0.0836 0.033323 0.026945 0.032499 0.031744 15 0.0122 0.0313 0.025132 0.025766 0.0492 0.0492 0.018302 0.014853 0.01522 0.015277 16 0.0119 0.0274 0.020261 0.020238 0.0441 0.0441 0.01489 0.014543 0.016624 0.016485 17 0.0073 0.0213 0.01591 0.015912 0.0267 0.0267 0.010657 0.011093 0.012019 0.01218 18 0.0063 0.0184 0.014002 0.013972 0.0399 0.0399 0.009968 0.011696 0.014667 0.014636 19 0.0063 0.0138 0.011117 0.011398 0.0609 0.0609 0.012691 0.012448 0.018417 0.017168 20 0.0064 0.0121 0.014109 0.014268 0.0333 0.0333 0.018084 0.014903 0.019136 0.018141 21 0.0054 0.0083 0.015761 0.015219 0.0558 0.0558 0.00363 0.01022 0.014831 0.014247 22 0.0068 0.0065 0.011686 0.011205 0.054 0.054 0.00501 0.010636 0.017272 0.016478 23 0.0097 0.0049 0.00791 0.008124 0.0351 0.0351 0.003627 0.006385 0.007661 0.00744 24 0.013837 0.003694 0.00582 0.006825 0.022815 0.022815 0.003017 0.003218 0.003631 0.003569 25 0.019738 0.002785 0.004029 0.004856 0.01483 0.01483 0.002668 0.001864 0.001955 0.001889 26 0.006525 0.002099 0.002201 0.002308 0.009639 0.009639 0.002379 0.001137 0.001109 0.001082 27 0 0.001582 0.001069 0.001073 0.006266 0.006266 0.00214 0.00071 0.000645 0.000647 28 0 0.00044 0.000253 0.000245 0.004073 0.004073 0.001953 0.000417 0.000378 0.000362 29 0 0 0.000147 0.000139 0.002647 0.002647 0.001784 0.00024 0.000223 0.000197 30 0 0 0.001957 0.001836 0.064531 0.064531 0.028609 0.010581 0.018036 0.013841 
Table 18 Inspection and Maintenance Data for 2008 

Pol ProcessID stateID yearID 

Source typeID 

Fuel TypeID

IM ProgramID

Inspect Freq 

Test StandardsID 

Beg Model YearID 

End Model YearID 

UI

101 29 2008 21 1 1 1 11 1971 1995 N 101 29 2008 21 1 10 2 51 1996 2006 Y 101 29 2008 31 1 1 1 11 1971 1995 N 101 29 2008 31 1 10 2 51 1996 2006 Y 101 29 2008 32 1 1 1 11 1971 1995 N 101 29 2008 32 1 10 2 51 1996 2006 Y 102 29 2008 21 1 1 1 11 1971 1995 N 102 29 2008 21 1 10 2 51 1996 2006 Y 102 29 2008 31 1 1 1 11 1971 1995 N 102 29 2008 31 1 10 2 51 1996 2006 Y 102 29 2008 32 1 1 1 11 1971 1995 N 102 29 2008 32 1 10 2 51 1996 2006 Y 112 29 2008 21 1 7 1 41 1971 1995 N 112 29 2008 21 1 8 2 43 1996 2006 Y 112 29 2008 31 1 7 1 41 1971 1995 N 112 29 2008 31 1 8 2 43 1996 2006 Y 112 29 2008 32 1 7 1 41 1971 1995 N 112 29 2008 32 1 8 2 43 1996 2006 Y 113 29 2008 21 1 7 1 41 1971 1995 N 113 29 2008 21 1 8 2 43 1996 2006 Y 113 29 2008 31 1 7 1 41 1971 1995 N 113 29 2008 31 1 8 2 43 1996 2006 Y 113 29 2008 32 1 7 1 41 1971 1995 N 113 29 2008 32 1 8 2 43 1996 2006 Y 201 29 2008 21 1 1 1 11 1971 1995 N 201 29 2008 21 1 10 2 51 1996 2006 Y 201 29 2008 31 1 1 1 11 1971 1995 N 201 29 2008 31 1 10 2 51 1996 2006 Y 201 29 2008 32 1 1 1 11 1971 1995 N 
Pol ProcessID stateID yearID 

Source typeID 

Fuel TypeID

IM ProgramID

Inspect Freq 

Test StandardsID 

Beg Model YearID 

End Model YearID 

UI

201 29 2008 32 1 10 2 51 1996 2006 Y 202 29 2008 21 1 1 1 11 1971 1995 N 202 29 2008 21 1 10 2 51 1996 2006 Y 202 29 2008 31 1 1 1 11 1971 1995 N 202 29 2008 31 1 10 2 51 1996 2006 Y 202 29 2008 32 1 1 1 11 1971 1995 N 202 29 2008 32 1 10 2 51 1996 2006 Y 301 29 2008 21 1 10 2 51 1996 2006 Y 301 29 2008 31 1 10 2 51 1996 2006 Y 301 29 2008 32 1 10 2 51 1996 2006 Y 302 29 2008 21 1 10 2 51 1996 2006 Y 302 29 2008 31 1 10 2 51 1996 2006 Y 302 29 2008 32 1 10 2 51 1996 2006 Y 

Table 19 Fuel Formulation for 2008 

Fuel FormulationID 

Fuel SubtypeID FuelSubtypeDesc RVP 

Sulfur Level 

ETOH Volume

MTBE Volume

ETBE Volume

TAME Volume

ArCo

2302 12 Gasohol (E10) 11.2917 43.0622 10 0 0 0 22303 12 Gasohol (E10) 8.75115 46.6452 10 0 0 0 12304 12 Gasohol (E10) 6.84571 49.3325 10 0 0 0 12305 12 Gasohol (E10) 13.1972 40.375 10 0 0 0 2

20043 20 Conventional Diesel 0 43 0 0 0 0 

Fuel FormulationID 

Fuel SubtypeID fuelSubtypeDesc 

Benzene Content e200 e300 

biodiesel EsterVolume cetaneIndex P

2302 12 Gasohol (E10) 0.848747 56.4983 84.16 0 0 2303 12 Gasohol (E10) 0.763743 53.3414 85.1429 0 0 2304 12 Gasohol (E10) 0.69999 50.9738 85.88 0 0 2305 12 Gasohol (E10) 0.9125 58.8659 83.4229 0 0 

20043 20 Conventional Diesel 0 0 0 0 0 
Table 20 2008 Fuel Supply 

FuelYearID Month GroupID Fuel FormulationID Market Share Market ShareCV 

2008 1 2305 1 0.52008 1 20043 1 0.52008 2 20043 1 0.52008 2 2302 1 0.52008 3 2302 1 0.52008 3 20043 1 0.52008 4 20043 1 0.52008 4 2303 1 0.52008 5 2303 1 0.52008 5 20043 1 0.52008 6 20043 1 0.52008 6 2304 1 0.52008 7 2304 1 0.52008 7 20043 1 0.52008 8 20043 1 0.52008 8 2304 1 0.52008 9 2304 1 0.52008 9 20043 1 0.52008 10 20043 1 0.52008 10 2303 1 0.52008 11 2302 1 0.52008 11 20043 1 0.52008 12 20043 1 0.52008 12 2302 1 0.5
Table 21 Average Monthly Temperatures by Hour of the Day for St. Louis County in Fahrenheit 

MonthID 

HourID 1 2 3 4 5 6 7 8 9 10 

1 25.5 28.1 39 48.2 56.2 70.2 71.8 68.8 62.4 50.7 2 24.5 26.6 37.3 46.2 55 69.1 70.6 68.1 62.5 49.8 3 23.6 25.2 36.1 45.1 53.8 68 69.9 67.2 61.6 49.1 4 22.7 24.5 35.1 44.3 52.8 67 69.6 66.5 60.9 48.4 5 21.9 23.9 34.2 43.6 52.1 66.1 68.9 65.9 60.4 47.6 6 21.4 23.4 33.1 43.3 51.6 65.6 68.4 65.3 59.9 47.1 7 21.2 23.1 32.6 43.3 53.2 67.7 69.7 65.8 59.8 46.6 8 21.2 22.7 32.9 45.7 56.5 70.9 72.5 69.4 61.9 47.9 9 22.5 24.1 36.4 48.9 59.4 73.9 75.7 72.8 65.2 52.2 

10 26.6 26.7 39.8 51.8 62.5 76.8 78.5 76.6 68.7 56.7 11 30.8 29.5 43.3 54.6 65.2 79.3 81 79.5 72.2 60.7 12 34.9 32.5 46.7 56.8 67.1 81.6 83.1 81.4 74.8 63.9 13 38.2 35 49.4 59.3 68.4 83.1 84.8 83 76.8 65.8 14 41 37.1 51.3 61 69.4 84 86.2 84.1 78.3 67.2 15 42.5 38.5 52.7 62.4 70.8 84.8 87.2 84.8 79 67.9 16 42.5 39 53 63.2 71.6 85 87.3 84.9 79 68.1 17 41.6 38.6 53 63.1 71.9 84.9 86.8 84.6 78.4 67 18 38.1 37.2 51.7 62.4 70.9 84 85.9 83.2 76.3 64.2 19 34.2 34.6 49.1 60.1 69.3 82.5 83.9 80.5 72.3 59.9 20 31.8 32.9 46.3 56.8 65.6 79.5 80.7 76.8 68.5 57.1 21 30.1 31.6 44.4 54.4 62.5 76 77.4 73.9 66.6 55.5 22 29.2 30.8 42.6 52.8 60.2 73.9 75.8 72.1 65.2 54.1 23 27.9 29.5 41.7 51 58.4 72.4 74.4 70.8 64.1 52.9 24 26.8 28.8 40 49.6 57.2 71.2 73 69.8 63.1 51.7 
Table 22 Average Monthly Percent Relative Humidity by Hour of the Day for St. Louis County 

MonthID 

HourID 1 2 3 4 5 6 7 8 9 10 

1 67.3 75.9 71.8 70 75.9 75.8 82.3 85 87.4 75.9 2 68.1 77.1 72.2 72.6 76 78.1 83.3 85.8 87.7 77.6 3 69.5 78.3 73.3 74.2 77.4 80 84.2 86.7 88.6 79.1 4 70.3 78.5 74.4 74.7 78.5 81.3 84.7 87 89.5 79.6 5 71.5 78.5 75.9 75.6 79.3 82.4 85.9 87.9 89.8 81.1 6 72 78.8 77.7 76.1 80.5 83.3 86.2 88.4 90.1 82 7 71.7 79.1 78 76.4 79.4 81.1 84.7 88.2 90.1 82.9 8 71.4 78.4 78.6 72.5 75 75.6 79.8 83.2 88.6 82.4 9 70.3 77.2 74.8 67.9 71 70 73.4 76.3 83.3 76.7 

10 66 74.2 69.9 63.7 65 64.7 67.9 68.6 76.2 67.6 11 61.4 70.5 64.6 60.2 60 60 63.2 62.8 69.1 59.4 12 56.7 67.1 59.6 57.8 57.5 55.2 59.2 58.4 63.5 53.1 13 52.8 64.6 56 54.9 56.4 52.3 56.3 55.8 59.6 49.5 14 49.8 62 53.9 53.1 55.1 51.3 54.2 53.9 57 47.2 15 47.8 59.9 52.4 51.3 53.5 49.5 52.5 52.9 55.5 45.9 16 46.8 59 52.7 49.9 52.7 48.6 52.5 52.9 55.3 45.5 17 47.2 59.7 52.9 49.6 51.4 48.6 53.2 53.9 56.8 46.6 18 50.6 61.2 54.8 50.5 51.4 49.7 54.7 56.4 61.5 51.4 19 55.1 65.1 58.5 54 53.5 52.4 58.9 62 70.6 59.1 20 58.2 68.2 62.5 58.2 59 57.9 65.8 69.8 78.6 65.1 21 60.2 70.4 65.3 61.4 64.5 64.3 72.3 76.1 82.2 68.2 22 61.9 72.1 67.7 63.6 69.2 69 75.5 80 84.2 70.4 23 63.7 73.8 69.3 66.6 72.5 71.6 77.7 82.2 85.3 72.5 24 65.2 75 71.1 68.3 74.6 74.3 80.1 83.9 86.5 74.6 
Table 23 Average Monthly Temperatures by Hour of the Day for St. Louis City in Fahrenheit 

MonthID 

HourID 1 2 3 4 5 6 7 8 9 10 

1 25.9 28.9 40.2 48.1 56 70.1 72.4 69.2 62.7 51.5 2 25 27.5 38.4 46.2 54.9 69.1 71.2 68.5 62.9 50.7 3 24 26.3 37.4 45.3 53.8 68 70.6 67.7 62.2 49.9 4 22.9 25.4 36.3 44.3 52.9 67 70.1 67 61.5 49.4 5 22.4 24.9 35.6 43.7 52.2 66.2 69.6 66.3 61 48.6 6 21.7 24.4 34.5 43.4 51.8 65.6 69.1 65.9 60.6 47.9 7 21.5 23.8 33.9 43.7 53.6 67.9 70.6 66.5 60.5 47.5 8 21.3 23.5 34.2 46 57 71.2 73.5 70.2 62.6 48.8 9 22.8 24.9 37.7 49.2 59.8 74.4 76.5 73.7 66 53.3 

10 27 27.5 41 52.1 62.9 77.4 79.2 77.5 69.5 57.8 11 31 30.3 44.3 54.8 65.6 79.9 81.6 80.3 72.9 61.8 12 35 33 47.4 57 67.7 82.1 83.6 82.3 75.4 64.8 13 38.1 35.5 50.1 59.3 68.7 83.8 85.2 83.7 77.3 66.8 14 41.1 37.4 51.8 61 69.7 84.5 86.7 84.9 78.7 68.1 15 42.7 38.8 53.3 62.4 71.1 85.3 87.6 85.5 79.4 68.8 16 42.5 39.3 53.6 63.2 71.7 85.4 87.8 85.5 79.5 68.8 17 41.6 39.1 53.4 62.9 72 85.4 87.5 85.3 78.7 67.9 18 38.1 37.7 52.2 62.1 71.2 84.4 86.4 83.8 76.8 65.1 19 34.3 35.1 49.5 60.1 69.4 82.9 84.5 81.2 72.5 60.7 20 32.1 33.4 47 56.7 65.8 79.8 81.4 77.2 68.5 57.8 21 30.4 32.2 45 54.5 62.5 76 77.9 74.3 66.8 56.2 22 29.5 31.3 43.5 52.8 60.2 73.6 76.2 72.3 65.5 54.9 23 28.3 30.1 42.6 51 58.3 72.2 74.8 71.2 64.3 53.6 24 27.2 29.6 41.1 49.5 57.1 71 73.6 70.3 63.4 52.4 
Table 24 Average Monthly Percent Relative Humidity by Hour of the Day for St. Louis City 

MonthID 

HourID 1 2 3 4 5 6 7 8 9 10 

1 68 76.6 72.6 71.4 77 76.6 83.4 85.9 87.7 76.9 2 69 78.1 73.2 73.8 76.9 78.7 84.2 86.5 87.7 78 3 69.8 79 74 74.8 78 80.8 85.4 87 88 79.7 4 70.9 79 75.2 75.9 79.1 81.9 85.6 87.6 88.9 80.3 5 72.1 78.9 76.3 76.5 79.9 82.7 86.5 88.5 89.5 81.5 6 72.4 79.2 78.4 77.4 80.5 83.9 86.8 88.5 89.8 82.7 7 72.7 79.5 79 77.1 79.4 81.7 85.1 88.2 89.5 83.3 8 72.3 79.1 79.4 73.4 75.1 75.9 80.1 83.3 88.3 83.1 9 70.9 77.9 75.6 68.3 71 70 74 76.4 83 77 

10 66.7 74.9 70.6 64.2 64.8 64.5 68.4 68.9 75.7 67.4 11 61.9 71.5 65.5 60.7 60.1 59.6 63.7 63.1 68.9 59.1 12 57.4 68.3 60.7 58.5 57.1 55.3 59.7 58.7 63.6 52.8 13 53.7 65.5 57 55.7 56.4 52 57.1 56.3 59.7 48.9 14 50.6 63.3 55.1 53.7 55.1 51.2 54.6 54.2 57 46.4 15 48.4 61.4 53.4 51.7 53.7 49.5 53.1 53.5 55.5 45.5 16 47.8 60.3 53.4 50.4 52.9 48.9 52.7 53.5 55.1 45.3 17 48 60.7 53.8 50.2 51.8 48.9 53.4 54.2 56.8 46.4 18 51.2 62.1 55.8 51.4 51.4 49.9 55.2 57.1 61.6 51.3 19 55.9 66 59.7 54.8 53.9 52.4 59.2 62.6 71.1 59.4 20 58.7 69.2 63.6 59.6 59.7 58.2 66.3 71.1 79.7 65.7 21 60.8 71.1 66.4 62.1 65.5 65 73.6 77.5 83.4 68.8 22 62.5 73.1 68.7 64.8 70 70.2 76.8 81.4 84.8 71 23 64.3 74.8 70.2 67.7 73.6 72.8 79.1 83.1 86.2 73.1 24 66.1 75.7 71.8 69.4 75.7 75.3 81 84.8 87.1 75.5 
Page 84 

3.3.2.3 On Road Source Emissions Summary 

The MOVES model runs were set up selecting all available gasoline and diesel fuel 

vehicle type combinations, all months, days, hours, and all road types. The emissions 

were post-aggregated to the year level using MOVES. 

A list of on road mobile emissions by county and SCC is included in Appendix A-2. 

Table 25 summarizes the 2008 annual on-road emissions by county as calculated using 

MOVES 2010A for St. Louis City and St. Louis County. 

Table 25 On Road Mobile 2008 CO Emissions for St. Louis City and St. Louis County 

County Name CO Emissions (tons/year) 

St. Louis County 132,855.83 

St. Louis City 34,576.81 

Totals 167,432.64 

4.0 Quality Assurance/Quality Control 

4.1 Point Source QA/QC and Results 

Prioritization 

The EI Unit prioritizes review of those facilities that have the largest bulk emissions, 

specifically facilities with a Part 70 or Intermediate operating permit. While every data 

element collected helps to characterize the emission estimate, in evaluating the data, 

those fields most directly tied to the emissions calculation are given the highest priority. 

The MoEIS database system itself was quality assured to provide smooth data transfer 

from the state inventory to the NEI. 

Methods 

The EI Unit’s general QA procedures utilize any and all of the techniques outlined in the 

EPA’s Emission Inventory Improvement Program (EIIP) Technical Report Series 

Volume 6: Quality Assurance Procedures. The unit groups these techniques into two 

basic categories: Phase I, or Bottom-Up QA procedures, and Phase II, or Top-Down QA 

procedures. Top-Down Procedures analyze groups of emissions data that share a 

common trait and look for outliers, in keeping with the ‘Reality Check’ technique. 

Bottom-Up Procedures evaluate individual EIQs that are believed to be erroneous, 

whether due to a top-down analysis, errors found when entering the EIQ into the 

database, or inconsistencies brought to the attention of the EI Unit by a third party. These 

bottom-up procedures utilize the ‘Peer Review’, the ‘Sample Calculations’, or the 

‘Independent Audit’ techniques. Note that any of these techniques could be found in 
Page 85 

either category; they have simply been mentioned in reference to the category in which 

they are most often found. 

Quality checks are completed using computerized checks in the MoEIS automated 

system, exploiting its utility in ensuring that the necessary data is reported, and in 

providing an acceptable numeric range for certain fields. It streamlines the process of 

ensuring that all data fields required for the EPA’s EIS system are present, are compatible 

with, and meet the needs of the EPA system. For example, emission release point records 

that were missing fields were corrected with the input of emission modelers and facility 

staff. Outdated Source Classification Codes (SCC), units of measure, and control device 

codes were removed, and required data fields for stack emission release points were 

added. 

Phase I reviews address individual EIQs to reconcile discrepancies with emission data. 

Phase I reviews are generally done only on hardcopy submitted EIQs, but may also be 

done based on priority. Examples of EIQ issues that were encountered include 

throughputs and emission factors with inconsistent units of measure, emission unit 

identifiers that are different from previous EIQs, and MoEIS-calculated emissions that 

differ from the emissions on the hardcopy forms. Technical staff conducting these 

reviews worked with the companies to make corrections to their EIQs and place written 

documentation of all changes in the hardcopy EIQ files stored in the fileroom. In 

addition, all changes made to EIQs are tracked in an electronic log file. 

Phase II reviews take a top-down look at the emissions data. This phase involves running 

Access queries to identify potential issues to investigate further. The Phase II QA queries 

included ensuring condensable particulate emissions were reported, ensuring correct 

application of sulfur/ash content in emission factors, and reviewing emission trends by 

facility and industry type to identify any anomalies. In addition, point source data from 

other databases incorporated by the EPA into the EIS, such as the Toxics Release 

Inventory (TRI) and the Clean Air Markets Division (CAMD), will be reviewed and 

compared to MoEIS data. Prioritization of the largest sources, largest changes, and 

largest anomalies is a top consideration, as is realizing a meaningful emission difference 

within a reasonable amount of time. Any changes made to EIQs during the Phase II QA 

process will be done with input from the companies, and written documentation of all 

changes will be placed in the EIQ files stored in the fileroom and in electronic files. 

Results 

Interannual Variability- Facilities that reported over 20 tons of chargeable emissions 

were examined to find sources with large interannual variability. A list of 20 facilities 

was generated where plantwide chargeable emissions changed by more than 20%, and 

each of these facilities were contacted to verify the source of the increase or decrease. 

Four facilities reported an emission change due to emission factor or control device 

changes, and the other 16 facilities reported throughput changes were the cause of the 

emission differences. Since the cause of the emission variability has been documented, 

there is no cause for changes to the emissions report for these twenty facilities. 
Page 86 

Local Agency QA – Four facilities in St. Louis City were selected for a detailed audit 

based on their level of emissions and variation from past year reporting. At the four 

facilities, over 20 emission units were audited to confirm throughput, appropriate 

emission factor use, appropriate control efficiency application, permitted equipment 

limits, and number of pollutants. Six emission units were found to be incorrectly 

reported in the 2008 emission report, with one facility having overreported almost 10 tons 

of PM10, and another underreported 40 tons facility-wide. Phase 1 quality assurance steps 

were used on 14 facilities in Springfield, 7 facilities in St. Louis County, and twenty 

facilities in Kansas City. Throughputs, emission factors, incorrect calculations, and HAP 

reporting were reviewed for these sites. 

Stack Parameters – In preparation for point source data submission to the NEI, the 

required data elements for stack emission release points were queried to ensure the data 

submittal could occur without errors. Of the over 2,600 stack release points associated 

with point source emission reports that are submitted to the 2008 NEI, almost 50% 

required quality assurance before they could be submitted. Three main quality assurance 

steps were taken to correct the stack data: missing data elements were filled in as 

possible, data elements that were out of range were quality assured, and previously 

submitted NEI data elements were compared to current Missouri emission report data to 

identify discrepancies. Filling in missing data elements took the most time because it 

required review of modeling files, contact with local agency staff, or contact with the 

facility. Out of range data elements were a much smaller portion of the quality 

assurance, but these were also corrected via modeling files and contact with the facility. 

Discrepancies between the EIS and 2008 Missouri EIQ data were reconciled by accepting 

the Missouri data instead of EIS data. 

4.2 Nonpoint Source QA/QC 

EI Unit staff has documented the following information for each nonpoint source 

category: source of data for activity, emission factors, allocation methodologies, nonpoint 

source SCCs covered, pollutants covered, and point source subtraction in Table . Much 

of the documentation for EPA categories appears at the NEI website: 

http://www.epa.gov/ttn/chief/net/2008inventory.html

Emission inventory staff participated in the ERTAC workgroup that developed many of 

the updated emission factors and methodologies used for 2008 emission estimates, and 

the resulting emission factors were checked against those used in EPA templates for 

accuracy. All nonpoint source categories in the 2008 NEI will be reviewed, including 

those for which EPA is developing emissions estimates. The emission estimates were 

compared to the 2005 NEI to identify outlying or missing categories. 

Quality checks of the EPA excel worksheets showed that three worksheets had incorrect 

emission factors when compared to the ERTAC summary emission factor page, and these 

were corrected before emissions were submitted. Several categories had spreadsheet 
Page 87 

templates that omitted HAP calculations, and these were amended prior to completing the 

categories. Spot checks were also done on the calculation pages to ensure formulas were 

followed, and no problems were found. 

Quality assurance of the data included checks against 2002 NEI data submissions, and 

completeness checks for the number of counties, number of pollutants, order of 

magnitude, and correct units of measure. The priority data checks showed no errors, but 

there are a few source categories included in the 2002 NEI that were not included in the 

2008 NEI due to time constraints (see section 3.2). 

4.3 Mobile Source QA/QC 

4.3.1 Nonroad Source QA/QC 

Quality control and quality assurance were conducted throughout the nonroad modeling 

process. Data collected from various data sources were verified and correctly entered or 

transcribed into the model. In some instances, input values, i.e., temperatures and fuel 

values were double and/or triple checked for accuracy to insure they corresponded to 

Missouri DNR data. In addition, a spot-checking of the modeling results, including 

rerunning the model for those results in question, was performed to ensure reliability. 

4.3.2 Onroad Source QA/QC 

The data used for the modeling was originally collected for creating the 2008 NEI. 

Missouri DNR has conducted extensive quality assurance on the model inputs and the 

inputs have been reviewed by EPA. The inputs were converted to MOVES formatting 

using EPA conversion tools. The MOVES converted data was double and/or triple 

checked to ensure accuracy. In addition, a spot-checking of the modeling results, 

including rerunning the model for those results in question, was performed to ensure 

reliability.
1 of 16 

Appendix A‐1

List of Statewide Point Source CO Emissions by Facility 
2 of 16 

This page left intentionally blank.
3 of 16 

Facility Name 

State 

County 

FIPS Code

Facility 

ID NAICS 

CO 

Emissions 

(tons/year)

Amerenue-Kirksville Combustion Turbine 29001 0006 221112 0.05 

Keller Construction Company-Keller Construction Company 29003 P011 324121 8.66 

Archer Daniels Midland Co-Mexico Plant 29007 0002 311222 19.79 

Harbison-Walker Refractories-Vandalia Plant 29007 0003 327124 20.69 

Amerenue-Mexico Combustion Turbine 29007 0012 221112 0.11 

Martinsburg Farmers Elevator-Martinsburg 29007 0033 42451 

Teva Pharmaceuticals Usa Inc-Mexico 29007 0040 325412 0.51 

VANDALIA POWER PLANT-VANDALIA 29007 0041 221112 0.08 

Cerro Copper Casting Company-Cerro Copper Casting Company 29007 0047 331525 144.61 

Mexico Plastic Company-Mexico 29007 0051 326111 0.07 

Audrain Generating Station 29007 0053 221112 10.66 

POET BIOREFINING-LADDONIA PLANT 29007 0054 325193 41.29 

Efco Corporation-Efco Corporation 29009 0003 332321 4.34 

Hydro Aluminum Wells-Monett 29009 0005 331421 14.26 

SCHREIBER FOODS INC-SCHREIBER FOODS INC - MONETT 29009 0021 311513 10.99 

Fasco Industries Inc-Cassville Plant 29009 0037 335312 1.23 

Justin Boot Company-Cassville (Plant 414) 29009 0052 316213 0.14 

ARCHITECTURAL SYSTEMS INC-MONETT 29009 0062 332321 

GEORGE'S INC-POULTRY FEED MILL 29009 0066 311119 0.21 

Lamar City Electrical Generation-Lamar 29011 0031 221112 0.20 

BFI Waste Systems Of North America Inc-Lamar Landfill & Prairie View 

Reg Waste 29011 0039 562212 125.44 

Butler Municipal Power Plant-Butler 29013 0029 221112 0.08 

CONTINENTAL COAL INC-COTTONWOOD CREEK MINE 29013 0036 212111 1.50 

Natural Gas Pipeline Company-Marble Hill Plant 29017 0019 48621 161.20 

Columbia Municipal Power Plant-Columbia 29019 0002 221112 137.00 

University Of Missouri - Columbia-Power Plant 29019 0004 221112 681.51 

Magellan Pipeline Company Llc-Columbia Station 29019 0005 48691 9.25 

A B Chance Co-Allen Street Complex 29019 0039 335313 5.05 

Christian Health Systems-Boone Hospital Center 29019 0045 62211 1.70 

University Of Missouri - Columbia-Main Campus Sources 29019 0047 62211 - 

Torque Traction Integration Technologies-Columbia 29019 0066 336211 0.35 

Panhandle Eastern Pipeline-Centralia Compressor Station 29019 0077 48621 232.05 

Columbia Sanitary Landfill-Columbia Sanitary Landfill 29019 0091 562212 76.16 

Ameren Energy Generating Company-Columbia Energy Center 29019 0105 221112 0.37 

Aquila Inc-Lake Road Plant 29021 0004 221112 165.26 

Life Line Foods-St Joseph 29021 0016 311211 22.39 

Albaugh Inc-Albaugh Inc 29021 0037 32532 

Omnium Llc-St Joseph 29021 0045 32532 - 

Weyerhaeuser-St Joseph 29021 0046 322211 4.25 

Bartlett Grain Company Lp-St Joseph 29021 0056 42451 

Ag Processing Inc-St Joseph - Lower Lake Road 29021 0060 311222 1.53 

Heartland Regional Medical Center East-St Joseph 29021 0063 62211 4.25 
4 of 16 

Facility Name 

State 

County 

FIPS Code

Facility 

ID NAICS 

CO 

Emissions 

(tons/year)

Silgan Containers Corp-Silgan Containers 29021 0064 332431 5.42 

Altec Industries Inc-Altec Industries Inc 29021 0078 33312 1.95 

Varco-Pruden Buildings-St Joseph 29021 0095 332311 - 

St Joseph Landfill-St Joseph Landfill 29021 0105 562212 15.08 

AG PROCESSING-ST. JOSEPH BIODIESEL 29021 0118 325199 

Williamsville Materials-Poplar Bluff 29023 0003 212321 

Pace Construction Co-Poplar Bluff Plant 29023 0021 324121 0.07 

John J Pershing Va Medical Center-Poplar Bluff 29023 0027 62211 1.23 

Gates Rubber Company-Poplar Bluff Division 29023 0032 32622 3.51 

Briggs & Stratton Corp-Poplar Bluff 29023 0038 333618 30.85 

Centerpoint Energy-Poplar Bluff Compressor Station 29023 0042 48621 130.90 

Poplar Bluff Municipal Utilities-Generating Plant 29023 0050 221112 3.61 

Butler County Sanitary Landfill-Allied Waste Industries 29023 0058 562212 50.51 

Nordyne-Poplar Bluff 29023 0062 333415 0.01 

Consumers Oil And Supply Company-Braymer Plant 29025 0008 42451 

Harbison-Walker Refractories-Harbison-Walker Refractories 29027 0001 327124 5.08 

Fulton Power Plant-Fulton 29027 0007 221112 1.29 

A P Green Industries Inc-Fulton Plant 29027 0010 327124 31.57 

ABB Inc-Jefferson City Plant 29027 0019 335311 4.16 

Fulton State Hospital-Fulton 29027 0021 62221 5.51 

Amerenue-Callaway Nuclear Power Plant 29027 0026 221113 4.34 

Modine Manufacturing Co-Modine Manufacturing Co 29029 0009 333415 1.61 

Delta Asphalt Inc-Cape Girardeau 29031 0002 324121 37.21 

Martin Marietta Materials-Appleton Quarry #368 29031 0008 212312 - 

Southeast Missouri State University-Facilities Management 29031 0010 61131 33.90 

Ceramo Co Inc-Jackson 29031 0012 327112 3.48 

Lone Star Industries Inc-Cape Girardeau 29031 0021 32731 8,359.89 

Procter & Gamble Paper Products Co-Neely'S Landing 29031 0053 322291 266.04 

St Francis Medical Center-Cape Girardeau 29031 0058 62211 4.24 

Jackson Municipal Utilities-Jackson Municipal Utilities 29031 0061 221112 0.12 

Biokyowa Inc-Nash Road Site 29031 0064 325411 19.76 

Nordenia U S A Inc-Neely'S Landing 29031 0072 31213 - 

Consolidated Grain And Barge Co-Cape Girardeau 29031 0081 42451 

Sinclair Oil Corp-Carrollton Station 29033 0001 48691 3.18 

Agriservices Of Brunswick Llc-Brunswick West 29033 0013 42451 - 

Carrollton Municipal Utilities 29033 0022 221112 0.71 

Ray-Carroll County Grain Growers Inc-Carrollton Facility 29033 0023 42451 0.20 

SHOW ME ETHANOL LLC-CARROLLTON 29033 0036 325193 - 

Martin Marietta-Greenwood Quarry #527 29037 0001 212312 

Martin Marietta-Peculiar Quarry #528 29037 0002 212312 

Aquila Inc-Ralph Green Generating Plant 29037 0003 221112 0.53 

Southern Star Central Gas Pipeline-Peculiar Compressor Station 29037 0048 48621 6.58 

Aries Power Plant-Pleasant Hill 29037 0056 221112 46.47 
5 of 16 

Facility Name 

State 

County 

FIPS Code

Facility 

ID NAICS 

CO 

Emissions 

(tons/year)

KCP&L GMO-SOUTH HARPER PEAKING FACILITY 29037 0063 221112 56.06 

Dairiconcepts-El Dorado Springs 29039 0003 311514 8.20 

Salisbury Station Platte Pipe Line Co-Salisbury 29041 0013 42472 

National Starch & Chemical Co-National Starch & Chemical Co 29047 0002 311221 28.73 

Archer Daniels Midland Co-ADM Milling Co 29047 0009 311211 0.59 

Cook Composites And Polymers Co-North Kansas City 29047 0012 325510 5.19 

Ford Motor Co-Kansas City Assembly Plant 29047 0019 336111 57.08 

Bartlett Grain Company-Birmingham 29047 0025 42451 

Cargill Inc-Chouteau Elevator 29047 0027 42451 

Henry Wurst Inc-North Kansas City 29047 0032 323110 0.07 

Midland Lithography Co-North Kansas City 29047 0033 323110 - 

Davis Paint Co-Davis Paint Co 29047 0040 32551 - 

Jesco Resources Inc-Jesco Resources Inc 29047 0052 324191 0.15 

Hallmark Cards Inc-Distribution Center 29047 0059 323110 1.62 

Tnemec Company Inc-Tnemec Company Inc 29047 0075 32551 

Campbell Earl Mfg Co-Campbell Earl Mfg Co 29047 0079 32551 

Independence Power And Light-Missouri City Station 29047 0096 221112 8.85 

Banta Publications-Kansas City 29047 0122 336211 1.50 

Sericol Inc-Sericol Inc 29047 0141 32591 0.07 

Vertex Plastics Inc-Kearney 29047 0175 326191 

Water Supply Division-Kansas City 29047 2227 22131 1.62 

United Cooperative Inc-Plattsburg Elevator 29049 0016 42472 - 

Amerenue-Moreau Combustion Turbine 29051 0008 221112 0.13 

Unilever Hpc Usa-Jefferson City Plant 29051 0009 325611 3.21 

Von Hoffman Press Inc-Jefferson City 29051 0028 323117 

Modine Manufacturing Company-Jefferson City 29051 0032 336211 2.06 

Johnson Controls Hoover Auto-Johnson Controls Hoover Auto 29051 0037 32614 - 

Phillips Pipeline Company-Jefferson City Terminal 29051 0042 42471 32.25 

Command Web Offset Missouri Inc-Jefferson City 29051 0043 323110 4.51 

Amerenue-Fairgrounds Combustion Turbine 29051 0049 221112 0.25 

Jefferson City Landfill-Laidlaw Waste Systems 29051 0058 562212 70.46 

W R Meadows Inc-Boonville 29053 0003 321219 70.39 

Caterpillar Inc-Caterpillar Inc 29053 0019 326291 1.80 

Nordyne Inc-Boonville Plant 29053 0021 333414 0.74 

Missouri Dept Of Corrections-Boonville Correctional Center 29053 0027 92214 2.67 

Paramount Metalizing Co-Sullivan 29055 0043 32622 

Landmark Mfg Corp-Landmark Mfg Corp 29061 0010 332313 1.34 

Magellan Pipeline Company Llc-Osborn Station 29063 0009 48691 3.86 

United Cooperative Inc-Osborn Elevator 29063 0013 42451 

Royal Oak Enterprises Inc-Salem Briquet Plant 29065 0038 325191 38.34 

White Oak Gin Company Inc-White Oak Gin Company Inc 29069 0010 115111 1.02 

Graves Kennett Gin-Kennett 29069 0014 115111 0.13 

Farmers Union Gin-Farmers Union Gin 29069 0018 115111 
6 of 16 

Facility Name 

State 

County 

FIPS Code

Facility 

ID NAICS 

CO 

Emissions 

(tons/year)

Four Way Gin Company-Four Way Gin Company 29069 0027 115111 

Cardwell Cooperative Inc-Cardwell Cooperative Inc 29069 0029 115111 

Stokes Mayberry Gin Company-Stokes Mayberry Gin Company 29069 0032 115111 - 

Kennett Generating Plant 29069 0063 221112 0.97 

Campbell Municipal Power Plant 29069 0064 221112 0.20 

Associated Electric Cooperative Inc-St Francis Power Plant 29069 0066 221112 30.23 

Amerenue-Labadie Plant 29071 0003 221112 2,494.33 

Canam Steel Corp-Canam Steel Corp 29071 0014 332312 0.14 

Steelweld Equipment Co-St Clair 29071 0020 336211 0.17 

Jefferson Smurfit Corp-Pacific 29071 0031 322212 - 

Meramec Industries Inc-Ramsey St Plant 29071 0068 326121 0.06 

Bull Moose Tube Company-Bull Moose Tube Company 29071 0087 33121 0.32 

Sullivan Precision Metal Finishing Inc-Sullivan Precision Metal Finishing 

Inc 29071 0131 332813 - 

Sporlan Valve Company-Plant #2 - West Main 29071 0132 332911 

Integram - St Louis Seating-Pacific 29071 0144 33636 0.48 

Aerofil Technology Inc-Aerofil Technology Inc 29071 0151 311942 0.39 

Magnet Llc-Washington 29071 0153 33995 

Marble Decor Inc-Marble Decor Inc 29071 0154 326121 - 

Plaze Incorporated-Plaze Incorporated 29071 0157 311942 0.35 

GDX Automotive - Danny Scott Drive-New Haven 29071 0173 31332 

Sporlan Valve Company-Plant #3 - Lange Drive 29071 0178 332919 

RR Donnelley-Owensville 29073 0008 323110 1.58 

Carlisle Power Transmission Products Inc-Springfield 29077 0004 326220 5.97 

James River Power Plant 29077 0005 221112 1,195.87 

Bristol Manufacturing Corp-Bristol Manufacturing Corp 29077 0008 311513 0.91 

Aarons Automotive Products Inc-Westgate Ave Facility 29077 0010 336211 192.96 

Interstate Brands Corporation-Butternut Bread 29077 0011 311812 0.75 

Clariant Life Science Molecules-Clariant Life Science Molecules 29077 0017 325411 1.79 

Sweetheart Cup-Sweetheart Cup 29077 0021 322215 2.11 

Kraft Foods North America Inc-Kraft Foods North America Inc 29077 0026 311513 9.33 

St John'S Regional Health Center-Springfield 29077 0028 62211 16.38 

Dairy Farmers Of America Inc-Springfield 29077 0036 311514 7.82 

Southwest Power Plant 29077 0039 221112 154.05 

Southwest Mo State Univ-Physical Plant 29077 0047 61131 6.15 

3M Company-Springfield ITSD/TMD 29077 0051 32552 6.00 

General Electric-Springfield 29077 0056 335312 0.84 

Magellan Pipeline Company Llc-Springfield Terminal 29077 0116 48691 17.94 

City Utilities Of Springfield-Main Avenue Gas Turbine 29077 0145 221112 0.02 

Springfield Sanitary Landfill-Willard 29077 0161 562212 90.80 

City Utilities Of Springfield-Fulbright Treatment Plant 29077 0163 92613 0.09 

N L McCartney Dist Generation 29077 0164 221112 21.29 

CITY UTILITIES OF SPRINGFIELD MISSOURI-NOBLE HILL LANDFILL 

RENEW ENGY CTR 29077 0170 221119 97.45 
7 of 16 

Facility Name 

State 

County 

FIPS Code

Facility 

ID NAICS 

CO 

Emissions 

(tons/year)

Trinity Industries Inc-Trinity Industries Inc 29077 0200 48711 - 

Superior Solvents & Chemicals-Superior Solvents & Chemicals 29077 0228 42469 

Modine Manufacturing Company-Trenton 29079 0004 336211 3.32 

Trenton Municipal Utilities-Trenton Peaking Plant 29079 0027 221112 0.37 

Magellan Pipeline Company Llc-Ridgeway Station 29081 0010 48691 19.60 

Montrose Generating Station 29083 0001 221112 517.37 

Tracker Marine-Clinton Plant 29083 0031 336612 2.03 

Schreiber Foods Inc-Packaging Converting Plant 29083 0033 322221 0.54 

Exide Technologies-Canon Hollow 29087 0001 331314 3.47 

Golden Triangle Energy-Craig 29087 0016 32511 4.07 

Smith Flooring Company-Mountain View 29091 0005 321918 30.17 

Systems & Electronics Inc-West Plains 29091 0011 336212 0.15 

Garnett Wood Products-Charcoal Plant 29091 0038 325191 982.05 

Bruce Hardwood Floors-Bruce Hardwood Floors 29091 0046 321113 22.44 

West Plains City Power Station 29091 0068 221112 0.01 

Doe Run Company-Buick Mill 29093 0005 212231 - 

Doe Run Company-Glover Smelter 29093 0008 331419 0.01 

Doe Run Company-Buick Smelter 29093 0009 331419 13,390.57 

Bp Products North America Inc-Sugar Creek Terminal 29095 0002 32411 1.07 

U S Dept Of Energy-Kansas City Plant (Alliedsignal) 29095 0005 33422 1.07 

Bayer Cropscience-Kansas City 29095 0011 32532 25.81 

Clay & Bailey Mfg Co-Clay & Bailey Mfg Co 29095 0012 331511 0.05 

Folgers Coffee Co-Folgers Coffee Co 29095 0017 31192 331.48 

Trigen Energy Corporation-Grand Avenue Station 29095 0021 221112 34.41 

Hawthorn Station 29095 0022 221112 2,406.55 

Kansas City Power & Light Co-Northeast Station 29095 0023 221112 0.09 

Wolcott & Lincoln Jackson Llc-Kansas City 29095 0026 42451 

Lafarge North America Inc-Independence Plant 29095 0030 32731 639.59 

Aquila Inc-Sibley Generating Station 29095 0031 221112 370.96 

Vance Brothers Inc-Vance Brothers Inc 29095 0037 324121 18.54 

Blue River Treatment Plant-Blue River Treatment Plant 29095 0039 562211 28.33 

Alliant Llc-Lake City Army Ammunition Plant 29095 0046 332992 26.59 

Blue Valley Station 29095 0050 221112 53.07 

Koch Materials Company-Koch Materials Company 29095 0064 324121 0.40 

Independence Regional Health Center-Independence 29095 0066 62211 0.98 

Peterson Mfg Co-Grandview 29095 0075 336321 0.51 

Barber & Sons Aggregates-Barber & Sons Aggregates 29095 0076 212312 10.24 

Hallmark Cards-Hallmark Cards 29095 0114 323110 3.07 

Aquila Inc-Greenwood Energy Center 29095 0139 221112 14.18 

Ball Metal Beverage Container Co -Kansas City 29095 0175 332431 6.72 

Unilever Bestfoods North America-Unilever Bestfoods North America 29095 0178 311421 8.74 

Aero Transportation Products Inc-Independence Plant 29095 0191 336211 

Independence Power And Light-Sub Station I 29095 0222 221112 0.07 
8 of 16 

Facility Name 

State 

County 

FIPS Code

Facility 

ID NAICS 

CO 

Emissions 

(tons/year)

Independence Power And Light-Sub Station H 29095 0223 221112 0.55 

Independence Power And Light-Sub Station J 29095 0224 221112 0.03 

Tiffany Marble Inc-Lee'S Summit 29095 0244 326121 - 

Courtney Ridge Landfill Llc-Courtney Ridge Landfill Llc 29095 0267 562212 129.38 

Lee'S Summit Sanitary Landfill-Lee'S Summit Sanitary Landfill 29095 0272 562212 37.96 

Rumble Recycling And Disposal-Sanitary Landfill Rumble 1 & 2 29095 0273 562212 22.83 

LAFARGE NORTH AMERICA INC-COURTNEY RIDGE QUARRY 29095 0321 212312 

Cargill Inc-Kansas City 29095 2001 311222 1.82 

Crown Center Redevelopment Corporation-Kansas City 29095 2007 72111 9.65 

Research Medical Center-Research Medical Center 29095 2054 62211 2.40 

Cook Brothers Insulation Inc-Cook Brothers Insulation Inc 29095 2058 32614 - 

Baptist Medical Center-Baptist Medical Center 29095 2087 62211 0.88 

Allied Waste Industries Sanitary Landfil-Kansas City Landfill 29095 2101 562212 66.75 

Truman Medical Center - East-Truman Medical Center - East 29095 2154 62211 0.04 

International Paper Company-International Paper Company 29095 2177 322211 2.62 

New Surface Llc-East 12th 29095 2224 327991 0.00 

SUN CHEMICAL-KANSAS CITY 29095 2431 325910 

Empire District Electric Co-Asbury Plant 29097 0001 221112 195.75 

Dyno Nobel Inc-Carthage Plant 29097 0007 32592 5.49 

ADM Milling Company-Carthage Flour Mill 29097 0011 311211 0.07 

Tamko Roofing Products Inc-High St Plant 29097 0013 324122 8.14 

St John'S Regional Medical Center-St John'S Regional Medical Center 29097 0021 62211 4.24 

Justin Boot Company-Carthage (Plant 417) 29097 0058 316219 

Empire District Electric Co-Empire Energy Center 29097 0062 221112 6.01 

Modine Manufacturing Company-Joplin 29097 0065 332313 0.43 

Magellan Pipeline Company-Carthage Terminal 29097 0079 48691 2.36 

Able Manufacturing & Assembly L L C -Schifferdecker 29097 0089 336211 

Tamko Roofing Products Inc-Rangeline Plant 29097 0094 324122 88.27 

Able Manufacturing Corporation-7th Street 29097 0095 326121 

Empire District Electric Co-State Line Facility 29097 0104 221112 650.53 

Carthage Water & Electric 29097 0110 221112 3.79 

Eagle-Picher Technologies Llc-Federal Systems 29097 0117 335911 0.18 

Pechiney Plastic Packaging Inc-Joplin Plant 29097 0132 323112 2.08 

ICI Explosives Environmental Co-Joplin 29097 0138 562211 0.35 

Leggett & Platt-Wire Mill - Carthage Central Ave 29097 0143 331222 12.67 

DYNAMIC FINISHES - JOPLIN 29097 0154 333131 

Rc Cement Company Inc-River Cement Co - Selma Plant 29099 0002 32731 302.96 

Doe Run Company-Herculaneum Smelter 29099 0003 331419 23.25 

Union Pacific Railroad Co-Desoto Car Shop 29099 0011 336510 1.27 

Trautman Quarry-Pevely 29099 0012 212312 

Dow Chemical Company The-Riverside Plant 29099 0014 325211 1.11 

Amerenue-Rush Island Plant 29099 0016 221112 1,333.35 

Metal Container Corporation-Arnold 29099 0044 332431 9.43 
9 of 16 

Facility Name 

State 

County 

FIPS Code

Facility 

ID NAICS 

CO 

Emissions 

(tons/year)

Engineered Coil Company-D B A Marlo Coil 29099 0052 336611 0.02 

Saint-Gobain Containers Llc-Pevely 29099 0068 327213 8.30 

Bussen Quarries Inc-Antire Quarry 29099 0103 212312 

Carondelet Corporation-Carondelet Corporation 29099 0111 331513 4.14 

Aero Metal Finishing-Aero Metal Finishing 29099 0114 332813 

Central Missouri State University-Physical Plant 29101 0002 61131 5.60 

Stahl Specialty Co-Kingsville Plant 29101 0003 331524 10.16 

Whiteman Air Force Base-Whiteman 29101 0009 92811 15.54 

Hawker Energy Products Inc-Warrensburg 29101 0023 335912 2.72 

Show-Me Regional Landfill-Show-Me Regional Landfill 29101 0046 562212 46.45 

Holden Power Plant 29101 0051 221112 0.57 

Master Marble Inc-Holden 29101 0054 326121 - 

Independent Stave Co Inc-Lebanon Plant 29105 0001 321920 37.88 

Lowe Boats-Omc Aluminum Boat Group 29105 0006 336612 0.16 

Detroit Tool & Engineering-Lebanon 29105 0013 332212 

Marathon Electric Mfg Corp-Lebanon Plant 29105 0033 335312 0.28 

G3 Boats-Lebanon 29105 0038 336612 

Tracker Marine-Lebanon Plant 29105 0046 336612 0.23 

S & K Industries Inc-S & K Industries Inc B #1 29107 0004 337122 2.00 

Wincup-Higginsville Plant 29107 0010 325211 5.40 

S & K Industries Inc-S & K Industries Inc B #2 29107 0029 321912 

Higginsville Municipal Power Facility 29107 0038 221112 0.43 

Bartlett Grain Company Lp-Waverly 29107 0050 42451 0.00 

NEW SURFACE-ODESSA 29107 0063 326121 0.01 

Razorback Pipeline Company-Transmontaigne Product Services Inc 29109 0002 49311 0.30 

Bcp Ingredients-Verona Plant 29109 0004 325411 1.61 

Mo Rehabilitation Center-Mo Rehabilitation Center 29109 0008 62211 1.06 

ConocoPhillips Co-Mount Vernon Products Terminal 29109 0036 42471 18.78 

E F Marsh Engineering Company-Mt Vernon 29109 0051 333922 

AYERS OIL CO-CANTON 29111 0019 424710 

Old Monroe Elevator & Supplies-Old Monroe 29113 0003 311119 0.04 

Toyota Motor Corporate Services-Bodine Aluminum Inc 29113 0029 331524 4.70 

Farmers Elevator & Supply Co-Hawk Point 29113 0042 42491 0.02 

Most Inc-Troy 29113 0046 331314 1.46 

Walsworth Publishing Company-Marceline 29115 0001 323110 0.04 

Chillicothe Municipal Utilities 29117 0002 221112 0.22 

Donaldson Co Inc-Donaldson Co Inc 29117 0012 336211 1.16 

Simmons Foods Inc-Southwest City 29119 0017 311615 52.65 

Superior Maple Hill Landfill-Macon 29121 0027 562212 41.59 

Northeast Missouri Grain Llc-Macon 29121 0028 32511 66.39 

MACON MUNICIPAL UTILITIES-NEMO GENERATING STATION 29121 0033 221112 12.02 

MACON MUNICIPAL UTILITIES-KELLOGG AVE 29121 0035 221112 0.25 

MACON MUNICIPAL UTILITIES-NOLL DRIVE 29121 0036 221112 0.12 
10 of 16 

Facility Name 

State 

County 

FIPS Code

Facility 

ID NAICS 

CO 

Emissions 

(tons/year)

Centerpoint Energy-Twelve Mile Compressor Station 29123 0018 48621 194.01 

Versa-Tech Inc-Fredericktown 29123 0022 32614 - 

Kingsford Manufacturing Co-Briquetting Plant 29125 0001 325191 22.89 

BASF Agri Chemicals-Hannibal Plant 29127 0001 32532 147.32 

Magellan Pipeline Company Llc-Palmyra Station 29127 0002 48691 3.04 

Fasco Industries Inc-Eldon Plant 29131 0032 335312 0.05 

Gates Rubber Company-Gates Rubber Company 29133 0014 32622 0.92 

Consolidated Grain And Barge Co-Dorena Facility 29133 0016 49313 - 

Monroe City Power Plant-Monroe City 29137 0028 221112 0.04 

Christy Minerals Co-High Hill 29139 0008 212324 82.34 

Associated Electric Cooperative Inc-New Madrid Power Plant 29143 0004 221112 1,100.66 

Noranda Aluminum Inc-Noranda Aluminum Inc 29143 0008 331312 24,770.83 

Mahan Gin Co-Mahan Gin Co 29143 0012 115111 0.02 

Portageville Farmers Gin Inc-Portageville Farmers Gin Inc 29143 0013 115111 

Plastene Supply Company-Div Siegel-Robert Inc 29143 0015 326121 0.65 

Mccord Gin Company-Gideon 29143 0023 115111 - 

Cargill Inc-New Madrid 29143 0027 325314 

A C Riley Cotton Company-New Madrid Gin 29143 0046 115111 

Bootheel Cotton Company Inc-Matthews 29143 0047 115111 - 

Bunge North America Inc-Linda Elevator 29143 0062 42451 0.03 

La-Z-Boy Chair Company-La-Z-Boy Midwest 29145 0005 337121 0.81 

Fag Bearings Corporation-Joplin 29145 0007 332991 22.08 

Premier Turbines-Neosho Plant 29145 0044 336412 12.45 

Southern Star Central Gas Pipeline-Saginaw Compressor Station 29145 0049 48621 7.95 

Northwest Missouri State University-Maryville 29147 0005 61131 57.07 

Eveready Battery Co Inc-Maryville Plant 29147 0008 335912 1.90 

Kawasaki Motors Mfg Corp-Kawasaki Motors Mfg Corp 29147 0023 333618 84.25 

Anr Pipeline Company-Maitland Compressor Station 29147 0024 486210 236.82 

Consumers Oil Co Inc-Maryville Plant 29147 0027 42451 

Nodaway Plant 29147 0032 221112 0.12 

Central Electric Power Cooperative-Chamois Plant 29151 0002 221112 78.38 

Quaker Window Products Company-Quaker Window Products Company 29151 0050 332321 0.56 

L Berry Gin Company-L Berry Gin Company 29155 0021 115111 0.10 

Still Gin & Grain Inc-Steele 29155 0024 115111 - 

Trinity Marine Products Inc-Caruthersville - Plant #75 29155 0030 336611 0.50 

Loxcreen Company Inc-Hayti 29155 0045 331316 3.53 

Trinity Marine Products Inc-Caruthersville Plant #73 29155 0049 326121 0.12 

Bunge North America Inc-Caruthersville Plant 29155 0063 42451 - 

Tg Missouri-Perryville 29157 0019 336211 2.67 

Falcon Foam-Falcon Foam 29157 0020 326121 2.28 

H & G Marine Service Inc-Perryville 29157 0022 332439 

Tnt Plastics Inc-Perryville 29157 0027 326113 - 

Martin Marietta Materials-Carolina Asphalt Company 29157 0032 324121 0.44 
11 of 16 

Facility Name 

State 

County 

FIPS Code

Facility 

ID NAICS 

CO 

Emissions 

(tons/year)

Martin Marietta Materials Inc-Perryville Quarry #366 29157 P023 212312 

Lafarge North America Inc -Sedalia Quarry & Asphalt 29159 0002 212312 9.15 

Pittsburgh-Corning Corp-Pittsburgh-Corning Corp 29159 0009 327993 22.34 

Waterloo Industries Inc-Waterloo Industries Inc 29159 0012 332117 5.99 

Alcan Cable-Div Of Alcan Products Corporation 29159 0022 331319 2.26 

Hayes Lemmerz International Inc-Sedalia 29159 0027 336211 4.96 

Tyson Foods Inc-Sedalia Processing Plant 29159 0037 311615 32.29 

Gardner Denver Inc-Sedalia Plant 29159 0039 333912 - 

Missouri Pressed Metals Inc-Sedalia 29159 0041 332117 0.00 

Panhandle Eastern Pipe Line Co-Houstonia 29159 0047 48621 341.54 

Edwards Fiberglass Inc-Sedalia 29159 0056 326191 

WEST CENTRAL CONCRETE LLC-SNOW RD 29159 0058 327320 - 

EDWARDS FRP REPAIR-WINGATE 29159 0059 325211 

University Of Mo - Rolla-Rolla Power Plant 29161 0006 61131 23.79 

Manchester Packaging Company-Manchester Packaging Company 29161 0039 326121 0.01 

Rolla Municipal Utilities-Multiple Peaking Plants 29161 0054 221112 0.01 

Holcim (Us) Inc-Clarksville 29163 0001 32731 1,734.85 

Aqualon Div Of Hercules Inc-Missouri Chemical Works 29163 0002 32511 54.23 

Wayne B Smith Inc-Wayne B Smith Inc 29163 0008 212312 0.03 

Bunge North America Inc-Louisiana Plant 29163 0025 49313 0.11 

Dyno Nobel Inc-Lomo Plant 29163 0031 325311 

Eagle Ridge Landfill-Bowling Green 29163 0040 562212 0.94 

Amerenue-Peno Creek Energy Center 29163 0047 221112 2.18 

American Airlines-Mci Maintenance And Engineering Base 29165 0005 336411 - 

Kansas City Power & Light Co-Iatan Generating Station 29165 0007 221112 628.83 

Package Service Co Llc-Package Service Co Llc 29165 0021 323112 - 

Woodbridge Corporation-Kansas City Foam Div 29165 0028 32614 1.21 

KCI Airport - KCMO Aviation Dept 29165 2404 488111 3.20 

Harley Davidson Motor Company-Kansas City Plant 29165 2415 336991 6.42 

FACILITY OPERATION SERVICES LLC-NW 112TH 29165 2424 221330 13.15 

Tracker Marine-Bolivar Plant 29167 0028 336612 - 

Manscen And Fort Leonard Wood-Manscen And Fort Leonard Wood 29169 0004 928110 9.45 

Associated Electric Cooperative Inc-Unionville Power Station 29171 0015 221112 0.01 

Continental Cement Company Inc-Ilasco Plant 29173 0001 32731 84.78 

ENNIS PAINT INC-SAVERTON 29173 0021 325510 

Buckhorn Rubber Products Inc-Buckhorn Rubber Company Inc 29173 0037 32622 - 

Associated Electric Cooperative Inc-Thomas Hill Energy Center-Power 

Division 29175 0001 221112 4,486.18 

Amerenue-Moberly Combustion Turbine 29175 0010 221112 0.13 

OFFICE OF ADMINISTRATION FMDC-MOBERLY CORRECTIONAL 

CENTER 29175 0034 922140 6.92 

Wilson Trailer Sales Inc-Moberly 29175 0061 336212 0.21 

Doe Run Company-Bunker (Fletcher Mine) 29179 0006 212231 - 

Amerenue-Sioux Plant 29183 0001 221112 765.30 
12 of 16 

Facility Name 

State 

County 

FIPS Code

Facility 

ID NAICS 

CO 

Emissions 

(tons/year)

Fred Weber Inc-O'Fallon Asphalt Plant 29183 0004 324121 15.54 

Fred Weber Inc-O'Fallon Stone Plant 29183 0007 212312 

McDonnell Douglas Corp-Boeing Company 29183 0010 334413 2.15 

St Joseph Health Center-St Joseph Health Center 29183 0019 62211 3.18 

Memc Electronic Materials Inc-St Peters Plant 29183 0027 334416 10.07 

General Motors-Wentzville Center 29183 0076 336111 101.51 

O Fallon Casting Llc-O Fallon 29183 0077 331512 1.55 

Woodbridge Corporation-St Peters 29183 0129 32614 - 

Superior Home Products Inc-Superior Home Products Inc 29183 0131 326121 - 

True Manufacturing Co-O'Fallon 29183 0184 333415 1.39 

Mississippi Lime Company-Mississippi Lime Co 29186 0001 32741 11,815.05 

Biltbest Windows Corp-Ste Genevieve 29186 0003 321911 0.49 

Tower Rock Stone Co-Ste Genevieve 29186 0022 212312 

Centerpoint Energy-Ste Genevieve Compressor Station 29186 0024 48621 9.73 

Chemical Lime Company-Ste Genevieve 29186 0035 32741 28.37 

Lead Belt Materials Co Inc-Park Hills 29187 0001 212312 4.30 

Vessell Mineral Products-Vessell Mineral Products 29187 0002 327124 32.06 

Flat River Glass Co-Park Hills 29187 0017 327211 4.76 

Playpower Lt Farmington Inc-Iron Mountain Forge Corp 29187 0041 337121 2.67 

S-R Products-Farmington 29187 0048 336991 0.21 

Base Rock Minerals Inc-Bonne Terre Plant 29187 0072 212312 1.70 

FARMINGTON LIGHT & POWER-FARMINGTON 29187 0075 221112 0.10 

Chrysler Assembly Plant 1-Fenton 29189 0002 336111 21.86 

Amerenue-Meramec Plant 29189 0010 221112 3,811.99 

Fred Weber Inc-North Stone 29189 0017 324121 

Fred Weber Inc-South Stone 29189 0019 324121 

Monsanto World Headquarters-Lindbergh Blvd 29189 0020 54171 10.33 

U S Silica Company-Pacific 29189 0021 212322 3.51 

Dana Corporation-Perfect Circle Division 29189 0025 336311 0.87 

Pharmacia-Chesterfield Village 29189 0032 32511 14.82 

Rockwood Pigments Na Inc-E Hoffmeister 29189 0035 325131 8.27 

Washington University-Millbrook Blvd 29189 0042 61131 18.42 

St Louis Post-Dispatch-Dunlap Ind Dr 29189 0057 51111 0.16 

Sunnen Products Company-Maplewood 29189 0064 333512 1.01 

St Louis Airport Authority-Lambert International Blvd 29189 0065 336212 9.38 

Simpson Construction Materials Llc-West Lake Quarry & Material Co 29189 0111 212312 15.71 

Energy Petroleum Company-Kienlen 29189 0141 42471 

Printpack Inc-Hazelwood Plant 29189 0208 322221 3.45 

Metropolitan St Louis Sewer District-Lemay Waste Water Treatment 

Plant 29189 0217 22132 321.07 

Nesco Container Corp-Fenton 29189 0226 332439 1.07 

McDonnell Douglas Corp /Boeing Company-Lindbergh Plant 29189 0230 336411 20.96 

Chrysler Corp-North Plant 29189 0231 336111 65.23 
13 of 16 

Facility Name 

State 

County 

FIPS Code

Facility 

ID NAICS 

CO 

Emissions 

(tons/year)

St Louis Lithographing Company-Heege Avenue 29189 0238 323110 

Multiplex Display Fixture-Fenton 29189 0242 337127 0.49 

Bussen Quarries Inc-Bussen Road 29189 0275 212312 

Ruprecht Quarry-Paule Rd 29189 0276 212312 

BFI Missouri Pass Landfill-Maryland Heights 29189 0281 562212 30.58 

Color Art Inc-Crestwood 29189 0282 323110 1.01 

Fred Weber Inc Sanitary Landfill-St Louis County 29189 0308 562212 130.13 

Onyx Oak Ridge Landfill Inc-(West County) 29189 0310 562212 44.89 

Bridgeton Landfill Authority-Bridgeton 29189 0312 562212 244.28 

Flex-O-Lite Inc-Fenton 29189 0315 327215 - 

Pro-Tect Mfg Inc-Ferguson Ave 29189 0317 32614 

St Marys Health Center-Richmond Heights 29189 0318 62211 6.74 

Camie-Campbell Inc-Watson Industrial Park 29189 0327 325520 

Belt Service Corp-Earth City 29189 1012 326220 0.47 

Kv Pharmaceutical Company-Brentwood 29189 1015 325412 - 

Depaul Health Center-Bridgeton 29189 1029 62211 6.05 

Kv Pharmaceutical Company-Schuetz Rd 29189 1047 325412 1.22 

Veterans Admin Medical Center-Jefferson Barracks Drive 29189 1052 62211 - 

Reichhold Chemicals Inc-Valley Park 29189 1097 325211 4.40 

St Luke'S Hospital-Woods Mill Road 29189 1101 62211 5.24 

St Joseph Hospital-Kirkwood 29189 1156 62211 2.99 

Pan-Glo St Louis-Trenton Avenue 29189 1192 811310 

Whitmire Microgen Research Laboratory-Kirkwood 29189 1204 32532 

Metropolitan St Louis Sewer District-Mo River Wasterwater Treatment 

Plant 29189 1205 22132 7.10 

Metropolitan St Louis Sewer District-Coldwater Creek Sewage 

Treatment Plant 29189 1210 22132 50.69 

Simpson Construction Materials Llc-Valley Park 29189 1226 324121 20.28 

Fred Weber Inc-South Asphalt 29189 1248 324121 24.49 

Fred Weber Inc-North Asphalt H & B 29189 1249 324121 37.15 

Fred Weber Inc-North Asphalt B & G 29189 1250 324121 37.42 

Gkn Aerospace Services Inc-Berkeley 29189 1489 336413 11.36 

F & S Real Eastate Inc-St Louis 29189 1520 323112 

KV PHARMACEUTICAL-BRIDGETON 29189 1538 325412 - 

Conagra Foods-Marshall Plant 29195 0004 311412 4.08 

Marshall Municipal Utilities 29195 0010 221112 45.49 

MID-MISSOURI ENERGY INC-MALTA BEND 29195 0046 325193 64.50 

Tetra Pak Materials-Sikeston 29201 0003 32213 - 

Sikeston Power Station-Sikeston Power Station 29201 0017 221112 287.95 

TEPPCO-Cape Girardeau Terminal 29201 0018 48691 

Havco Wood Products Inc-Havco Wood Products Inc 29201 0021 321113 57.98 

Crowder Gin Company Inc-Sikeston 29201 0073 115111 0.03 

Texas Eastern Transmission Corporation-Oran Facility 29201 0099 48621 29.32 
14 of 16 

Facility Name 

State 

County 

FIPS Code

Facility 

ID NAICS 

CO 

Emissions 

(tons/year)

Manac Trailers Usa Inc-Oran 29201 0102 333294 0.01 

CONSTRUCTION TRAILER SPECIALISTS INC-SIKESTON 29201 0110 336212 

CONSOLIDATED GRAIN AND BARGE CO-CONSOLIDATED GRAIN 

AND BARGE CO 29201 8001 424510 0.23 

Missouri Hardwood Flooring Co-Missouri Hardwood Flooring Co 29203 0005 321113 19.55 

Cerro Copper Tube Company-Cerro Copper Tube Company 29205 0010 331421 82.30 

Shelbina Power Plant 29205 0011 221112 0.01 

Ames True Temper Inc-Bernie North Plant 29207 0007 321999 6.92 

J P Ross Cotton Co Inc-J P Ross Cotton Co Inc 29207 0008 115111 0.05 

Nestle Purina Petcare Company-Bloomfield 29207 0014 212324 43.19 

Stoddard County Cotton Co-Bernie 29207 0018 115111 0.23 

W W Wood Products-Dudley 29207 0019 321113 0.64 

Lemons Sanitary Landfill-Lemons Sanitary Landfill 29207 0062 562212 67.28 

Essex Power Plant 29207 0064 221112 0.01 

Table Rock Asphalt Constr Co Inc-Quarry #3 & Concrete Plant 29209 0007 212312 

Horner Charcoal Co Inc-Horner Charcoal Co Inc 29213 0002 325191 0.86 

Table Rock Asphalt Constr Co Inc-Hwy 248 Quarry 29213 0003 212312 1.03 

Royal Oak Enterprises-Royal Oak Enterprises 29213 0007 325191 26.06 

College Of The Ozarks-Branson 29213 0048 61131 1.85 

Dairy Farmers Of America Inc-Cabool 29215 0026 311514 7.69 

Woodpro Cabinetry Inc-Cabool 29215 0060 33711 9.92 

3M Company-Nevada - Commercial Graphics 29217 0004 326121 20.58 

Aquila Inc-Nevada Gas Turbine 29217 0034 221112 0.01 

PRAIRIE PRIDE INC-EVE 29217 0043 311222 10.61 

Holland Usa-Warrenton Facility 29219 0013 332117 0.00 

Warrenton Copper Llc-Warrenton 29219 0028 331314 6.59 

Greif Inc-Wright City 29219 0036 322214 0.09 

Cascades Plastics Inc-Warrenton 29219 0038 32614 

Red Wing Shoe Company Inc-Potosi 29221 0008 316214 

Buckman Laboratories Inc-Cadet 29221 0018 311942 2.45 

Purcell Tire-Purcell Tire 29221 0022 443112 2.10 

IESI CORPORATION-TIMBER RIDGE LANDFILL 29221 0031 562212 

Steel Processors-Steel Processors 29225 0026 336212 0.31 

Hutchens Industries-Mansfield Steel Div 29229 0001 336212 0.29 

Black Oak Recycling & Disposal Facility-Div Waste Corporation Of 

America 29229 0022 562212 39.35 

Anheuser-Busch Inc-St Louis 29510 0003 312120 145.98 

Mallinckrodt Inc -Mallinckrodt Inc 29510 0017 32511 77.49 

Precoat Metals-Precoat Metals 29510 0027 332812 5.10 

ADM Gromark River Systems-St Louis 29510 0031 311211 0.00 

Trigen-St Louis Energy Corp-Ashley Street Station 29510 0038 221112 46.27 

Washington Univ Medical School-Boiler Plant 29510 0040 62211 28.23 

Fred Weber Inc-Asphalt Plant 29510 0047 324121 9.56 

Metropolitan St Louis Sewer District-Bissel Plant 29510 0053 92411 552.29 
15 of 16 

Facility Name 

State 

County 

FIPS Code

Facility 

ID NAICS 

CO 

Emissions 

(tons/year)

Procter & Gamble-Procter & Gamble 29510 0057 325611 9.89 

Dial Corp-Dial Corp 29510 0063 325611 8.39 

Elementis Specialties Inc-Elementis Specialties Inc 29510 0066 325131 6.78 

Astaris Llc-Carondelet Plant 29510 0070 211112 27.07 

P D George Co (The)-P D George Co (The) 29510 0096 32551 3.73 

U S Paint Div Of Grow Group-U S Paint Div Of Grow Group 29510 0097 32551 

Alumax Foils Inc-Alcoa Foil Products/Alumax Foils Inc 29510 0118 322225 14.02 

ADM/TPC Milling Co-Pillsbury Company 29510 0159 311211 - 

Poly One Corporation-St Louis 29510 0161 32551 

Marquette Tool & Die-Marquette Tool & Die 29510 0162 314999 

St Louis Metallizing-St Louis 29510 0175 332812 0.08 

Italgrani Elevator-Italgrani Elevator 29510 0179 42451 3.22 

St Alexius Hospital-St Louis 29510 0200 62211 0.33 

Bjc Health System-Pavillion 29510 0204 62211 1.51 

Sensient Colors Inc-Baldwin Plant 29510 0269 31192 2.41 

Hermann Oak Leather Co-Hermann Oak Leather Co 29510 0391 31611 - 

Lange-Stegmann Co-Lange-Stegmann Co 29510 0468 42491 0.00 

Sigma - Aldrich Co-Sigma - Aldrich Co 29510 0697 325199 3.14 

Chemisphere Corporation-Chemisphere 29510 0808 32511 

PQ Corporation (The)-St Louis 29510 0809 211112 9.65 

Interstate Brands Corp-Interstate Brands Corp 29510 0938 311812 1.27 

Goodwin Printing Co -St Louis 29510 1055 323110 

Mid-West Industrial Chemical-Mid-West Industrial Chemical 29510 1077 32552 - 

Brenntag Mid-South Inc-Brenntag Mid-South Inc 29510 1093 42392 0.00 

U S Ringbinder Corp-Loose Leaf Metals 29510 1123 323116 

St Louis Post Dispatch-St Louis Post Dispatch 29510 1280 51111 0.44 

National Geospatial-Intelligence Agency-National Geospatial-Intelligence 

Agency 29510 1370 92811 1.38 

Sigma - Aldrich Co-Sigma Chemical Company 29510 1396 325414 4.92 

Southern Metal Processing-Southern Metal Processing 29510 1407 333414 2.17 

Ashland Distribution Company-St Louis Plant 29510 1423 311942 

Allied Health Care Products-Allied Health Care Products 29510 1460 332919 - 

Energy Center (The)-St Louis Univ Health Sciences Center 29510 1505 621111 9.43 

Permacel St Louis Inc-Permacel St Louis Inc 29510 1519 326299 2.30 

Connector Castings-Connector Castings 29510 1556 331314 0.00 

J S Alberici Construction-J S Alberici Construction 29510 1642 236220 - 

Superior Solvent & Chemical-St Louis 29510 2300 49311 

Laclede Tower Associates Llc-Laclede Gas Building 29510 2378 22121 320.75 

New World Pasta- Marceau Facility-New World Pasta 29510 2433 311823 4.59 

Southwestern Bell Telephone Company-Southwestern Bell Telephone 

Company 29510 2545 517110 6.68 

St Louis University-Facilities Svcs 29510 2711 323110 9.70 

WASHINGTON UNIVERSITY-HILLTOP CAMPUS 29510 2833 611310 1.06 
16 of 16 

Facility Name 

State 

County 

FIPS Code

Facility 

ID NAICS 

CO 

Emissions 

(tons/year)

Statewide Total 92,239.10 
1 of 17 

Appendix A‐2

List of On-Road Mobile Source Emissions by SCC for St. Louis County and St. Louis City (tons/year)
2 of 17 

This page intentionally left blank.
3 of 17 

Area SCC SCC Road Type SCC Vehicle Type 

SCC 

Process 

Type 

CO 

Emissions 

(tons/year) 

St. Louis County 220100100X Off-Network Light Duty Gasoline Vehicles (LDGV) Exhaust      23,231.78

St. Louis County 220100111X Rural Interstate Light Duty Gasoline Vehicles (LDGV) Exhaust              42.35

St. Louis County 220100113X Rural Principal 

Arterial Light Duty Gasoline Vehicles (LDGV) Exhaust              92.46

St. Louis County 220100115X Rural Minor Arterial Light Duty Gasoline Vehicles (LDGV) Exhaust              43.77

St. Louis County 220100117X Rural Major Collector Light Duty Gasoline Vehicles (LDGV) Exhaust              84.79

St. Louis County 220100119X Rural Minor Collector Light Duty Gasoline Vehicles (LDGV) Exhaust                     ‐   

St. Louis County 220100121X Rural Local Light Duty Gasoline Vehicles (LDGV) Exhaust              56.87

St. Louis County 220100123X Urban Interstate Light Duty Gasoline Vehicles (LDGV) Exhaust        8,912.00

St. Louis County 220100125X Urban 

Freeway/Expressway Light Duty Gasoline Vehicles (LDGV) Exhaust        1,981.59

St. Louis County 220100127X Urban Principal 

Arterial Light Duty Gasoline Vehicles (LDGV) Exhaust        3,686.99

St. Louis County 220100129X Urban Minor Arterial Light Duty Gasoline Vehicles (LDGV) Exhaust        2,437.24

St. Louis County 220100131X Urban Collector Light Duty Gasoline Vehicles (LDGV) Exhaust        1,299.25

St. Louis County 220100133X Urban Local Light Duty Gasoline Vehicles (LDGV) Exhaust        4,799.43

St. Louis County 220102000X Off-Network Light Duty Gasoline Trucks 1 & 2 Exhaust      18,311.11

St. Louis County 220102011X Rural Interstate Light Duty Gasoline Trucks 1 & 2 Exhaust              49.09

St. Louis County 220102013X Rural Principal 

Arterial Light Duty Gasoline Trucks 1 & 2 Exhaust            111.16

St. Louis County 220102015X Rural Minor Arterial Light Duty Gasoline Trucks 1 & 2 Exhaust              52.62

St. Louis County 220102017X Rural Major Collector Light Duty Gasoline Trucks 1 & 2 Exhaust            101.94

St. Louis County 220102019X Rural Minor Collector Light Duty Gasoline Trucks 1 & 2 Exhaust                     ‐   

St. Louis County 220102021X Rural Local Light Duty Gasoline Trucks 1 & 2 Exhaust              68.37

St. Louis County 220102023X Urban Interstate Light Duty Gasoline Trucks 1 & 2 Exhaust      11,379.00
4 of 17 

Area SCC SCC Road Type SCC Vehicle Type 

SCC 

Process 

Type 

CO 

Emissions 

(tons/year) 

St. Louis County 220102025X Urban 

Freeway/Expressway Light Duty Gasoline Trucks 1 & 2 Exhaust        2,530.13

St. Louis County 220102027X Urban Principal 

Arterial Light Duty Gasoline Trucks 1 & 2 Exhaust        4,433.25

St. Louis County 220102029X Urban Minor Arterial Light Duty Gasoline Trucks 1 & 2 Exhaust        2,930.54

St. Louis County 220102031X Urban Collector Light Duty Gasoline Trucks 1 & 2 Exhaust        1,562.22

St. Louis County 220102033X Urban Local Light Duty Gasoline Trucks 1 & 2 Exhaust        5,770.85

St. Louis County 220104000X Off-Network Light Duty Gasoline Trucks 3 and 4 Exhaust        9,432.99

St. Louis County 220104011X Rural Interstate Light Duty Gasoline Trucks 3 and 4 Exhaust              25.29

St. Louis County 220104013X Rural Principal 

Arterial Light Duty Gasoline Trucks 3 and 4 Exhaust              57.27

St. Louis County 220104015X Rural Minor Arterial Light Duty Gasoline Trucks 3 and 4 Exhaust              27.11

St. Louis County 220104017X Rural Major Collector Light Duty Gasoline Trucks 3 and 4 Exhaust              52.51

St. Louis County 220104019X Rural Minor Collector Light Duty Gasoline Trucks 3 and 4 Exhaust                     ‐   

St. Louis County 220104021X Rural Local Light Duty Gasoline Trucks 3 and 4 Exhaust              35.22

St. Louis County 220104023X Urban Interstate Light Duty Gasoline Trucks 3 and 4 Exhaust        5,861.91

St. Louis County 220104025X Urban 

Freeway/Expressway Light Duty Gasoline Trucks 3 and 4 Exhaust        1,303.40

St. Louis County 220104027X Urban Principal 

Arterial Light Duty Gasoline Trucks 3 and 4 Exhaust        2,283.79

St. Louis County 220104029X Urban Minor Arterial Light Duty Gasoline Trucks 3 and 4 Exhaust        1,509.67

St. Louis County 220104031X Urban Collector Light Duty Gasoline Trucks 3 and 4 Exhaust            804.78

St. Louis County 220104033X Urban Local Light Duty Gasoline Trucks 3 and 4 Exhaust        2,972.86

St. Louis County 220107000X Off-Network Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust        2,637.96

St. Louis County 220107011X Rural Interstate Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust                 7.63

St. Louis County 220107013X Rural Principal 

Arterial 

Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust              18.99

St. Louis County 220107015X Rural Minor Arterial Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust                 8.99
5 of 17 

Area SCC SCC Road Type SCC Vehicle Type 

SCC 

Process 

Type 

CO 

Emissions 

(tons/year) 

St. Louis County 220107017X Rural Major Collector Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust              17.41

St. Louis County 220107019X Rural Minor Collector Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust                     ‐   

St. Louis County 220107021X Rural Local Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust              11.68

St. Louis County 220107023X Urban Interstate Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust        1,918.39

St. Louis County 220107025X Urban 

Freeway/Expressway

Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust            426.56

St. Louis County 220107027X Urban Principal 

Arterial 

Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust            777.97

St. Louis County 220107029X Urban Minor Arterial Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust            514.26

St. Louis County 220107031X Urban Collector Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust            274.14

St. Louis County 220107033X Urban Local Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust        1,012.70

St. Louis County 220108000X Off-Network Motorcycles (MC) Exhaust              83.09

St. Louis County 220108011X Rural Interstate Motorcycles (MC) Exhaust                 2.21

St. Louis County 220108013X Rural Principal 

Arterial Motorcycles (MC) Exhaust                 7.69

St. Louis County 220108015X Rural Minor Arterial Motorcycles (MC) Exhaust                 3.64

St. Louis County 220108017X Rural Major Collector Motorcycles (MC) Exhaust                 7.05

St. Louis County 220108019X Rural Minor Collector Motorcycles (MC) Exhaust                     ‐   

St. Louis County 220108021X Rural Local Motorcycles (MC) Exhaust                 4.73

St. Louis County 220108023X Urban Interstate Motorcycles (MC) Exhaust            771.73

St. Louis County 220108025X Urban 

Freeway/Expressway Motorcycles (MC) Exhaust            171.60

St. Louis County 220108027X Urban Principal 

Arterial Motorcycles (MC) Exhaust            298.99

St. Louis County 220108029X Urban Minor Arterial Motorcycles (MC) Exhaust            197.64

St. Louis County 220108031X Urban Collector Motorcycles (MC) Exhaust            105.36

St. Louis County 220108033X Urban Local Motorcycles (MC) Exhaust            389.20
6 of 17 

Area SCC SCC Road Type SCC Vehicle Type 

SCC 

Process 

Type 

CO 

Emissions 

(tons/year) 

St. Louis County 223000100X Off-Network Light Duty Diesel Vehicles (LDDV) Exhaust                 3.01

St. Louis County 223000111X Rural Interstate Light Duty Diesel Vehicles (LDDV) Exhaust                 0.00

St. Louis County 223000113X Rural Principal 

Arterial Light Duty Diesel Vehicles (LDDV) Exhaust                 0.02

St. Louis County 223000115X Rural Minor Arterial Light Duty Diesel Vehicles (LDDV) Exhaust                 0.01

St. Louis County 223000117X Rural Major Collector Light Duty Diesel Vehicles (LDDV) Exhaust                 0.02

St. Louis County 223000119X Rural Minor Collector Light Duty Diesel Vehicles (LDDV) Exhaust                     ‐   

St. Louis County 223000121X Rural Local Light Duty Diesel Vehicles (LDDV) Exhaust                 0.01

St. Louis County 223000123X Urban Interstate Light Duty Diesel Vehicles (LDDV) Exhaust                 1.34

St. Louis County 223000125X Urban 

Freeway/Expressway Light Duty Diesel Vehicles (LDDV) Exhaust                 0.30

St. Louis County 223000127X Urban Principal 

Arterial Light Duty Diesel Vehicles (LDDV) Exhaust                 0.80

St. Louis County 223000129X Urban Minor Arterial Light Duty Diesel Vehicles (LDDV) Exhaust                 0.53

St. Louis County 223000131X Urban Collector Light Duty Diesel Vehicles (LDDV) Exhaust                 0.28

St. Louis County 223000133X Urban Local Light Duty Diesel Vehicles (LDDV) Exhaust                 1.04

St. Louis County 223006000X Off-Network Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust              13.15

St. Louis County 223006011X Rural Interstate Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust                 0.18

St. Louis County 223006013X Rural Principal 

Arterial 

Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust                 0.86

St. Louis County 223006015X Rural Minor Arterial Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust                 0.41

St. Louis County 223006017X Rural Major Collector Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust                 0.79

St. Louis County 223006019X Rural Minor Collector Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust                     ‐   

St. Louis County 223006021X Rural Local Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust                 0.53

St. Louis County 223006023X Urban Interstate Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust              77.82

St. Louis County 223006025X Urban 

Freeway/Expressway

Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust              17.30
7 of 17 

Area SCC SCC Road Type SCC Vehicle Type 

SCC 

Process 

Type 

CO 

Emissions 

(tons/year) 

St. Louis County 223006027X Urban Principal 

Arterial 

Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust              44.94

St. Louis County 223006029X Urban Minor Arterial Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust              29.71

St. Louis County 223006031X Urban Collector Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust              15.84

St. Louis County 223006033X Urban Local Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust              58.50

St. Louis County 223007100X Off-Network Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust                 5.71

St. Louis County 223007111X Rural Interstate Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust                 0.08

St. Louis County 223007113X Rural Principal 

Arterial 

Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust                 0.38

St. Louis County 223007115X Rural Minor Arterial Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust                 0.18

St. Louis County 223007117X Rural Major Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust                 0.35

St. Louis County 223007119X Rural Minor Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust                     ‐   

St. Louis County 223007121X Rural Local Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust                 0.23

St. Louis County 223007123X Urban Interstate Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust              34.32

St. Louis County 223007125X Urban 

Freeway/Expressway

Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust                 7.63

St. Louis County 223007127X Urban Principal 

Arterial 

Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust              19.82

St. Louis County 223007129X Urban Minor Arterial Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust              13.10

St. Louis County 223007131X Urban Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust                 6.98

St. Louis County 223007133X Urban Local Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust              25.80

St. Louis County 223007200X Off-Network Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust              30.70

St. Louis County 223007211X Rural Interstate Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust                 0.43

St. Louis County 223007213X Rural Principal 

Arterial 

Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust                 2.07

St. Louis County 223007215X Rural Minor Arterial Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust                 0.98

St. Louis County 223007217X Rural Major Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust                 1.90
8 of 17 

Area SCC SCC Road Type SCC Vehicle Type 

SCC 

Process 

Type 

CO 

Emissions 

(tons/year) 

St. Louis County 223007219X Rural Minor Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust                     ‐   

St. Louis County 223007221X Rural Local Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust                 1.27

St. Louis County 223007223X Urban Interstate Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust            186.81

St. Louis County 223007225X Urban 

Freeway/Expressway

Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust              41.54

St. Louis County 223007227X Urban Principal 

Arterial 

Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust            107.92

St. Louis County 223007229X Urban Minor Arterial Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust              71.34

St. Louis County 223007231X Urban Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust              38.03

St. Louis County 223007233X Urban Local Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust            140.48

St. Louis County 223007300X Off-Network Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust              46.26

St. Louis County 223007311X Rural Interstate Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust                 0.59

St. Louis County 223007313X Rural Principal 

Arterial 

Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust                 2.60

St. Louis County 223007315X Rural Minor Arterial Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust                 1.23

St. Louis County 223007317X Rural Major Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust                 2.38

St. Louis County 223007319X Rural Minor Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust                     ‐   

St. Louis County 223007321X Rural Local Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust                 1.60

St. Louis County 223007323X Urban Interstate Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust            217.78

St. Louis County 223007325X Urban 

Freeway/Expressway

Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust              48.42

St. Louis County 223007327X Urban Principal 

Arterial 

Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust            116.12

St. Louis County 223007329X Urban Minor Arterial Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust              76.76

St. Louis County 223007331X Urban Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust              40.92

St. Louis County 223007333X Urban Local Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust            151.15

St. Louis County 223007400X Off-Network Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust            472.81
9 of 17 

Area SCC SCC Road Type SCC Vehicle Type 

SCC 

Process 

Type 

CO 

Emissions 

(tons/year) 

St. Louis County 223007411X Rural Interstate Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust                 2.31

St. Louis County 223007413X Rural Principal 

Arterial 

Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust                 9.68

St. Louis County 223007415X Rural Minor Arterial Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust                 4.58

St. Louis County 223007417X Rural Major Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust                 8.87

St. Louis County 223007419X Rural Minor Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust                     ‐   

St. Louis County 223007421X Rural Local Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust                 5.95

St. Louis County 223007423X Urban Interstate Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust            826.54

St. Louis County 223007425X Urban 

Freeway/Expressway

Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust            183.78

St. Louis County 223007427X Urban Principal 

Arterial 

Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust            431.19

St. Louis County 223007429X Urban Minor Arterial Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust            285.03

St. Louis County 223007431X Urban Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust            151.94

St. Louis County 223007433X Urban Local Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust            561.28

St. Louis County 223007500X Off-Network Heavy Duty Diesel Buses (School and 

Transit) Exhaust              32.97

St. Louis County 223007511X Rural Interstate Heavy Duty Diesel Buses (School and 

Transit) Exhaust                 0.19

St. Louis County 223007513X Rural Principal 

Arterial 

Heavy Duty Diesel Buses (School and 

Transit) Exhaust                 0.63

St. Louis County 223007515X Rural Minor Arterial Heavy Duty Diesel Buses (School and 

Transit) Exhaust                 0.30

St. Louis County 223007517X Rural Major Collector Heavy Duty Diesel Buses (School and 

Transit) Exhaust                 0.58

St. Louis County 223007519X Rural Minor Collector Heavy Duty Diesel Buses (School and 

Transit) Exhaust                     ‐   

St. Louis County 223007521X Rural Local Heavy Duty Diesel Buses (School and 

Transit) Exhaust                 0.39

St. Louis County 223007523X Urban Interstate Heavy Duty Diesel Buses (School and 

Transit) Exhaust              69.03

St. Louis County 223007525X Urban 

Freeway/Expressway

Heavy Duty Diesel Buses (School and 

Transit) Exhaust              15.35

St. Louis County 223007527X Urban Principal 

Arterial 

Heavy Duty Diesel Buses (School and 

Transit) Exhaust              22.90
10 of 17 

Area SCC SCC Road Type SCC Vehicle Type 

SCC 

Process 

Type 

CO 

Emissions 

(tons/year) 

St. Louis County 223007529X Urban Minor Arterial Heavy Duty Diesel Buses (School and 

Transit) Exhaust              15.14

St. Louis County 223007531X Urban Collector Heavy Duty Diesel Buses (School and 

Transit) Exhaust                 8.07

St. Louis County 223007533X Urban Local Heavy Duty Diesel Buses (School and 

Transit) Exhaust              29.81

St. Louis County Total 132,855.83

St. Louis City 220100100X Off-Network Light Duty Gasoline Vehicles (LDGV) Exhaust        5,479.03

St. Louis City 220100111X Rural Interstate Light Duty Gasoline Vehicles (LDGV) Exhaust                     ‐   

St. Louis City 220100113X Rural Principal 

Arterial Light Duty Gasoline Vehicles (LDGV) Exhaust                     ‐   

St. Louis City 220100115X Rural Minor Arterial Light Duty Gasoline Vehicles (LDGV) Exhaust                     ‐   

St. Louis City 220100117X Rural Major Collector Light Duty Gasoline Vehicles (LDGV) Exhaust                     ‐   

St. Louis City 220100119X Rural Minor Collector Light Duty Gasoline Vehicles (LDGV) Exhaust                     ‐   

St. Louis City 220100121X Rural Local Light Duty Gasoline Vehicles (LDGV) Exhaust                     ‐   

St. Louis City 220100123X Urban Interstate Light Duty Gasoline Vehicles (LDGV) Exhaust        2,813.60

St. Louis City 220100125X Urban 

Freeway/Expressway Light Duty Gasoline Vehicles (LDGV) Exhaust                     ‐   

St. Louis City 220100127X Urban Principal 

Arterial Light Duty Gasoline Vehicles (LDGV) Exhaust        1,206.30

St. Louis City 220100129X Urban Minor Arterial Light Duty Gasoline Vehicles (LDGV) Exhaust            797.84

St. Louis City 220100131X Urban Collector Light Duty Gasoline Vehicles (LDGV) Exhaust            425.96

St. Louis City 220100133X Urban Local Light Duty Gasoline Vehicles (LDGV) Exhaust        1,570.28

St. Louis City 220102000X Off-Network Light Duty Gasoline Trucks 1 & 2 Exhaust        3,609.69

St. Louis City 220102011X Rural Interstate Light Duty Gasoline Trucks 1 & 2 Exhaust                     ‐   

St. Louis City 220102013X Rural Principal 

Arterial Light Duty Gasoline Trucks 1 & 2 Exhaust                     ‐   

St. Louis City 220102015X Rural Minor Arterial Light Duty Gasoline Trucks 1 & 2 Exhaust                     ‐   

St. Louis City 220102017X Rural Major Collector Light Duty Gasoline Trucks 1 & 2 Exhaust                     ‐   
11 of 17 

Area SCC SCC Road Type SCC Vehicle Type 

SCC 

Process 

Type 

CO 

Emissions 

(tons/year) 

St. Louis City 220102019X Rural Minor Collector Light Duty Gasoline Trucks 1 & 2 Exhaust                     ‐   

St. Louis City 220102021X Rural Local Light Duty Gasoline Trucks 1 & 2 Exhaust                     ‐   

St. Louis City 220102023X Urban Interstate Light Duty Gasoline Trucks 1 & 2 Exhaust        3,617.21

St. Louis City 220102025X Urban 

Freeway/Expressway Light Duty Gasoline Trucks 1 & 2 Exhaust                     ‐   

St. Louis City 220102027X Urban Principal 

Arterial Light Duty Gasoline Trucks 1 & 2 Exhaust        1,448.26

St. Louis City 220102029X Urban Minor Arterial Light Duty Gasoline Trucks 1 & 2 Exhaust            957.87

St. Louis City 220102031X Urban Collector Light Duty Gasoline Trucks 1 & 2 Exhaust            511.40

St. Louis City 220102033X Urban Local Light Duty Gasoline Trucks 1 & 2 Exhaust        1,885.26

St. Louis City 220104000X Off-Network Light Duty Gasoline Trucks 3 and 4 Exhaust        1,859.54

St. Louis City 220104011X Rural Interstate Light Duty Gasoline Trucks 3 and 4 Exhaust                     ‐   

St. Louis City 220104013X Rural Principal 

Arterial Light Duty Gasoline Trucks 3 and 4 Exhaust                     ‐   

St. Louis City 220104015X Rural Minor Arterial Light Duty Gasoline Trucks 3 and 4 Exhaust                     ‐   

St. Louis City 220104017X Rural Major Collector Light Duty Gasoline Trucks 3 and 4 Exhaust                     ‐   

St. Louis City 220104019X Rural Minor Collector Light Duty Gasoline Trucks 3 and 4 Exhaust                     ‐   

St. Louis City 220104021X Rural Local Light Duty Gasoline Trucks 3 and 4 Exhaust                     ‐   

St. Louis City 220104023X Urban Interstate Light Duty Gasoline Trucks 3 and 4 Exhaust        1,863.41

St. Louis City 220104025X Urban 

Freeway/Expressway Light Duty Gasoline Trucks 3 and 4 Exhaust                     ‐   

St. Louis City 220104027X Urban Principal 

Arterial Light Duty Gasoline Trucks 3 and 4 Exhaust            746.08

St. Louis City 220104029X Urban Minor Arterial Light Duty Gasoline Trucks 3 and 4 Exhaust            493.45

St. Louis City 220104031X Urban Collector Light Duty Gasoline Trucks 3 and 4 Exhaust            263.45

St. Louis City 220104033X Urban Local Light Duty Gasoline Trucks 3 and 4 Exhaust            971.19

St. Louis City 220107000X Off-Network Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust            582.21
12 of 17 

Area SCC SCC Road Type SCC Vehicle Type 

SCC 

Process 

Type 

CO 

Emissions 

(tons/year) 

St. Louis City 220107011X Rural Interstate Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust                     ‐   

St. Louis City 220107013X Rural Principal 

Arterial 

Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust                     ‐   

St. Louis City 220107015X Rural Minor Arterial Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust                     ‐   

St. Louis City 220107017X Rural Major Collector Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust                     ‐   

St. Louis City 220107019X Rural Minor Collector Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust                     ‐   

St. Louis City 220107021X Rural Local Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust                     ‐   

St. Louis City 220107023X Urban Interstate Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust            606.29

St. Louis City 220107025X Urban 

Freeway/Expressway

Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust                     ‐   

St. Louis City 220107027X Urban Principal 

Arterial 

Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust            254.42

St. Louis City 220107029X Urban Minor Arterial Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust            168.27

St. Louis City 220107031X Urban Collector Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust              89.84

St. Louis City 220107033X Urban Local Heavy Duty Gasoline Vehicles 2B thru 

8B and Gasoline Buses Exhaust            331.19

St. Louis City 220108000X Off-Network Motorcycles (MC) Exhaust              13.15

St. Louis City 220108011X Rural Interstate Motorcycles (MC) Exhaust                     ‐   

St. Louis City 220108013X Rural Principal 

Arterial Motorcycles (MC) Exhaust                     ‐   

St. Louis City 220108015X Rural Minor Arterial Motorcycles (MC) Exhaust                     ‐   

St. Louis City 220108017X Rural Major Collector Motorcycles (MC) Exhaust                     ‐   

St. Louis City 220108019X Rural Minor Collector Motorcycles (MC) Exhaust                     ‐   

St. Louis City 220108021X Rural Local Motorcycles (MC) Exhaust                     ‐   

St. Louis City 220108023X Urban Interstate Motorcycles (MC) Exhaust            242.33

St. Louis City 220108025X Urban 

Freeway/Expressway Motorcycles (MC) Exhaust                     ‐   

St. Louis City 220108027X Urban Principal 

Arterial Motorcycles (MC) Exhaust              97.39
13 of 17 

Area SCC SCC Road Type SCC Vehicle Type 

SCC 

Process 

Type 

CO 

Emissions 

(tons/year) 

St. Louis City 220108029X Urban Minor Arterial Motorcycles (MC) Exhaust              64.41

St. Louis City 220108031X Urban Collector Motorcycles (MC) Exhaust              34.39

St. Louis City 220108033X Urban Local Motorcycles (MC) Exhaust            126.78

St. Louis City 223000100X Off-Network Light Duty Diesel Vehicles (LDDV) Exhaust                 0.71

St. Louis City 223000111X Rural Interstate Light Duty Diesel Vehicles (LDDV) Exhaust                     ‐   

St. Louis City 223000113X Rural Principal 

Arterial Light Duty Diesel Vehicles (LDDV) Exhaust                     ‐   

St. Louis City 223000115X Rural Minor Arterial Light Duty Diesel Vehicles (LDDV) Exhaust                     ‐   

St. Louis City 223000117X Rural Major Collector Light Duty Diesel Vehicles (LDDV) Exhaust                     ‐   

St. Louis City 223000119X Rural Minor Collector Light Duty Diesel Vehicles (LDDV) Exhaust                     ‐   

St. Louis City 223000121X Rural Local Light Duty Diesel Vehicles (LDDV) Exhaust                     ‐   

St. Louis City 223000123X Urban Interstate Light Duty Diesel Vehicles (LDDV) Exhaust                 0.42

St. Louis City 223000125X Urban 

Freeway/Expressway Light Duty Diesel Vehicles (LDDV) Exhaust                     ‐   

St. Louis City 223000127X Urban Principal 

Arterial Light Duty Diesel Vehicles (LDDV) Exhaust                 0.26

St. Louis City 223000129X Urban Minor Arterial Light Duty Diesel Vehicles (LDDV) Exhaust                 0.17

St. Louis City 223000131X Urban Collector Light Duty Diesel Vehicles (LDDV) Exhaust                 0.09

St. Louis City 223000133X Urban Local Light Duty Diesel Vehicles (LDDV) Exhaust                 0.34

St. Louis City 223006000X Off-Network Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust                 2.65

St. Louis City 223006011X Rural Interstate Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust                     ‐   

St. Louis City 223006013X Rural Principal 

Arterial 

Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust                     ‐   

St. Louis City 223006015X Rural Minor Arterial Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust                     ‐   

St. Louis City 223006017X Rural Major Collector Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust                     ‐   

St. Louis City 223006019X Rural Minor Collector Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust                     ‐   
14 of 17 

Area SCC SCC Road Type SCC Vehicle Type 

SCC 

Process 

Type 

CO 

Emissions 

(tons/year) 

St. Louis City 223006021X Rural Local Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust                     ‐   

St. Louis City 223006023X Urban Interstate Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust              25.39

St. Louis City 223006025X Urban 

Freeway/Expressway

Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust                     ‐   

St. Louis City 223006027X Urban Principal 

Arterial 

Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust              15.06

St. Louis City 223006029X Urban Minor Arterial Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust                 9.96

St. Louis City 223006031X Urban Collector Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust                 5.32

St. Louis City 223006033X Urban Local Light Duty Diesel Trucks 1 thru 4 

(LDDT) Exhaust              19.61

St. Louis City 223007100X Off-Network Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust                 1.15

St. Louis City 223007111X Rural Interstate Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust                     ‐   

St. Louis City 223007113X Rural Principal 

Arterial 

Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust                     ‐   

St. Louis City 223007115X Rural Minor Arterial Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust                     ‐   

St. Louis City 223007117X Rural Major Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust                     ‐   

St. Louis City 223007119X Rural Minor Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust                     ‐   

St. Louis City 223007121X Rural Local Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust                     ‐   

St. Louis City 223007123X Urban Interstate Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust              11.19

St. Louis City 223007125X Urban 

Freeway/Expressway

Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust                     ‐   

St. Louis City 223007127X Urban Principal 

Arterial 

Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust                 6.63

St. Louis City 223007129X Urban Minor Arterial Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust                 4.39

St. Louis City 223007131X Urban Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust                 2.34

St. Louis City 223007133X Urban Local Heavy Duty Diesel Vehicles (HDDV) 

Class 2B Exhaust                 8.64

St. Louis City 223007200X Off-Network Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust                 6.19

St. Louis City 223007211X Rural Interstate Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust                     ‐   
15 of 17 

Area SCC SCC Road Type SCC Vehicle Type 

SCC 

Process 

Type 

CO 

Emissions 

(tons/year) 

St. Louis City 223007213X Rural Principal 

Arterial 

Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust                     ‐   

St. Louis City 223007215X Rural Minor Arterial Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust                     ‐   

St. Louis City 223007217X Rural Major Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust                     ‐   

St. Louis City 223007219X Rural Minor Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust                     ‐   

St. Louis City 223007221X Rural Local Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust                     ‐   

St. Louis City 223007223X Urban Interstate Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust              61.09

St. Louis City 223007225X Urban 

Freeway/Expressway

Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust                     ‐   

St. Louis City 223007227X Urban Principal 

Arterial 

Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust              36.26

St. Louis City 223007229X Urban Minor Arterial Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust              23.98

St. Louis City 223007231X Urban Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust              12.80

St. Louis City 223007233X Urban Local Heavy Duty Diesel Vehicles (HDDV) 

Class 3, 4, and 5 Exhaust              47.20

St. Louis City 223007300X Off-Network Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust              14.50

St. Louis City 223007311X Rural Interstate Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust                     ‐   

St. Louis City 223007313X Rural Principal 

Arterial 

Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust                     ‐   

St. Louis City 223007315X Rural Minor Arterial Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust                     ‐   

St. Louis City 223007317X Rural Major Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust                     ‐   

St. Louis City 223007319X Rural Minor Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust                     ‐   

St. Louis City 223007321X Rural Local Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust                     ‐   

St. Louis City 223007323X Urban Interstate Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust              69.65

St. Louis City 223007325X Urban 

Freeway/Expressway

Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust                     ‐   

St. Louis City 223007327X Urban Principal 

Arterial 

Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust              38.13

St. Louis City 223007329X Urban Minor Arterial Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust              25.22
16 of 17 

Area SCC SCC Road Type SCC Vehicle Type 

SCC 

Process 

Type 

CO 

Emissions 

(tons/year) 

St. Louis City 223007331X Urban Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust              13.47

St. Louis City 223007333X Urban Local Heavy Duty Diesel Vehicles (HDDV) 

Class 6 and 7 Exhaust              49.64

St. Louis City 223007400X Off-Network Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust            136.61

St. Louis City 223007411X Rural Interstate Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust                     ‐   

St. Louis City 223007413X Rural Principal 

Arterial 

Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust                     ‐   

St. Louis City 223007415X Rural Minor Arterial Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust                     ‐   

St. Louis City 223007417X Rural Major Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust                     ‐   

St. Louis City 223007419X Rural Minor Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust                     ‐   

St. Louis City 223007421X Rural Local Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust                     ‐   

St. Louis City 223007423X Urban Interstate Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust            263.29

St. Louis City 223007425X Urban 

Freeway/Expressway

Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust                     ‐   

St. Louis City 223007427X Urban Principal 

Arterial 

Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust            139.88

St. Louis City 223007429X Urban Minor Arterial Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust              92.51

St. Louis City 223007431X Urban Collector Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust              49.39

St. Louis City 223007433X Urban Local Heavy Duty Diesel Vehicles (HDDV) 

Class 8A and 8B Exhaust            182.08

St. Louis City 223007500X Off-Network Heavy Duty Diesel Buses (School and 

Transit) Exhaust                 9.88

St. Louis City 223007511X Rural Interstate Heavy Duty Diesel Buses (School and 

Transit) Exhaust                     ‐   

St. Louis City 223007513X Rural Principal 

Arterial 

Heavy Duty Diesel Buses (School and 

Transit) Exhaust                     ‐   

St. Louis City 223007515X Rural Minor Arterial Heavy Duty Diesel Buses (School and 

Transit) Exhaust                     ‐   

St. Louis City 223007517X Rural Major Collector Heavy Duty Diesel Buses (School and 

Transit) Exhaust                     ‐   

St. Louis City 223007519X Rural Minor Collector Heavy Duty Diesel Buses (School and 

Transit) Exhaust                     ‐   

St. Louis City 223007521X Rural Local Heavy Duty Diesel Buses (School and 

Transit) Exhaust                     ‐   
17 of 17 

Area SCC SCC Road Type SCC Vehicle Type 

SCC 

Process 

Type 

CO 

Emissions 

(tons/year) 

St. Louis City 223007523X Urban Interstate Heavy Duty Diesel Buses (School and 

Transit) Exhaust              28.04

St. Louis City 223007525X Urban 

Freeway/Expressway

Heavy Duty Diesel Buses (School and 

Transit) Exhaust                     ‐   

St. Louis City 223007527X Urban Principal 

Arterial 

Heavy Duty Diesel Buses (School and 

Transit) Exhaust                 9.69

St. Louis City 223007529X Urban Minor Arterial Heavy Duty Diesel Buses (School and 

Transit) Exhaust                 6.41

St. Louis City 223007531X Urban Collector Heavy Duty Diesel Buses (School and 

Transit) Exhaust                 3.42

St. Louis City 223007533X Urban Local Heavy Duty Diesel Buses (School and 

Transit) Exhaust              12.61

St. Louis City Total 34,576.81

Combined Total For St. Louis County and St. Louis City 167,432.64
Appendix A-3 

Nonroad 2008 Inventory Documentation for the Emissions Inventory Methodology for 

Commercial Marine Vessels, Locomotives, and Aircrafts 

 Documentation of the Commercial Marine Vessel Component of the National 

Emissions Inventory Methodology 

 Documentation of the Locomotive Component of the National Emissions 

Inventory Methodology 

 Documentation of the Aircraft Component of the National Emissions Inventory 

Methodology 
ERG No.: 0245.02.302.001 

Contract No.: EP-D-07-097 

Documentation for the Commercial Marine Vessel Component 

of the National Emissions Inventory 

Methodology 

Prepared by: 

Eastern Research Group 

1600 Perimeter Park Drive 

Morrisville, North Carolina 27560 

Under Contract to: 

E.H. Pechan & Associates, Inc. 

3622 Lyckan Parkway 

Suite 2002 

Durham, North Carolina 27707 

For Submittal to: 

Laurel Driver 

Emissions, Monitoring and Analysis Division 

U.S. Environmental Protection Agency 

Research Triangle Park, North Carolina 27711 

March 30, 2010 
TABLE OF CONTENTS 

Section Page No. 

1.0 INTRODUCTION........................................................................................................... 1-1 

1.1 What is the National Emission Inventory? .......................................................... 1-1 

1.2 Why Did the EPA Create the NEI?...................................................................... 1-1 

1.3 How is the EPA Going to Use This Version of the NEI?....................................1-1 

1.4 Report Organization............................................................................................. 1-2 

2.0 DEVELOPMENT OF THE COMMERCIAL MARINE VESSEL COMPONENT FOR 

THE NEI.......................................................................................................................... 2-1 

2.1 How Does This CMV Study Fit into the NEI? .................................................... 2-1 

2.2 What are Commercial Marine Vessels?............................................................. 2-10 

2.3 What Pollutants are Included in the National Emission Estimates for CMVs?.2-11 

2.4 How Were the CMV Emissions Estimated?...................................................... 2-11 

2.5 How Were Emissions Allocated? ...................................................................... 2-14 

2.6 How Were Port Emissions Allocated?............................................................... 2-14 

2.7 How Were Underway Emissions Allocated?..................................................... 2-15 

2.7.1 Category 1 and 2 Underway .................................................................. 2-15 

2.7.2 Category 3 Reduced Speed Zones (RSZ) .............................................. 2-15 

2.7.3 Category 3 Approach ............................................................................. 2-15 

2.7.4 Category 3 Interport............................................................................... 2-16 

2.8 QA/QC............................................................................................................... 2-16 

2.9 What are the Results?......................................................................................... 2-17 

2.10 Commercial Marine Vessel References............................................................. 2-19 

Appendix A – 2008 Category 3 Commercial Marine Vessel Inventory Methodology 

Appendix B – 2008 Commercial Marine Vessel HAP Speciation Profiles 

i 
LIST OF TABLES AND FIGURES 

Tables Page No. 

Table 2-2. Commercial Marine Vessel Pollutant List ............................................................... 2-12 

Table 2-3. Commercial Marine Vessel Criteria and Greenhouse Gas Emission Estimates 2008 

 (TPY).............................................................................................................................2-17 

Table 2-4. Commercial Marine Vessel HAP Emission Estimates 2008 (TPY) ........................ 2-18 

Figures Page No. 

Figure 2-1. General Approach Used to Develop Marine Vessel Component of the 2008 National 

 Emission Inventory........................................................................................................2-13

ii 
1.0 INTRODUCTION 

1.1 What is the National Emission Inventory? 

The National Emission Inventory (NEI) is a comprehensive inventory covering all 

anthropogenic sources of criteria pollutants and hazardous air pollutants (HAPs) for all areas of 

the United States. The NEI was created by the U.S. Environmental Protection Agency’s 

Emission Inventory and Analysis Group (EIAG) in Research Triangle Park, North Carolina. The 

NEI will be used to support air quality modeling and other activities. To this end, the EPA 

established a goal to compile comprehensive emissions data in the NEI for criteria and HAPs for 

mobile, point, and nonpoint sources. This report presents an overview of how emission estimates 

for the commercial marine vessel (CMV) component of the 2008 NEI was compiled. 

1.2 Why Did the EPA Create the NEI? 

The Clean Air Act (CAA), as amended in 1990, includes mandates for the EPA related to 

criteria and hazardous air pollutants. The CAA defines criteria pollutants as being one of the 

following air pollutants: 

• Carbon monoxide (CO); 

• Sulfur oxides (SOx); 

• Nitrogen oxides (NOx); 

• Ozone; and 

• Particulate matter (PM). 

 Where emission factors and activity data permit, ammonia (NH3) estimates are also 

included as an important precursor to PM. Hazardous air pollutants are also delineated in the 

CAA, see http://www.epa.gov/ttn/atw/188polls.html for a complete list of regulated pollutants 

and their chemical abstract service [CAS] numbers. 

 The CAA requires the EPA to identify emission sources of these pollutants, quantify 

emissions, develop regulations for the identified source categories, and assess the public health 

and environmental impacts after the regulations are put into effect. The NEI is a tool that EPA 

can use to meet the CAA mandates. In this report, criteria and HAP emission estimates are 

discussed for CMV sources. 

1.3 How is the EPA Going to Use This Version of the NEI? 

 It is anticipated that the emission inventory developed from this effort will have multiple 

end uses. The data have been formatted according to protocols established for the EPA’s NEI 

submittals. The common data structure on which the NEI platform is based will allow the NEI 

emission data to be transferred to multiple end-users for a variety of purposes. 

1-1 
The criteria and HAP emission estimates developed for the NEI will be used to evaluate 

air pollution trends, air quality modeling analysis and impacts of potential regulations. 

1.4 Report Organization 

 Following this introduction, Section 2.0 provides information on how the national CMV, 

emission estimates were developed. This inventory effort was coordinated by the EPA’s Office 

of Transportation and Air Quality (OTAQ) and EIAG. 

 The appendix were created to provide technical details on how the national emissions 

were developed and how state and local inventory data (when provided) were incorporated into 

the national estimates. Appendix A provides a copy of the report documenting how the 2002 data 

were adjusted to reflect marine vessel activity and emissions for 2008. 

1-2 
2.0 DEVELOPMENT OF THE COMMERCIAL MARINE VESSEL 

COMPONENT FOR THE NEI 

2.1 How Does This CMV Study Fit into the NEI? 

The NEI was developed to include all point, nonpoint (sometimes referenced as “area”), 

and mobile sources. The approaches used in the point and nonpoint source categories are 

documented in other reports. Table 1 summarizes the approaches used to estimate emissions 

from all nonroad sources included in the NEI program. Those source categories and years that 

are included in this report are noted in bold. 

 The scope of this inventory component of the NEI was to compile criteria and HAP 

emissions data for CMVs operating in United States waters and federal waters extending 200 

nautical miles from the United States’ coastline. In this effort, national emission estimates were 

often developed and allocated to counties based on available Geographic Information System 

(GIS) data. The methodologies used to estimate emissions and the procedures used to spatially 

allocate them to the county-level are discussed in this report. 

Table 2-1. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method*

NONROAD Categories

Nonroad 

Gasoline, 

Diesel, LPG, 

CNG 

2002 VOC, NOx, CO, 

SO2, PM10, PM2.5, 

NH3, & HAPs 

Emission estimates for NONROAD model 

engines were developed using EPA’s National 

Mobile Inventory Model (NMIM), which 

incorporates NONROAD2004. Where states 

provided alternate nonroad inputs, these data 

replaced EPA default inputs. State-supplied 

emissions data also replaced default EPA 

emission estimates. 

2-1 
Table 2-1. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources (Continued)

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method*

1999 VOC, NOx, CO, 

SO2, PM10, PM2.5

Using emission estimates from two emission 

inventories including: 1) a 1996 county-level 

inventory, developed using EPA’s October 

2001 draft NONROAD model; and 2) an 

updated 1999 national inventory, based on 

EPA’s draft Lockdown C NONROAD model 

(dated May 2002). Using the 1996 county-level 

emission estimates, seasonal and daily countyto-national ratios were then developed for 

application to updated national estimates per 

season estimated from the Lockdown C model. 

Replaced State-submitted data for California for 

all NONROAD model categories; Pennsylvania 

for recreational marine and aircraft ground 

support equipment, and Texas for select 

equipment categories. 

1996, 1997, 

1998, 2000 

& 2001 

VOC, NOx, CO, 

SO2, PM10, PM2.5

Using emission estimates from two emission 

inventories including: 1) a 1996 county-level 

inventory, developed using EPA’s October 

2001 draft NONROAD model; and 2) updated 

year-specific national and California 

inventories, based on EPA’s draft Lockdown C 

NONROAD model (dated May 2002). Using 

the 1996 county-level emission estimates, 

seasonal and daily county-to-national ratios and 

California county-to-state ratios were then 

developed for application to updated national 

estimates per season estimated from the 

Lockdown C model. California results replace 

the diesel equipment emissions generated from 

prior application of county-to-national ratios. 

2-2 
Table 2-1. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources (Continued)

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method*

Nonroad 

Gasoline, 

Diesel, LPG, 

and CNG 

(Continued) 

1991-1995 VOC, NOx, CO, 

SO2, PM10, PM2.5, 

NH3 

Using 1990 and 1996 county-level emissions 

inventories, estimated emissions using linear 

interpolation of national emissions between 

1990 and 1996. From these emissions, 

calculated the average annual growth rate for 

each pollutant/SCC combination for each year, 

and then applied the growth factors to 1990 

county-level emissions to estimate 1991-1995 

emissions. 

1990 VOC, NOx, CO, 

SO2, PM10, PM2.5

Using emission estimates from two emission 

inventories including: 1) a 1996 county-level 

inventory, developed using EPA’s October 

2001 draft NONROAD model; and 2) updated 

1990 national inventory, based on EPA’s draft 

Lockdown C NONROAD model (dated May 

2002). Using the 1996 county-level emission 

estimates, seasonal and daily county-to-national 

ratios were then developed for application to 

updated national estimates per season estimated 

from the Lockdown C model. 

1986, 1988, 

& 1989 

VOC, NOx, CO, 

SO2, PM10, PM2.5, 

NH3 

Using 1985 and 1990 county-level emissions 

inventories, estimated emissions using linear 

interpolation of national emissions between 

1985 and 1990. From these emissions, 

calculated the average annual growth rate for 

each pollutant/SCC combination for each year, 

and then applied the growth factors to 1985 

county-level emissions to estimate 1986-1989 

emissions. 

1987 VOC, NOx, CO, 

SO2, PM10, PM2.5

Using EPA’s draft Lockdown C NONROAD 

model (dated May 2002), developed updated 

national emissions for 1987 by running 4 

seasonal NONROAD model runs to estimate 

annual criteria pollutant emissions. Also 

performed national NONROAD model runs to 

estimate typical summer weekday emissions. 

2-3 
Table 2-1. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources (Continued)

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method*

Nonroad 

Gasoline, 

Diesel, LPG, 

and CNG 

(Continued) 

1985 VOC, NOx, CO, 

SO2, PM10, PM2.5

Using emission estimates from two emission 

inventories including: 1) a 1996 county-level 

inventory, developed using EPA’s October 

2001 draft NONROAD model; and 2) updated 

1985 national inventory, based on EPA’s draft 

Lockdown C NONROAD model (dated May 

2002). Using the 1996 county-level emission 

estimates, seasonal and daily county-to-national 

ratios were then developed for application to 

updated national estimates per season estimated 

from the Lockdown C model. 

1970, 1975, 

1978, & 

1980 

VOC, NOx, CO, 

SO2, PM10, PM2.5

Using EPA’s draft Lockdown C NONROAD 

model (dated May 2002), developed updated 

national emissions for all years by running 4 

seasonal NONROAD model runs to estimate 

annual criteria pollutant emissions. Also 

performed national NONROAD model runs to 

estimate typical summer weekday emissions. 

1996, 1997, 

1998, 1999, 

2000, & 

2001 

NH3 Obtaining national fuel consumption estimates 

from the Lockdown C NONROAD model, 

multiplying by NH3 emission factors, and 

distributing to counties using 1996 inventory, 

based on October 2001 draft NONROAD. NH3

emissions for California were also recalculated 

using updated diesel fuel consumption values 

generated for California-specific runs, and 

assuming the 1996 county-level distribution. 

1985 & 1990 NH3 Obtaining national fuel consumption estimates 

from the Lockdown C NONROAD model, 

multiplying by NH3 emission factors, and 

distributing to counties using 1996 inventory, 

based on October 2001 draft NONROAD. 

1987 NH3 Obtaining 1987 national fuel consumption 

estimates from Lockdown C NONROAD model 

and multiplying by NH3 emission factors. 

2-4 
Table 2-1. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources (Continued)

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method*

Nonroad 

Gasoline, 

Diesel, LPG, 

and CNG 

(Continued) 

1970, 1975, 

1978, & 

1980 

NH3 Obtaining national fuel consumption estimates 

from the Lockdown C NONROAD model and 

multiplying by NH3 emission factors. 

1990, 1996, 

& 1999 

HAPs Speciation profiles applied to county VOC and 

PM estimates. Metal HAPs were calculated 

using fuel and activity-based emission factors. 

Some state data were provided and replaced 

national estimates. (2003) 

Aircraft

Commercial 

Aircraft 

2008 Criteria and HAPsFederal Aviation Administration (FAA) 

Emissions and Dispersion and Modeling System

(EDMS) - Version 5.1.was run using BTS T100 LTO data. (2009) 

2002 Criteria and HAPsFederal Aviation Administration (FAA) 

Emissions and Dispersion and Modeling System

(EDMS) was run for criteria pollutants, VOC 

and PM emissions were speciated into HAP 

components. (2004) 

1990, 1996, 

1999, 2000, 

2001 

VOC, NOx, CO, 

SOx

Input landing and take-off (LTO) data into FAA 

EDMS. National emissions were assigned to 

airports based on airport specific LTO data and 

BTS GIS data. State data replaced national 

estimates. (2003) 

1970-1998 VOC, NOx, CO, 

SOx

Estimated emissions for interim years using 

linear interpolation between available base 

years. (2003) 

1990, 1996, 

1999 

HAPs Speciation profiles were applied to VOC 

estimates to get national HAP estimates. State 

data replaced national estimates. (2003) 

General 

Aviation, Air 

Taxis 

2008 Criteria and HAPsUsed FAA LTO data from TAF and OTAQ 

provided activity data for smaller airports 

derived from FAA 5010 master plans. EPA 

approved generic emission factors for criteria 

estimates. Speciation profiles were applied to 

VOC and PM estimates to get national HAP 

estimates. (2009) 

2-5 
Table 2-1. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources (Continued)

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method*

General 

Aviation, Air 

Taxis 

(Continued) 

1978, 1987, 

1990, 1996, 

1999, 2000, 

2001, & 

2002 

VOC, NOx, CO, 

SO2, PM10, PM2.5

Used FAA LTO data and EPA approved 

emission factors for criteria estimates. 

Speciation profiles were applied to VOC 

estimates to get national HAP estimates. State 

data replaced national estimates. (2004) 

1970-1998 VOC, NOx, CO, 

SOx, PM10, PM2.5

Estimated emissions for interim years using 

linear interpolation between available base 

years. (2003) 

1990, 1996, 

1999, & 

2002 

HAPs Used FAA LTO data and EPA approved 

emission factors for criteria estimates. 

Speciation profiles were applied to VOC 

estimates to develop national HAP estimates. 

(2004) 

1990, 1996, 

1999, & 

2002 

Pb Used Department of Energy (DOE) aviation 

gasoline usage data with lead concentration of 

aviation gasoline. (2004) 

1996 NH3 Applied NH3 emissions factors to 1996 national 

jet fuel and aviation gasoline consumption 

estimates. 

Military 

Aircraft 

1978, 1987, 

1990, 1996, 

1999, 2000, 

2001, 2002, 

2008 

VOC, NOx, CO, 

SO2, PM10, PM2.5

Used FAA LTO data as reported in TAF and 

EPA approved emission factors for criteria 

estimates. Representative HAP profiles were 

not readily available, therefore HAP estimates 

were not developed. (2009) 

1970-1998 VOC, NOx, CO, 

SOX, PM10, PM2.5

Estimated emissions for interim years using 

linear interpolation between available base 

years. (2003) 

Auxiliary 

Power Units 

2008 VOC, NOx, CO, 

SO2, PM10, PM2.5

Federal Aviation Administration (FAA) 

Emissions and Dispersion and Modeling System

(EDMS) - Version 5.1.was run using BTS T100 LTO data. (2009) 

1985-2001 VOC, NOx, CO, 

SO2, PM10, PM2.5

Grew 1996 emissions to each year using LTO 

operations data from the FAA. Estimation 

methods prior to 1996 reported in EPA, 1998. 

2-6 
Table 2-1. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources (Continued)

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method*

Unpaved 

Airstrips1

1985-2001 PM10, PM2.5 Grew 1996 emissions to each year using SIC 45-

Air Transportation growth factors, consistent with 

the current draft version of EGAS. Estimation 

methods prior to 1996 reported in EPA, 1998. 

Aircraft 

Refueling1

1985-2001 VOC Grew 1996 emissions to each year using SIC 45-

Air Transportation growth factors, consistent with 

the current draft version of EGAS. Estimation 

methods prior to 1996 reported in EPA, 1998. 

Commercial Marine Vessel (CMV)

All CMV 

Categories 

2008 VOC, NOx, CO, 

SO2, PM10, PM2.5

2002 estimates were adjusted by OTAQ to 

reflect 2008 activity levels., note that the SCCs 

for this category have changed such that the 

Diesel category refers to smaller vessels 

(Category 1 and 2) using distillate fuels and the 

Residual category refers to larger (Category 3) 

vessel using a blend of residual fuels (2009) 

2008 HAPs OTAQ’s 2008 estimates were speciated into 

HAP components using SEPA profiles 

2002 VOC, NOx, CO, 

SO2, PM10, PM2.5

2001 Estimates carried over. Used state data when 

provided. (2004) 

HAPs 1999 Estimates carried over. Used state data when 

provided. (2004) 

CMV Diesel 1978, 1987, 

1990, 1996, 

1999, 2000, 

& 2001 

VOC, NOx, CO, 

SOx, PM10, & 

PM2.5 

Used criteria emission estimates in the 

background document for marine diesel 

regulations for 2000. Adjusted 2000 criteria 

emission estimates for other used based on fuel 

usage. Emissions were disaggregated into port 

traffic and underway activities. Port emissions 

were assigned to specific ports based on amount 

of cargo handled. Underway emissions were 

allocated based on Army Corp of Engineering 

waterway data. State data replaced national 

estimates. (2003) 

1970-1998 VOC, NOx, CO, 

SOx, PM10, PM2.5

Estimated emissions for interim years using linear 

interpolation between available base years. (2003)

1990, 1996, 

1999 

HAPs VOC and PM emission estimates were speciated 

into HAP components. State data replaced 

national estimates. (2003) 

2-7 
Table 2-1. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources (Continued)

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method*

1996 NH3 Applied NH3 emissions factors to 1996 distillate 

and residual fuel oil estimates (i.e., as reported in 

EIA, 1996). 

1990-1995 NH3 Estimation methods reported in EPA, 1998. 

CMV Steam 

Powered 

1978, 1987, 

1990, 1996, 

1999, 2000, 

& 2001 

VOC, NOx, CO, 

SOx, PM10, & 

PM2.5

Calculated criteria emissions based on EPA SIP 

guidance. Emissions were disaggregated into port 

traffic and under way activities. Port emissions 

were assigned to specific ports based on amount 

of cargo handled. Underway emissions were 

allocated based on Army Corp of Engineering 

waterway data. State data replaced national 

estimates. (2003) 

1970-1998 VOC, NOx, CO, 

SOx, PM10, PM2.5 

Estimated emissions for interim years using linear 

interpolation between available base years. (2003)

1990, 1996, 

& 1999 

HAPs VOC and PM emission estimates were speciated 

into HAP components. State data replaced 

national estimates. (2003) 

Military Marine 1997-2001 VOC, NOx, CO, 

SO2, PM10, PM2.5

Applied EGAS growth factors to 1996 emissions 

estimates for this category. 

CMV Coal,2

CMV, Steam 

powered, CMV 

Gasoline2

1997-1998 VOC, NOx, CO, 

SO2, PM10, PM2.5

Applied EGAS growth factors to 1996 emissions 

estimates for this category. 

CM Coal, CMV, 

Steam powered, 

CMV Gasoline, 

Military Marine 

1991-1995 VOC, NOx, CO, 

SO2, PM10, PM2.5

Estimation methods reported in EPA, 1998. 

Locomotives

Class I, Class II, 

Commuter, 

Passenger, and 

Yard 

Locomotives 

1978, 1987, 

1990, 1996, 

1999, 2000, 

2000, & 

2002 

VOC, NOx, CO, 

PM10, PM2.5

Criteria pollutants were estimated by using 

locomotive fuel use data from DOE EIA and 

available emission factors. County-level estimates 

were obtained by scaling the national estimates 

with the rail GIS data from DOT. State data 

replaced national estimates. (2004) 

2-8 
Table 2-1. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources (Continued)

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method*

Class I, Class 

II, Commuter, 

Passenger, and 

Yard 

Locomotives 

(Continued) 

1978, 1987, 

1990, 1996, 

1999, 2000, 

2001, & 

2002 

SO2 SOx emissions were calculated by using 

locomotive fuel use and fuel sulfur 

concentration data from EIA. County-level 

estimates were obtained by scaling the national 

estimates with the county level rail activity data 

from DOT. State data replaced national 

estimates. (2004) 

1970-1998 VOC, NOx, CO, 

SOx, PM10, PM2.5

Estimated emissions for interim years using 

linear interpolation between available base 

years. (2003) 

1990, 1996, 

1999, & 

2002 

HAPs HAP emissions were calculated by applying 

speciation profiles to VOC and PM estimates. 

County-level estimates were obtained by 

scaling the national estimates with the county 

level rail activity from DOT. State data replaced 

national estimates. (2004) 

1997-1998 NH3 Grew 1996 base year emissions using EGAS 

growth indicators. 

1996 NH3 Applied NH3 emissions factors to diesel 

consumption estimates for 1996. 

1990-1995 NH3 Estimation methods reported in EPA, 1998. 

Notes: 

* Dates included at the end of Estimation Method represent the year that the section was revised. 

1 Emission estimates for unpaved airstrips and aircraft refueling are included in the area source NEI, since they 

represent non-engine emissions. 

2 National Emission estimates for CMV Coal and CMV Gasoline were not developed though states and local 

agencies may have submitted estimates for these source categories. 

EPA, 1998. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Emission 

Factors and Inventory Group, National Air Pollutant Emission Trends, Procedures Document, 1900–1996, EPA454/R-98-008. May 1998. 

2-9 
 The target inventory area includes every state in the United States and every county 

within a state. There are no boundary limitations pertaining to traditional criteria pollutant 

nonattainment areas or to designated urban areas. The pollutants inventoried included all criteria 

pollutants (except for the other nonroad source category which addressed only HAPs in this 

report) and the 188 HAPs identified in Section 112(b) of the CAA. Some state or local agencies 

provided emissions information on more HAPs than those delineated in the CAA, only the 

federally regulated HAPs are included in the NEI. 

 In addition to numerous specific chemical compounds, the list of 188 HAPs includes 

several compound groups [e.g., individual metals and their compounds, polycyclic organic 

matter (POM)]; the NEI includes emission estimates for the individual compounds wherever 

possible. Many of the uses of the NEI depend upon data (e.g., toxicity) for individual compounds 

within these groups rather than aggregated data on each group as a whole. 

 The intent in presenting the following emission inventory approach is to provide 

sufficient and transparent documentation such that states and local agencies can use these 

approaches, in conjunction with their specific local activity data to develop more accurate and 

comparable emission estimates in future submittals. 

2.2 What are Commercial Marine Vessels? 

 The CMV source category includes all boats and ships used either directly or indirectly in 

the conduct of commerce or military activity. These vessels range from 20-foot charter boats to 

large tankers which can exceed 1,000 feet in length (EPA, 1989). In spite of the broad range of 

vessels represented by this category, a number of common characteristics allow for the use of 

simple emission estimation methods. The majority of vessels in this category are powered by 

diesel engines that are either fueled with distillate or residual fuel oil blends. For the purpose of 

this inventory it is assumed that Category 3 vessels primarily use residual blends while Category 

1 and 2 vessels typically used distillate fuels. 

The Category 3 (C3) inventory developed by OTAQ includes vessels which use C3 

engines for propulsion. C3 engines are defined as having displacement above 30 liters per 

cylinder (U.S. EPA, 2003). The resulting inventory includes emissions from both propulsion and 

auxiliary engines used on these vessels, as well as those on gas and steam turbine vessels. 

Geographically, the inventories include port and interport emissions that occur within the area 

that extends 200 nautical miles (nm) from the official U.S. baseline, which is roughly equivalent 

to the border of the U.S. Exclusive Economic Zone (EEZ). 

Category 1 and 2 vessels tend to be smaller ships that operate closer to shore, and along 

inland and intercoastal waterways. Naval vessels are not included in this inventory, though Coast 

Guard vessels are included as Category 1 and 2 vessels. 

 The CMV source category does not include recreational marine vessels, which are 

generally less than 100 feet in length, most being less than 30 feet, and powered by either 

inboard or outboard engines (EPA, 1989). Emissions from recreational marine vessels are 

included in the nonroad source category. 

2-10 
2.3 What Pollutants are Included in the National Emission Estimates for CMVs? 

 The EPA’s Office of Transportation and Air Quality (OTAQ) provided estimates for all 

criteria pollutants including volatile organic compounds (VOC), nitrogen oxides (NOx), carbon 

monoxide (CO), sulfur oxides (SOx), particulate matter less than 10 microns (PM10), particulate 

matter less than 2.5 microns (PM2.5) and carbon dioxide (CO2). Criteria emissions were provided 

for Category 1 and 2 vessels (Carey, 2009b); Category 3 port, reduced speed zone, and cruising 

activities (Carey, 2009a and Carey, 2009c); and Category 3 interport activities (Carey, 2009d). 

The VOC and PM estimates were speciated into hazardous air pollutants (HAP) 

components based on available data sources. The Swedish Environmental Protection Agency 

(SEPA) document Methodology for Calculating Emissions from Ships: 1. Update of emission 

factors served as the primary source of HAP emission factors which were converted into 

speciation profiles (Cooper and Gustafsson, 2004). Ammonia emission factors were also 

obtained from the SEPA, but as these factors require activity data, and such data were not 

available for Category 3 vessels operating in Federal waters, ammonia was estimated as a ratio of 

PM10 using the SEPA emission factors. Similar ratios were developed for Category 1 and 2 

vessels, assuming that this fleet primarily operates on marine diesel fuel with 80.5 percent of the 

fleet equipped with medium speed engines and the remaining 19.5 percent were high speed 

engines. This provided a weighted NH3 emission factor of 4.61E-03 g/kw-hr for operations atsea and in-port. The PM10 factors vary for at-sea (0.2 g/kw-hr) and in-port (0.4 g/kw-hr), so our 

NH3 / PM10 ratios were different for at-sea (2.31E-02) and in-port (1.15E-02). 

 While the SEPA document was used as the primary speciation source, other resources 

were investigated for potential inclusion in this effort. Recent BTEX data from Moldanova et al. 

were examined, but it included inconsistent benzene factors, some over 20% of hydrocarbon 

(HC) factors, were much higher than others found in recent publications and, as a result, were 

not included (Cook, 2009). CE-CERT metals data was also reviewed as it pertained to slow 

speed residual fuel engines (Cook, 2009). The CE-CERT emission factors were in line with the 

Swedish factors for nickel and lead, but they were an order of magnitude different for chromium, 

cadmium, and selenium. As a result, the Swedish factors were retained over the CE-CERT data 

based on the larger study sample size, while CE-CERT’s manganese emission factors were 

added as these factors were not included in the Swedish study (Cook, 2009). 

The complete pollutant list for CMVs is shown in Table 2-2. 

2.4 How Were the CMV Emissions Estimated? 

As noted above, the CMV criteria and CO2 emission estimates were provided for this 

inventory by OTAQ. Category 3 commercial marine inventories were developed for a base year 

of 2002 then projected to 2008 applying regional adjustment factors to account for growth. In 

addition, NOX adjustment factors were applied to account for implementation of the NOX Tier 1 

standard. Details about adjustments and growth factors can be found in the Category 3 

documentation (Appendix A). For Category 1 and 2 marine diesel engines, the emission 

estimates were consistent with the 2008 Locomotive and Marine federal rule making (Carey, 

2009b). 

2-11 
Table 2-2. Commercial Marine Vessel Pollutant List 

2,2,4 Trimethylpentane Carbon Monoxide* Naphthalene 

Acenaphthene Chromium(VI) Nickel 

Acenaphthylene Chromium (III) Nitrogen Oxides*

Acetaldehyde Chrysene PAH, total 

Acrolein Cobalt Phenanthrene 

Ammonia Dibenzo[a,h]Anthracene Phosphorus 

Anthracene Dioxins/Furans PM10 Primary*

Arsenic Ethyl benzene PM2.5 Primary+

Benz(a)anthracene Fluoranthene Polychlorinated Biphenyls 

Benzene Fluorene Propionaldehyde 

Benzo(a)pyrene Formaldehyde Pyrene 

Benzo(b)fluoranthene Hexachlorobenzene Selenium 

Benzo(g,h,i)perylene Hexane Styrene 

Benzo(k)fluoranthene Indeno(1,2,3-cd)pyrene Sulfur Dioxide*

Beryllium Lead Toluene 

Cadmium Manganese VOCs*

Carbon Dioxide* Mercury Xylene * Provided by OTAQ

+ PM2.5 was provided by OTAQ for all vessels and modes except for Category 3 Interport, where it was calculated 

using OTAQ guidance. 

OTAQ’s emissions were then allocated to individual GIS polygons using appropriate 

methods that varied by operating mode (i.e., hotelling, maneuvering, reduced speed zone, and 

underway). HAP emissions were estimated by applying speciation profiles to each polygon’s 

VOC and PM estimates. Figure 2-1 provides an overview of the approach used to estimate and 

spatially allocate CMV emissions. 

Speciation profiles were applied to the VOC, PM10, and PM2.5 emission estimates to 

calculate the associated HAP emissions using the following equation. 

VOC-PM10/2.5 * speciation profilei = HAP emission estimate: 

 Where: 

HAP emission estimate = HAP Emission estimate (tons/year) 

 for pollutant: 

 VOC-PM10/2.5 = VOC or PM emission estimate 

 (tons/year) 

 Speciation Profilei = VOC or PM speciation fraction for 

 HAP i 

2-12 
Criteria Estimates for All Marine 

Diesel Engines

Criteria/HAP Annual Emission Estimates

Vessels Equipped 

with Category 1 and 2 

Propulsion Engine

Ports Inland 

Waterways 

and Coast

Vessel Equipped with 

Category 3 

Propulsion Engine

Ports

Reduced 

Speed 

Zone

Approach Underway

Criteria Estimates for All Marine 

Distillate and Residual Fueled

Engines

HAP Speciation Profiles

Criteria/HAP Annual Emission Estimates

Vessels Equipped 

with Category 1 and 2 

Propulsion Engine

Ports Inland 

Waterways 

and Coast

Vessel Equipped with 

Category 3 

Propulsion Engine

Ports

Reduced 

Speed 

Zone

Approach Underway

Figure 2-1. General Approach Used to Develop Marine Vessel Component of the 2008 

National Emission Inventory 

2-13 
 For Category I diesel-powered vessels, the speciation profiles were based on high-speed 

diesel vehicle (HSDV) factors obtained from information in the SEPA’s Methodology for 

Calculating Emissions from Ships: 1. Update of emission factors (Cooper and Gustafsson, 2004). 

For Category 2 diesel-powered vessels, the speciation profiles were developed from mediumspeed diesel vehicles (MSDV). Since emissions and activity data were provided as a combined 

value for all Category 1 and 2 vessels, the Category 1 and Category 2 emission factors were 

averaged to obtain a single emission factor for all diesel vessels. All port activities for Category 

1 and 2 vessels were assumed to be maneuvering. 

 For Category 3 vessels, speciation profiles were developed using data from Methodology 

for Calculating Emissions from Ships: 1. Update of emission factors and assuming 80.5% of 

Category 3 vessels were equipped with slow-speed engines and 19.5% of vessels were equipped 

with medium speed engines based on vessel census data reported in the International Maritime 

Organization’s (IMO) recent greenhouse gas (GHG) study (IMO 2009). Separate speciation 

profiles were created for Category 3 vessels for underway, maneuvering, and hotelling activities. 

Chromium emissions were split into hexavalent and trivalent chromium based on an assumption 

that 34% of total chromium was hexavalent and the remaining 66% was trivalent. 

2.5 How Were Emissions Allocated? 

 Previous emissions allocations were based on waterway length and port county 

assignment. In this effort, spatial accuracy was greatly enhanced via the creation of GIS 

polygons representing port and waterway boundaries. GIS polygons allowed the 

estimation/allocation of emissions to defined port, waterway, and coastal areas, leading to 

improved spatial resolution compared to 2002’s county-level emissions. Methodologies for both 

port and underway emissions are described in detail in the sections that follow. 

2.6 How Were Port Emissions Allocated? 

 Port boundaries were developed using a variety of resources to identify the most accurate 

port boundaries. First, GIS data or maps provided directly from the port were used. Next, maps 

or port descriptions from local port authorities, port districts, etc. were used in combination with 

existing GIS data to identify port boundaries. Finally, satellite imagery from tools such as 

Google Earth and street layers from StreetMap USA were used to delineate port areas. Emphasis 

was placed on mapping the 117 ports with Category 3 vessel activity using available shape files 

of the port area. The Port of Huntington was developed differently given its large extent and 

limited available map data. The state of West Virginia provided a revised file of US Army Corps 

of Engineers port terminals reported to be part of the Port of Huntington-Tristate area. A 200 

meter buffer of the water features near these port terminals was created to identify port area. 

 In all cases, polygons were created on land, bordering waterways and coastal areas, and 

were split by county boundary. Each polygon was identified by the port name and state and 

county FIPS in addition to a unique ShapeID. Smaller ports with Category 1 and 2 activities 

were mapped as small circles. Note that no Category 3 emissions were mapped to small circles. 

The final shapefile contained 159 ports and 196 polygons. 

 OTAQ provided Category 1 and 2 criteria emissions and activity as a single national 

number. These emissions and activity were allocated to ports based on total commodity tonnage 

2-14 
data obtained from the U.S. Army Corps of Engineers (USACE) Principal Ports file for 2007 

(U.S. ACE, 2009). Emissions were then assigned to polygons within a port based on port area. 

 OTAQ developed port-level emissions for 117 of the largest U.S. ports with Category 3 

activity. Activity in megawatt hours (MWh) and resulting criteria and CO2 emissions were 

provided by port for maneuvering and hotelling modes. Emissions were then assigned to 

polygons within a port based on port area. HAP emissions were then speciated from VOC and 

PM estimates for each polygon using the methodology described in Section 3.0. 

2.7 How Were Underway Emissions Allocated? 

 For this inventory, a GIS polygon layer was created to more accurately represent the 

location of CMV-related activity and emissions. Inland waterway polygons were obtained from 

the Bureau of Transportation Statistics’ National Transportation Atlas Database hydro polygon 

layer (U.S. DOT, 2007). These polygons were further divided by county boundary and waterway 

ID. Coastal waters were drawn using Mineral Management Service state-federal boundary files 

and were also divided to indicate county boundaries. Federal waters were included as large area 

blocks outlined by the Exclusive Economic Zone (EEZ) boundary provided by EPA, which 

extends to approximately 200 nautical miles from the coastline. The final product is a polygon 

layer that includes all inland and coastal state waters and federal waters along with FIP, polygon 

area, and a unique ShapeID. Underway emissions were allocated differently by vessel category 

and mode, as outlined below. 

2.7.1 Category 1 and 2 Underway 

 OTAQ provided Category 1 and 2 criteria emissions and activity as a single national 

number. These emissions and activity were allocated to underway polygons in state waters based 

on total commodity movements (in tons) data obtained from USACE (U.S. ACE, 2001). These 

data were waterway-specific, so waterways that crossed into multiple FIPs had emissions 

assigned by waterway length in each polygon. HAP emissions were then speciated from VOC 

and PM estimates using the methodology described in Section 3.0 for each polygon. 

2.7.2 Category 3 Reduced Speed Zones (RSZ) 

 OTAQ provided polyline shapefiles indicating location of RSZ activities along with portspecific RSZ emissions and activity. These polylines were intersected with existing shipping lane 

polygons, and emissions were allocated to polygons based on the approach segment length on a 

per-port basis. HAP emissions were then speciated from VOC and PM estimates using the 

methodology described in Section 3.0 for each polygon. 

2.7.3 Category 3 Approach 

 OTAQ provided polyline shapefiles indicating location of cruising activities along with 

port-specific cruising emissions and activity. These polylines were intersected with our existing 

polygons, and emissions were allocated to polygons based on the approach segment length on a 

per-port basis. HAP emissions were then speciated from VOC and PM estimates using the 

methodology described in Section 3.0 for each polygon. 

2-15 
2.7.4 Category 3 Interport 

 OTAQ provided 4km grids for interport-only emissions for CO, CO2, HC, NOx, SOx, and 

PM10. These grids were provided in a customized projection which, without a custom geographic 

transformation, could not be converted to match the polygon layer’s projection. Furthermore, the 

emission estimates provided by OTAQ were developed using EEZs which were in the GCS Arc 

Sphere projection. Per OTAQ’s direction, the interport polygons were converted from North 

American Equidistant Conic to GCS Arc Sphere by using the data frame projections tool as the a 

transformation method. This approach was recommended by OTAQ in order to mirror previous 

methodology and provide emission estimates consistent with the recent Category 3 Commercial 

Marine Inventory. Zonal statistics tools were used to sum the gridded emissions within each 

underway polygon. HAP emissions were then speciated from VOC and PM estimates using the 

methodology described in Section 3.0 for each polygon. 

2.8 QA/QC 

 Given the significant methodological changes over previous inventory efforts, several 

quality checks were implemented to ensure that these data were developed and allocated in a 

clear and reproducible manner. Some of the quality checks implemented include the following: 

GIS shapefiles 

• Topology was created and validated through several rounds or revisions to remove 

gaps or overlapping features both within and between polygon layers. 

• Boundaries derived from Google Earth imagery were validated against Street Map 

network, port-provided map images, USACE ports points, and other online mapping 

resources to improve boundary accuracy. 

• All final shapefiles and polygon characteristics (such as area, etc.) were managed and 

evaluated in a single projection to ensure quality area and distance measurements, 

consistent results across CMV activity types, and maximum accuracy across the study 

area. The only exception to this was in the case of the interport criteria emissions, as 

described in Section 4.2.4. 

Emissions allocations and estimations 

• Emission factors were compiled from a variety of sources, and emission factor 

development methodologies evaluated to identify the most accurate emission factor 

for use in this inventory effort. 

• National emission sums were checked both before and after allocation to ensure no 

emissions were dropped or grown. 

• HAP speciation profiles were checked for accuracy, and speciated emissions were 

checked on both the polygon and national level to ensure accuracy. 

• All unit conversions were double-checked for errors. 

• Emission sums were evaluated across activity types (i.e., hotelling, maneuvering, 

cruising, reduced speed zones, and interport) to ensure they consistently mirror 

activity levels. 

• Port and underway emissions were examined across SCCs to ensure consistency with 

activity levels and vessel populations. 

2-16 
• 2008 pollutants and emissions were checked against the 2005 inventory to identify 

any missing pollutants or major changes compared to previous inventories. 

Discrepancies were investigated and revisions were made as needed. 

2.9 What are the Results? 

 Table 2-3 summarizes the emission estimates for CMVs for criteria pollutants. Table 2-4 

summarizes the emission estimates for individual HAPs. Note that for the purposes of this 

inventory vessels equipped with category 1 and 2 propulsion engines are assumed to operate on 

Distillate diesel, while vessels equipped with Category 3 propulsion engines are assumed to used 

a residual blend. Both tables provide data for all states; these 2008 estimates do not include state 

submitted data. 

Table 2-3. Commercial Marine Vessel Criteria and Greenhouse Gas Emission Estimates 

2008 (TPY) 

Pollutant 

Diesel 

Port

Diesel 

Underway

Diesel 

Total

Residual 

Port

Residual 

Underway

Residual 

Total

CMV 

Total 

CO 113,452 37,817 151,269 5,871 68,588 74,459 225,728

CO2 39,221,848 13,073,950 52,295,798 3,703,169 30,986,332 34,689,501 86,985,299

NH3 210 140 350 64 323 387 737

NOX 588,844 196,281 785,125 70,044 813,908 883,952 1,669,077

PM10-

PRI 

20,954 6,985 27,939 6,730 67,702 74,432 102,371

PM25-

PRI 

20,325 6,775 27,100 6,081 62,318 68,399 95,499

SO2 34,803 11,601 46,404 52,512 522,327 574,839 621,243

VOC 12,752 4,251 17,003 2,412 28,711 31,123 48,126

* Note that for the purposes of this inventory vessels equipped with category 1 and 2 propulsion engines are 

assumed to operate on Distillate diesel, while vessels equipped with Category 3 propulsion engines are assumed to 

used a residual blend. 

2-17 
Table 2-4. Commercial Marine Vessel HAP Emission Estimates 2008 (TPY) 

Pollutant 

Diesel 

Port

Residual 

Port

Diesel 

Underway

Residual 

Underway

2,2,4-Trimethylpentane 3.825675 NA 1.062688 NA

Acenaphthene 0.36585 0.002068 0.101625 0.021188

Acenaphthylene 0.564019 0.003193 0.156672 0.032717

Acetaldehyde 710.6 0.552315 197.388896 6.574751

Acrolein 33.47466 NA 9.298516 NA

Anthracene 0.564019 0.003193 0.156672 0.032717

Arsenic 0.366686 2.358644 0.209535 11.836005

Benz[a]Anthracene 0.60975 0.003448 0.169375 0.035334

Benzene 194.5738 0.023636 54.048288 0.281365

Benzo[a]Pyrene 0.052384 0.011793 0.034923 0.059180

Benzo[b]Fluoranthene 0.104768 0.023586 0.069845 0.118360

Benzo[g,h,i,]Perylene 0.137194 0.000778 0.038109 0.007977

Benzo[k]Fluoranthene 0.052384 0.011793 0.034923 0.059180

Beryllium NA 0.003674 NA 0.036965

Cadmium 0.059298 0.057506 0.035970 1.530064

Chromium (VI) 0.178105 1.224973 0.118737 4.419583

Chromium III 0.345733 2.377888 0.230489 8.579191

Chrysene 0.106706 0.000604 0.029641 0.006188

Cobalt NA 1.717108 NA 10.426100

Dioxins/Furans as 2,3,7,8-TCDD TEQs 1.57E-06 1.18E-06 0.000001 0.000006

Ethyl Benzene 19.12838 NA 5.313438 NA

Fluoranthene 0.335363 0.001897 0.093156 0.019443

Fluorene 0.746944 0.004227 0.207484 0.043311

Formaldehyde 1430.802 3.786611 397.445137 45.075801

Hexachlorobenzene 0.000419 9.43E-05 0.000279 0.000473

Hexane 52.60303 NA 14.611954 NA

Indeno[1,2,3-c,d]Pyrene 0.104768 0.023586 0.069845 0.118360

Lead 1.571513 0.354705 1.047675 1.773791

Manganese 0.032059 0.385606 0.008905 3.879322

Mercury 0.000524 0.008218 0.000349 0.035508

Naphthalene 21.35649 0.121021 5.932360 1.240126

Nickel 10.47675 90.68502 6.984500 398.764466

PAH, total 26.5488 0.154501 7.496895 1.584859

Phenanthrene 0.85365 0.004829 0.237125 0.049480

Phosphorus 26.71489 NA 387.932155

Polychlorinated Biphenyls 0.005238 0.001179 0.003492 0.005918

Propionaldehyde 58.34154 NA 16.205985 NA

Pyrene 0.594506 0.003363 0.165141 0.034462

Selenium 0.000593 0.053465 0.000360 0.235603

Styrene 20.08479 NA 5.579110 NA

Toluene 30.6054 NA 8.501500 NA

Xylenes (Mixed Isomers) 45.9081 NA 12.752250 NA

* Note that for the purposes of this inventory vessels equipped with category 1 and 2 propulsion engines are 

assumed to operate on Distillate diesel, while vessels equipped with Category 3 propulsion engines are assumed to 

used a residual blend. 

NA – Not Applicable. 

2-18 
2.10 Commercial Marine Vessel References 

Carey, Penny. Document entitled 2008 Deep Sea Summary Baseline, to Laurel Driver, U.S. EPA 

Office of Air Quality Planning and Standards (OAQPS). U.S. EPA Office of Mobile Sources 

(OMS). Ann Arbor, MI. February 5, 2009. 

Carey, Penny. Memorandum entitled 2008 Emissions, Activity, and Fuel Consumption for CMV 

Diesel (i.e., Category 1, Category 2, and CMV < 37kW), to Laurel Driver, U.S. EPA Office of 

Air Quality Planning and Standards (OAQPS). U.S. EPA Office of Mobile Sources (OMS). Ann 

Arbor, MI. September 16, 2009. 

Carey, Penny. Document entitled 2008 Great Lakes Summary Baseline, to Laurel Driver, U.S. 

EPA Office of Air Quality Planning and Standards (OAQPS). U.S. EPA Office of Mobile 

Sources (OMS). Ann Arbor, MI. February 5, 2009. 

Carey, Penny. Memorandum entitled 2008 OGV inventories and shapefiles, to Laurel Driver, 

U.S. EPA Office of Air Quality Planning and Standards (OAQPS). U.S. EPA Office of Mobile 

Sources (OMS). Ann Arbor, MI. February 5, 2009. 

Cook, Rich. Memorandum entitled Marine EFs, to Laurel Driver and Penney Carrey, U.S. EPA 

Office of Air Quality Planning and Standards (OAQPS). U.S. EPA Office of Mobile Sources. 

Ann Arbor, MI. September 18, 2009. 

Cooper, D. and Gustafsson, T. Methodology for Calculating Emissions from Ships: 1. Update of 

emission factors. Swedish Methodology for Environmental Data, Report No. 2004-02-02. 

International Maritime Organization (IMO), Updated Study on Greenhouse Gas Emissions from 

Ships: Final Report Covering Phase 1 and Phase 2, 9 April 2009.

U.S. Army Corps of Engineers. U.S. Army Corps of Engineers (USACE) Principal Ports file for 

2007. U.S. Army Corps of Engineers, Navigation Data Center, Waterborne Commerce Statistics. 

Available at: http://www.iwr.usace.army.mil/ndc/db/pport/dbf/pport07.xls. September 10, 2009. 

U.S. Army Corps of Engineers. Waterway Network Link Commodity Data. Water Resources 

Support Center, Fort Belvoir, VA. Downloaded from the following Internet site: 

http://www.iwr.usace.army.mil/ndc/db/waternet/tons/dbf/linktons07.xls. January 22, 2001. 

U.S. Department of Transportation, Bureau of Transportation Statistics. National Transportation 

Atlas Database, 2007. Available at 

https://www.bts.gov/pdc/user/products/src/products.xml?p=2559&c=-1. 

U.S. Environmental Protection Agency. Development of 2008CY Category 3 Commercial 

Marine Inventory. Office of Transportation and Air Quality, Ann Arbor, MI. 2009. 

U.S. Environmental Protection Agency. Final Regulatory Support Document: Control of 

Emissions from New Marine Compression-Ignition Engines at or above 30 Liters per Cylinder. 

January 2003, EPA420-R-03-004. 

2-19 
U.S. Environmental Protection Agency. Procedures for Emission Inventory Preparation, Volume 

IV: Mobile Sources. Office of Air Quality Planning and Standards. Research Triangle Park, NC. 

1989. 

2-20 
Appendix A 

2008 Category 3 Commercial Marine Vessel Inventory Methodology

Citation: U.S. Environmental Protection Agency. Development of 2008CY Category 3 

Commercial Marine Inventory. Office of Transportation and Air Quality, Ann Arbor, MI. 2009. 
Development of 2008CY Category 3 Commercial Marine Inventory 

 The Category 3 (C3) inventory includes vessels which use C3 engines for propulsion. C3 

engines are defined as having displacement above 30 liters per cylinder. The resulting inventory 

includes emissions from both propulsion and auxiliary engines used on these vessels, as well as 

those on gas and steam turbine vessels. 

 Geographically, the inventories include port and interport emissions that occur within the 

area that extends 200 nautical miles (nm) from the official U.S. baseline, which is roughly 

equivalent to the border of the U.S. Exclusive Economic Zone (EEZ). The U.S. region was 

clipped to the boundaries of the U.S. EEZ in areas where the 200nm boundary extended beyond 

the EEZ. 

 Category 3 commercial marine inventories were developed for a base year of 2002. [1] 

These were then projected to 2008. Regional adjustment factors were applied to account for 

growth. In addition, NOX adjustment factors were applied to account for implementation of the 

NOX Tier 1 standard. The methodology for each type of adjustment is described below. 

Growth Factors by Geographic Region

 The emissions inventory is calculated for nine geographic regions: Alaska East, Alaska 

West, East Coast, Gulf Coast, Hawaii East, Hawaii West, North Pacific, South Pacific, and the 

Great Lakes. Average annual growth rates from 2002-2020 were calculated for five regions: East 

Coast, Gulf Coast, North Pacific, South Pacific, and the Great Lakes. The Alaska regions were 

assigned the growth factor for the North Pacific region, while the Hawaii regions were assigned 

the growth factor for the South Pacific region. Each regional growth rate was then compounded 

over the inventory projection time period for 2008 (i.e., 6 years). The average annual growth 

rates and resulting multiplicative growth factors for each emission inventory region is presented 

in Table 1 below. 

Table 1. Regional Emission Inventory Growth Factors for 2008 

Emission Inventory 

Region 

2002-2020 

Average 

Annualized 

Growth Rate (%) 

Multiplicative Growth 

Factor for 2008 

Relative to 2002 

Alaska East (AE) 3.3 1.2151 

Alaska West (AW) 3.3 1.2151 

East Coast (EC) 4.5 1.3023 

Gulf Coast (GC) 2.9 1.1871 

Hawaii East (HE) 5.0 1.3401 

Hawaii West (HW) 5.0 1.3401 

North Pacific (NP) 3.3 1.2151 

South Pacific (SP) 5.0 1.3401 

Great Lakes (GL) 1.7 1.1064 

A-1 
NOx Adjustment Factors

 The 2008 calendar year baseline inventory includes pre-control (Tier 0) engines and those 

subject to the NOX Tier 1 standard that became effective in 2000. The NOX emission factors 

(EFs) by tier and engine/ship type are given in Table 2. 

Table 2. NOX Emission Factors by Tier 

NOX EF (g/kW-hr) 

Engine/Ship Type Tier 0 Tier 1 

Main 

Slow-Speed Diesel (SSD) 18.1 16.1 

Medium-Speed Diesel (MSD) 14 12.5 

Steam Turbine (ST) 2.1 n/a 

Gas Turbine 6.1 n/a 

Auxiliary 

Passenger Ship 14.6 13.0 

Other Ships 14.5 12.9 

 The NOX EFs by tier were then used with age distributions to generate calendar year NOX

EFs by engine/ship type for 2008. For 2002, Tier 0 EFs were used for simplicity. These calendar 

year NOX EFs are provided in Table 3. Since the age distributions are different for vessels in the 

Great Lakes, NOX EFs were determined separately for the Great Lakes. 

Table 3. NOX Emission Factors by Calendar Year 

CY NOX EF (g/kW-hr) 

2008 

Engine/Ship Type 2002 DSPa GLb

Main 

Slow-Speed Diesel (SSD) 18.1 17.07 17.50 

Medium-Speed Diesel (MSD) 14 13.01 13.74 

Steam Turbine (ST) 2.1 2.1 2.1 

Gas Turbine 6.1 6.1 n/a 

Auxiliary 

Passenger Ship 14.6 13.76 14.32 

Other Ships 14.5 13.60 14.16 a

DSP = Deep sea ports and areas other than the Great Lakes 

b

GL = Great Lakes 

A-2 
 Emission adjustment factors for NOX were then calculated. Adjustment factors are ratios 

of the 2008 calendar year EFs to the 2002 calendar year EFs. The adjustment factors by 

engine/ship type are provided in Table 4. 

Table 4. NOX EF Adjustment Factors for 2008CY 

2008 NOX Adj (unitless) 

Engine/Ship Type DSPa GLb

Main 

Slow-Speed Diesel (SSD) 0.9433 0.9670 

Medium-Speed Diesel (MSD) 0.9293 0.9815 

Steam Turbine (ST) 1.0000 1.0000 

Gas Turbine 1.0000 n/a 

Auxiliary 

Passenger Ship 0.9403 0.9784 

Other Ships 0.9403 0.9784 

Methodology for Development of 2008CY Port Inventories

 For the non-California ports, 2002 emissions for each port are summed by engine/ship 

type. Propulsion and auxiliary emissions are summed separately, since the EF adjustment factors 

differ. The appropriate regional growth factor, as provided in Table 1, is then applied, along with 

the NOX EF adjustment factors by engine/ship type in Table 4 to calculate the 2008 port 

inventories. 

 For the California ports, 2002 emissions for each port are summed by ship type. 

Propulsion and auxiliary emissions are summed separately, since the EF adjustment factors 

differ. The EF adjustment factors by engine/ship type in Table 4 are consolidated by ship type, 

using the CARB assumption that engines on all ships except passenger ships are 95 percent slow 

speed diesel (SSD) engines and 5 percent medium speed diesel engines (MSD) based upon a 

2005 CARB survey. All passenger ships were assumed to be MSD engines. Steam turbines (ST) 

and gas turbines (GT) are not included in the CARB inventory. The NOX EF adjustment factors 

by ship type are then applied, along with ship-specific growth factors used by CARB, to 

calculate the 2008 California port inventories. The ship-specific growth factors for 2008 relative 

to 2002 are provided in Table 5 below. 

A-3 
Table 5. Growth Factors by Ship Type for California Ports 

Calendar Year 

Ship Type 2002 2008 

Auto 1.0000 1.1525 

Bulk 1.0000 0.7412 

Container 1.0000 1.4023 

General 1.0000 0.9071 

Passenger 1.0000 1.9823 

Reefer 1.0000 1.0112 

RoRo 1.0000 1.1525 

Tanker 1.0000 1.3005 

Methodology for Development of 2008CY Interport Inventories

 The interport portion of the inventory is not segregated by engine or ship type. As a 

result, regional NOX EF adjustment factors were developed based on the assumed mix of main 

(propulsion) engine types in each region. The mix of main engine types by region was developed 

using the ship call and power data and is presented in Table 6. Main engines are considered a 

good surrogate for interport emissions, since the majority of emissions while underway are due 

to the main engines. The NOX EF adjustment factors by main engine type in Table 4 were used 

together with the mix of main engine types by region in Table 6 to develop the regional 

adjustment factors. The resulting NOX EF regional adjustment factors are provided in Table 7. 

These NOX EF regional adjustment factors, together with the regional growth factors in Table 1, 

were applied to calculate the 2008 interport inventories. 

Table 6. Installed Power by Main Engine Type 

2008 Installed Power (%) 

Region MSD SSD GT ST 

Alaska East (AE) 19.1% 18.4% 0.3% 62.2% 

Alaska West (AW) 19.1% 18.4% 0.3% 62.2% 

East Coast (EC) 25.6% 72.5% 0.9% 1.0% 

Gulf Coast (GC) 13.7% 85.5% 0.0% 0.8% 

Hawaii East (HE) 66.2% 18.5% 7.4% 8.0% 

Hawaii West (HW) 66.2% 18.5% 7.4% 8.0% 

North Pacific (NP) 5.1% 83.5% 1.6% 9.7% 

South Pacific (SP) 17.8% 82.2% 0.0% 0.0% 

Great Lakes (GL) 47.9% 43.7% 0.0% 8.4% 

A-4 
Table 7. NOX EF Regional Adjustment Factors 

Region 2002 2008 

Alaska East (AE) 1.0000 0.9761 

Alaska West (AW) 1.0000 0.9761 

East Coast (EC) 1.0000 0.9408 

Gulf Coast (GC) 1.0000 0.9419 

Hawaii East (HE) 1.0000 0.9428 

Hawaii West (HW) 1.0000 0.9428 

North Pacific (NP) 1.0000 0.9490 

South Pacific (SP) 1.0000 0.9408 

Great Lakes (GL) 1.0000 0.9767 

 The resulting 2008 Category 3 emission inventories are shown in Table 8 for each of the 

nine geographic regions and the nation. 

Table 8. 2008 Regional and National Emissions from Category 3 Vessel Main and 

Auxiliary Engines 

Metric Tonnes 

Region NOX PM10 PM2.5 a HC CO SO2 CO2

Alaska East (AE) 21,590 1,749 1,609 733 1,730 13,032 807,159

Alaska West (AW) 71,901 5,755 5,294 2,441 5,750 42,694 2,631,081

East Coast (EC) 271,707 23,021 21,180 9,573 22,665 190,767 10,696,360

Gulf Coast (GC) 195,240 16,839 15,492 6,903 16,990 125,728 7,604,870

Hawaii East (HE) 28,837 2,403 2,211 1,013 2,390 17,843 1,108,047

Hawaii West (HW) 40,573 3,381 3,110 1,426 3,362 25,105 1,559,016

North Pacific (NP) 30,248 2,647 2,435 1,153 2,568 18,790 1,216,723

South Pacific (SP) 132,669 10,982 10,103 4,692 11,368 81,896 5,145,632

Great Lakes (GL) 16,395 1,318 1,212 557 1,312 9,797 605,001

Total Metric Tonnes 809,160 68,094 62,646 28,492 68,136 525,651 31,373,889

Total Short Tons b 891,946 75,061 69,056 31,407 75,107 579,431 34,583,792 a Estimated from PM10 using a multiplicative adjustment factor of 0.92. 

Reference (for 2002 inventory development)

1) U.S. Environmental Protection Agency, “Draft Regulatory Impact Analysis: Control of 

Emissions of Air Pollution from Category 3 Marine Diesel Engines,” Office of 

Transportation and Air Quality, EPA-420-D-09-002, June 2009. 

A-5 
Appendix B 

2008 Commercial Marine Vessel Hazardous Air Pollutant Speciation Profiles
Table 1. Category 1 and 2 Hazardous Air Pollutant Speciation Profile for Port Activities 

Pollutant 

Code Pollutant 

Speciation 

Basis 

2008 

Emission 

Factor 

540841 2,2,4-trimethylpentane VOC 3.00E-04 

83329 Acenaphthene PM2.5 1.80E-05 

208968 Acenaphthylene PM2.5 2.78E-05 

75070 Acetaldehyde VOC 5.57E-02 

107028 Acrolein VOC 2.63E-03 

NH3 Ammonia PM10 1.15E-02 

120127 Anthracene PM2.5 2.78E-05 

7440382 Arsenic PM10 1.75E-05 

56553 Benz[a]Anthracene PM2.5 3.00E-05 

71432 Benzene VOC 1.53E-02 

50328 Benzo[a]Pyrene PM10 2.50E-06 

205992 Benzo[b]Fluoranthene PM10 5.00E-06 

191242 Benzo[g,h,I,]Perylene PM2.5 6.75E-06 

207089 Benzo[k]Fluoranthene PM10 2.50E-06 

7440439 Cadmium PM10 2.83E-06 

16065831 Chromium III PM10 1.65E-05 

18540299 Chromium VI PM10 8.50E-06 

218019 Chrysene PM2.5 5.25E-06 

600 Dioxin PM10 2.50E-09 

100414 Ethylbenzene VOC 1.50E-03 

206440 Fluoranthene PM2.5 1.65E-05 

86737 Fluorene PM2.5 3.68E-05 

50000 Formaldehyde VOC 1.12E-01 

118741 Hexachlorobenzene PM10 2.00E-08 

193395 Indeno[1,2,3-c,d]Pyrene PM10 5.00E-06 

439921 Lead PM10 7.50E-05 

7439965 Manganese PM10 1.53E-06 

7439976 Mercury PM10 2.50E-08 

91203 Naphthalene PM2.5 1.05E-03 

110543 n-Hexane VOC 4.13E-03 

7440020 Nickel PM10 5.00E-04 

1336363 Polychlorinated Biphenyls PM10 2.50E-07 

85018 Phenanthrene PM2.5 4.20E-05 

123386 Propionaldehyde VOC 4.58E-03 

129000 Pyrene PM2.5 2.93E-05 

7782492 Selenium PM10 2.83E-08 

100425 Styrene VOC 1.58E-03 

108883 Toluene VOC 2.40E-03 

B-1 
Table 2. Category 1 and 2 Hazardous Air Pollutant Speciation Profile for 

Underway Activities 

Pollutant 

Code Pollutant 

Speciation 

Basis 

2008 

Emission 

Factor 

1330207 Xylene VOC 3.60E-03

540841 2,2,4-trimethylpentane VOC 2.50E-04

83329 Acenaphthene PM2.5 1.50E-05

208968 Acenaphthylene PM2.5 2.31E-05

75070 Acetaldehyde VOC 4.64E-02

107028 Acrolein VOC 2.19E-03

NH3 Ammonia PM10 2.31E-02

120127 Anthracene PM2.5 2.31E-05

7440382 Arsenic PM10 3.00E-05

56553 Benz[a]Anthracene PM2.5 2.50E-05

71432 Benzene VOC 1.27E-02

50328 Benzo[a]Pyrene PM10 5.00E-06

205992 Benzo[b]Fluoranthene PM10 1.00E-05

191242 Benzo[g,h,I,]Perylene PM2.5 5.63E-06

207089 Benzo[k]Fluoranthene PM10 5.00E-06

7440439 Cadmium PM10 5.15E-06

16065831 Chromium III PM10 3.30E-05

18540299 Chromium VI PM10 1.70E-05

218019 Chrysene PM2.5 4.38E-06

600 Dioxin PM10 5.00E-09

100414 Ethylbenzene VOC 1.25E-03

206440 Fluoranthene PM2.5 1.38E-05

86737 Fluorene PM2.5 3.06E-05

50000 Formaldehyde VOC 9.35E-02

118741 Hexachlorobenzene PM10 4.00E-08

193395 Indeno[1,2,3-c,d]Pyrene PM10 1.00E-05

7439921 Lead PM10 1.50E-04

7439965 Manganese PM10 1.28E-06

7439976 Mercury PM10 5.00E-08

91203 Naphthalene PM2.5 8.76E-04

110543 n-Hexane VOC 3.44E-03

7440020 Nickel PM10 1.00E-03

1336363 Polychlorinated Biphenyls PM10 5.00E-07

B-2 
Table 2. Category 1 and 2 Hazardous Air Pollutant Speciation Profile for 

Underway Activities (Continued) 

Pollutant 

Code Pollutant 

Speciation 

Basis 

2008 

Emission 

Factor 

85018 Phenanthrene PM2.5 3.50E-05

123386 Propionaldehyde VOC 3.81E-03

129000 Pyrene PM2.5 2.44E-05

7782492 Selenium PM10 5.15E-08

100425 Styrene VOC 1.31E-03

108883 Toluene VOC 2.00E-03

1330207 Xylene VOC 3.00E-03

Table 3. Category 3 Hazardous Air Pollutant Speciation Profile for 

Hotelling Activities 

Pollutant 

Code Pollutant 

Speciation 

Basis 

2008 

Emission 

Factor 

83329 Acenaphthene PM2.5 3.40E-07

208968 Acenaphthylene PM2.5 5.25E-07

75070 Acetaldehyde VOC 2.29E-04

NH3 Ammonia PM10 1.08E-02

120127 Anthracene PM2.5 5.25E-07

7440382 Arsenic PM10 4.00E-04

56553 Benz[a]Anthracene PM2.5 5.67E-07

71432 Benzene VOC 9.80E-06

50328 Benzo[a]Pyrene PM10 2.00E-06

205992 Benzo[b]Fluoranthene PM10 4.00E-06

191242 Benzo[g,h,I,]Perylene PM2.5 1.28E-07

207089 Benzo[k]Fluoranthene PM10 2.00E-06

7440417 Beryllium PM10 5.46E-07

7440439 Cadmium PM10 5.90E-06

16065831 Chromium III PM10 3.96E-04

18540299 Chromium VI PM10 2.04E-04

218019 Chrysene PM2.5 9.93E-08

7440484 Cobalt PM10 2.92E-04

53703 Dibenzo[a,h]Anthracene PM2.5 0.00E+00

600 Dioxin PM10 2.00E-09

B-3 
Table 3. Category 3 Hazardous Air Pollutant Speciation Profile for 

Hotelling Activities (Continued) 

Pollutant 

Code Pollutant 

Speciation 

Basis 

2008 

Emission 

Factor 

206440 Fluoranthene PM2.5 3.12E-07

86737 Fluorene PM2.5 6.95E-07

50000 Formaldehyde VOC 1.57E-03

118741 Hexachlorobenzene PM10 1.60E-08

193395 Indeno[1,2,3-c,d]Pyrene PM10 4.00E-06

7439921 Lead PM10 6.00E-05

7439965 Manganese PM10 5.73E-05

7439976 Mercury PM10 1.40E-06

91203 Naphthalene PM2.5 1.99E-05

7440020 Nickel PM10 1.54E-02

1336363 Polychlorinated Biphenyls PM10 2.00E-07

85018 Phenanthrene PM2.5 7.94E-07

7723140 Phosphorous PM10 4.38E-03

130498292 POM as 16-PAH PM2.5 2.49E-05

130498292 POM as 7-PAH PM10 4.50E-07

129000 Pyrene PM2.5 5.53E-07

7782492 Selenium PM10 9.08E-06

Table 4. Category 3 Hazardous Air Pollutant Speciation Profile for 

Maneuvering Activities 

Pollutant 

Code Pollutant 

Speciation 

Basis 

2008 

Emission 

Factor 

83329 Acenaphthene PM2.5 3.40E-07

208968 Acenaphthylene PM2.5 5.25E-07

75070 Acetaldehyde VOC 2.29E-04

NH3 Ammonia PM10 2.38E-03

120127 Anthracene PM2.5 5.25E-07

7440382 Arsenic PM10 8.74E-05

56553 Benz[a]Anthracene PM2.5 5.67E-07

71432 Benzene VOC 9.80E-06

50328 Benzo[a]Pyrene PM10 4.37E-07

205992 Benzo[b]Fluoranthene PM10 8.74E-07

B-4 
Table 4. Category 3 Hazardous Air Pollutant Speciation Profile for 

Maneuvering Activities (Continued) 

Pollutant 

Code Pollutant 

Speciation 

Basis 

2008 

Emission 

Factor 

191242 Benzo[g,h,I,]Perylene PM2.5 1.28E-07

207089 Benzo[k]Fluoranthene PM10 4.37E-07

7440417 Beryllium PM10 5.46E-07

7440439 Cadmium PM10 2.26E-05

16065831 Chromium III PM10 1.27E-04

18540299 Chromium VI PM10 6.53E-05

218019 Chrysene PM2.5 9.93E-08

7440484 Cobalt PM10 5.94E-05

53703 Dibenzo[a,h]Anthracene PM2.5 0.00E+00

600 Dioxin PM10 4.37E-10

206440 Fluoranthene PM2.5 3.12E-07

86737 Fluorene PM2.5 6.95E-07

50000 Formaldehyde VOC 1.57E-03

118741 Hexachlorobenzene PM10 3.50E-09

193395 Indeno[1,2,3-c,d]Pyrene PM10 8.74E-07

7439921 Lead PM10 1.40E-05

7439965 Manganese PM10 5.73E-05

7439976 Mercury PM10 2.71E-07

91203 Naphthalene PM2.5 1.99E-05

7440020 Nickel PM10 3.25E-03

1336363 Polychlorinated Biphenyls PM10 4.37E-08

85018 Phenanthrene PM2.5 7.94E-07

7723140 Phosphorous PM10 1.79E-03

130498292 POM as 16-PAH PM2.5 2.49E-05

130498292 POM as 7-PAH PM10 4.90E-07

129000 Pyrene PM2.5 5.53E-07

7782492 Selenium PM10 1.91E-06

Table 5. Category 3 Hazardous Air Pollutant Speciation Profile for 

Underway Activities 

Pollutant 

Code Pollutant 

Speciation 

Basis 

2008 

Emission 

Factor 

83329 Acenaphthene PM2.5 3.40E-07

208968 Acenaphthylene PM2.5 5.25E-07

B-5 
Table 5. Category 3 Hazardous Air Pollutant Speciation Profile for 

Underway Activities (Continued) 

Pollutant 

Code Pollutant 

Speciation 

Basis 

2008 

Emission 

Factor 

75070 Acetaldehyde VOC 2.29E-04

NH3 Ammonia PM10 4.77E-03

120127 Anthracene PM2.5 5.25E-07

7440382 Arsenic PM10 1.75E-04

56553 Benz[a]Anthracene PM2.5 5.67E-07

71432 Benzene VOC 9.80E-06

50328 Benzo[a]Pyrene PM10 8.74E-07

205992 Benzo[b]Fluoranthene PM10 1.75E-06

191242 Benzo[g,h,I,]Perylene PM2.5 1.28E-07

207089 Benzo[k]Fluoranthene PM10 8.74E-07

7440417 Beryllium PM10 5.46E-07

7440439 Cadmium PM10 2.26E-05

7440473 Chromium PM10 1.92E-04

16065831 Chromium III PM10 1.27E-04

18540299 Chromium VI PM10 6.53E-05

218019 Chrysene PM2.5 9.93E-08

7440484 Cobalt PM10 1.54E-04

53703 Dibenzo[a,h]Anthracene PM2.5 0.00E+00

600 Dioxin PM10 8.74E-10

206440 Fluoranthene PM2.5 3.12E-07

86737 Fluorene PM2.5 6.95E-07

50000 Formaldehyde VOC 1.57E-03

118741 Hexachlorobenzene PM10 6.99E-09

193395 Indeno[1,2,3-c,d]Pyrene PM10 1.75E-06

7439921 Lead PM10 2.62E-05

7439965 Manganese PM10 5.73E-05

7439976 Mercury PM10 5.24E-07

91203 Naphthalene PM2.5 1.99E-05

7440020 Nickel PM10 5.89E-03

1336363 Polychlorinated Biphenyls PM10 8.74E-08

85018 Phenanthrene PM2.5 7.94E-07

7723140 Phosphorus PM10 5.73E-03

130498292 POM as 16-PAH PM2.5 2.49E-05

130498292 POM as 7-PAH PM10 4.90E-07

129000 Pyrene PM2.5 5.53E-07

7782492 Selenium PM10 3.48E-06

B-6 
ERG No.: 0245.03.402.001 

Contract No.: EP-D-07-097 

Documentation for Locomotive Component of the National Emissions 

Inventory Methodology 

Prepared by: 

Eastern Research Group 

1600 Perimeter Park Drive 

Morrisville, North Carolina 27560 

Under Contract to: 

E.H. Pechan & Associates, Inc. 

3622 Lyckan Parkway 

Suite 2002 

Durham, North Carolina 27707 

For Submittal to: 

Laurel Driver 

Emissions, Monitoring and Analysis Division 

U.S. Environmental Protection Agency 

Research Triangle Park, North Carolina 27711 

May 3, 2011 
i 

TABLE OF CONTENTS 

Section Page No. 

1.0 INTRODUCTION ........................................................................................................... 1-1

1.1 What are Locomotive Sources? ........................................................................... 1-1

2.0 DEVELOPMENT OF THE LOCOMOTIVE COMPONENT FOR THE NEI .............. 2-1

2.1 What Pollutants are Included in the National Emission Estimates for 

Locomotives? ....................................................................................................... 2-1

3.0 HOW WERE LOCOMOTIVE EMISSIONS ESTIMATED? ........................................ 3-1

3.1 Line Haul Criteria Emissions Estimates .............................................................. 3-1

3.2 Rail Yard Criteria Emissions Estimates ............................................................... 3-1

3.3 Hazardous Air Pollutant Emissions Estimates ..................................................... 3-2

4.0 HOW WERE COUNTY LINE HAUL EMISSIONS REALLOCATED TO 

INDIVIDUAL RAIL SEGMENTS? ................................................................................ 4-1

4.1 Class I Line Haul Emissions Allocation .............................................................. 4-1

4.2 Class II/III Line Haul Emissions Allocation ........................................................ 4-2

4.3 Rail Yard Emissions Allocation........................................................................... 4-3

4.4 State Provided Data .............................................................................................. 4-3

4.5 What are the Results?........................................................................................... 4-3

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

Appendix A – ERTAC Class I Line Haul Documentation 

Appendix B – ERTAC Class II/III Line Haul Documentation 

Appendix C – ERTAC Rail Yard Documentation 
ii 

LIST OF TABLES AND FIGURES 

Tables Page No. 

Table 2-1. Locomotive Pollutant List .......................................................................................... 2-1

Table 2-2. Methods Used to Develop Annual Emission Estimates for Nonroad 

Mobile Sources ............................................................................................................................ 2-2

Table 3-1. Hazardous Air Pollutant Speciation Profile for 2008 Locomotive 

Emission Estimation .................................................................................................................... 3-2

Table 4-1. Line Haul Segment Activity (MGTM/Mi) Categories ............................................... 4-1
1-1 

1.0 INTRODUCTION 

1.1 What are Locomotive Sources? 

The locomotive source category includes railroad locomotives powered by diesel-electric 

engines. A diesel-electric locomotive uses 2-stroke or 4-stroke diesel engines and an alternator 

or a generator to produce the electricity required to power its traction motors. The locomotive 

source category does not include locomotives powered by electricity or steam. Emissions 

associated with the operation of electric locomotives would be included in the point source utility 

emission estimate. It is believed that the number of wood or coal driven steam locomotives is 

currently very small; therefore, these types of locomotives are not included in this inventory. 

The locomotive source category is further divided up into three categories: Class I line 

haul, Class II/III line haul, and Class I yard. The national rail estimates were developed by the 

Eastern Regional Technical Advisory Committee hereafter referenced as ERTAC Rail. This 

group is comprised of eastern states’ regulatory agencies in collaboration with the rail industry. 

ERTAC Rail developed emissions estimates based on fuel data obtained from the American 

Association of Railroads for each subcategory. California locomotive emission estimates were 

handled separately from the rest of the United States because of their use of low sulfur 

locomotive diesel fuels. 
2-1 

2.0 DEVELOPMENT OF THE LOCOMOTIVE COMPONENT FOR THE 

NEI 

2.1 What Pollutants are Included in the National Emission Estimates for Locomotives? 

 All of the criteria pollutants, VOC, CO, NOx, SOx, PM, and PM2.5, are included in the 

locomotive component of the NEI. OTAQ identified the HAPs for which data were available to 

develop inventory estimates (Scarbro, 2001). The hazardous air pollutants (HAPs), listed below, 

were identified based on available test data and accepted emission estimation procedures. 

Emission estimation methods have changed over the history of the NEI, as outlined briefly in 

Table 2-2 for nonroad sources. 

Table 2-1. Locomotive Pollutant List 

1,3-Butadiene Beryllium Napthalene 

2,2,4-Trimethylpentane Cadmium n-Hexane 

Acenaphthene Chromium (Hexavalent) Nickel 

Acenaphthylene Chromium (Trivalent) Phenanthrene 

Acetaldehyde Chrysene PAH Propionaldehyde 

Acrolein Dibenz(a,h) anthracene Pyrene 

Anthracene Ethyl Benzene Styrene 

Arsenic Fluoranthene Toluene 

Benzene Fluorene Xylene 

Benzo(a)anthracene Formaldehyde 

Benzo[a]pyrene Indeno(1,2,3-cd) pyrene 

Benzo[b]fluoranthene Lead 

Benzo[g,h,i,]perylene Manganese 

Benzo[k]fluoranthene Mercury 
2-2 

Table 2-2. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources 

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method* 

NONROAD CategoriesNonroad Gasoline, Diesel, LPG, CNG 

2008 VOC, NOx, CO, SO2, 

PM10, PM2.5, NH3, & 

HAPs 

Emission estimates for NONROAD model engines were developed using EPA’Model (NMIM), which incorporates NONROAD2008. Where states provided a

inputs, these data replaced EPA default inputs. 

2005 VOC, NOx, CO, SO2, , 

PM10, PM2.5, NH3, & 

HAPs 

Emission estimates for NONROAD model engines were developed using EPA’NONROAD2005. Where States provided alternate nonroad inputs, these data re

2002 VOC, NOx, CO, SO2, 

PM10, PM2.5, NH3, & 

HAPs 

Emission estimates for NONROAD model engines were developed using EPA’NONROAD2004. Where states provided alternate nonroad inputs, these data repState-supplied emissions data also replaced default EPA emission estimates. 

 1999 VOC, NOx, CO, SO2, 

PM10, PM2.5

Using emission estimates from two emission inventories including: 1) a 1996 cdeveloped using EPA’s October 2001 draft NONROAD model; and 2) an updat

based on EPA’s draft Lockdown C NONROAD model (dated May 2002). Using emission estimates, seasonal and daily county-to-national ratios were then develupdated national estimates per season estimated from the Lockdown C model. R

for California for all NONROAD model categories; Pennsylvania for recreationsupport equipment, and Texas for select equipment categories. 

 1996, 1997, 

1998, 2000 & 2001 

VOC, NOx, CO, SO2, 

PM10, PM2.5

Using emission estimates from two emission inventories including: 1) a 1996 cdeveloped using EPA’s October 2001 draft NONROAD model; and 2) updated California inventories, based on EPA’s draft Lockdown C NONROAD model (d1996 county-level emission estimates, seasonal and daily county-to-national rati

state ratios were then developed for application to updated national estimates peLockdown C model. California results replace the diesel equipment emissions gapplication of county-to-national ratios. 
2-3 

Table 2-2. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources (Continued)

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method*

Nonroad Gasoline, Diesel, LPG, and CNG (Continued) 

1991-1995 VOC, NOx, CO, SO2, 

PM10, PM2.5, NH3

Using 1990 and 1996 county-level emissions inventories, estimated emissions unational emissions between 1990 and 1996. From these emissions, calculated thfor each pollutant/SCC combination for each year, and then applied the growth femissions to estimate 1991-1995 emissions. 

 1990 VOC, NOx, CO, SO2, 

PM10, PM2.5

Using emission estimates from two emission inventories including: 1) a 1996 cdeveloped using EPA’s October 2001 draft NONROAD model; and 2) updated based on EPA’s draft Lockdown C NONROAD model (dated May 2002). Using emission estimates, seasonal and daily county-to-national ratios were then develupdated national estimates per season estimated from the Lockdown C model. 

 1986, 1988, & 

1989 

VOC, NOx, CO, SO2, 

PM10, PM2.5, NH3

Using 1985 and 1990 county-level emissions inventories, estimated emissions unational emissions between 1985 and 1990. From these emissions, calculated thfor each pollutant/SCC combination for each year, and then applied the growth femissions to estimate 1986-1989 emissions. 

 1987 VOC, NOx, CO, SO2, 

PM10, PM2.5

Using EPA’s draft Lockdown C NONROAD model (dated May 2002), developemissions for 1987 by running 4 seasonal NONROAD model runs to estimate anemissions. Also performed national NONROAD model runs to estimate typical 

1985 VOC, NOx, CO, SO2, 

PM10, PM2.5

Using emission estimates from two emission inventories including: 1) a 1996 cdeveloped using EPA’s October 2001 draft NONROAD model; and 2) updated based on EPA’s draft Lockdown C NONROAD model (dated May 2002). Using emission estimates, seasonal and daily county-to-national ratios were then develupdated national estimates per season estimated from the Lockdown C model. 

 1970, 1975, 

1978, & 1980 

VOC, NOx, CO, SO2, 

PM10, PM2.5

Using EPA’s draft Lockdown C NONROAD model (dated May 2002), developemissions for all years by running 4 seasonal NONROAD model runs to estimatemissions. Also performed national NONROAD model runs to estimate typical 
2-4 

Table 2-2. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources (Continued)

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method*

Nonroad Gasoline, Diesel, LPG, and CNG (Continued) 

1996, 1997, 1998, 1999, 2000, & 2001 

NH3 Obtaining national fuel consumption estimates from the Lockdown C NONROA

NH3 emission factors, and distributing to counties using 1996 inventory, based o

NONROAD. NH3 emissions for California were also recalculated using updated 

values generated for California-specific runs, and assuming the 1996 county-lev

1985 & 1990 NH3 Obtaining national fuel consumption estimates from the Lockdown C NONROA

NH3 emission factors, and distributing to counties using 1996 inventory, based o

NONROAD. 

1987 NH3 Obtaining 1987 national fuel consumption estimates from Lockdown C NONRO

by NH3 emission factors. 

1970, 1975, 1978, & 1980 

NH3 Obtaining national fuel consumption estimates from the Lockdown C NONROA

NH3 emission factors. 

 1990, 1996, & 

1999 

HAPs Speciation profiles applied to county VOC and PM estimates. Metal HAPs were 

activity-based emission factors. Some state data were provided and replaced nat

AircraftCommercial Aircraft 2008 Criteria and HAPs Federal Aviation Administration (FAA) Emissions and Dispersion Modeling Sy

5.1.was run using BTS T-100 LTO data. (2009) 

2002 and 2005 Criteria and HAPs Federal Aviation Administration (FAA) Emissions and Dispersion and Modelin

for criteria pollutants, VOC and PM emissions were speciated into HAP compo

1990, 1996, 1999, 2000, 2001 

VOC, NOx, CO, SOx Input landing and take-off (LTO) data into FAA EDMS. National emissions we

on airport specific LTO data and BTS GIS data. State data replaced national est

1970-1998 VOC, NOx, CO, SOx Estimated emissions for interim years using linear interpolation between availab1990, 1996, 1999 

HAPs Speciation profiles were applied to VOC estimates to get national HAP estimate

national estimates. (2003) 

General Aviation, Air Taxis 

2008 Criteria and HAPs Federal Aviation Administration (FAA) Emissions and Dispersion Modeling Sy

5.1.was run using BTS T-100 LTO for aircraft identified as Air taxis. (2010) Used FAA LTO data from TAF and OTAQ provided activity data for smaller ai

5010 master plans. EPA approved generic emission factors for criteria estimates

applied to VOC and PM estimates to get national HAP estimates. (2010) 
2-5 

Table 2-2. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources (Continued)

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method*

General Aviation, Air Taxis (Continued) 

2005 VOC, NOx, CO, SO2, 

PM10, PM2.5

2002 emissions for approximately 4,000 largest airports were calculated via EDincluded in the 2005 NEI as point sources. Only airports in FAA’s T100 and TAState point source submittals were incorporated. 

1978, 1987, 1990, 1996, 1999, 2000, 2001, & 2002 

VOC, NOx, CO, SO2, 

PM10, PM2.5

Used FAA LTO data and EPA approved emission factors for criteria estimates. 

applied to VOC estimates to get national HAP estimates. State data replaced nat

 1970-1998 VOC, NOx, CO, SOx, 

PM10, PM2.5

Estimated emissions for interim years using linear interpolation between availab

 1990, 1996, 

1999, & 2002 

HAPs Used FAA LTO data and EPA approved emission factors for criteria estimates. 

applied to VOC estimates to develop national HAP estimates. (2004) 

 1990, 1996, 

1999, & 2002 

Pb Used Department of Energy (DOE) aviation gasoline usage data with lead conce

(2004) 

 1996 NH3 Applied NH3 emissions factors to 1996 national jet fuel and aviation gasoline coMilitary Aircraft 2008 VOC, NOx, CO, SO2, 

PM10, PM2.5

Used FAA LTO data as reported in TAF and EPA approved emission factors foRepresentative HAP profiles were not readily available, therefore HAP estimate

2005 VOC, NOx, CO, SO2, 

PM10, PM2.5

2002 emissions were included in the 2005 NEI as point sources similar to other 

1978, 1987, 1990, 1996, 1999, 2000, 2001, 2002, 2008 

VOC, NOx, CO, SO2, 

PM10, PM2.5

Used FAA LTO data as reported in TAF and EPA approved emission factors foRepresentative HAP profiles were not readily available, therefore HAP estimate

 1970-1998 VOC, NOx, CO, SOX, 

PM10, PM2.5

Estimated emissions for interim years using linear interpolation between availab

Auxiliary Power Units and Ground Support Equipment 

2008 VOC, NOx, CO, SO2, 

PM10, PM2.5, HAPs 

Federal Aviation Administration (FAA) Emissions and Dispersion and Modelin5.1.was run using BTS T-100 LTO data. (2009) 

2002 and 2005 VOC, NOx, CO, SO2, 

PM10, PM2.5, HAPs 

Computed via NONROAD2005 model runs 

1985-2001 VOC, NOx, CO, SO2, 

PM10, PM2.5

Grew 1996 emissions to each year using LTO operations data from the FAA. Es1996 reported in EPA, 1998. 
2-6 

Table 2-2. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources (Continued)

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method*

Unpaved Airstrips1 1985-2001 PM10, PM2.5 Grew 1996 emissions to each year using SIC 45-Air Transportation growth fac

current draft version of EGAS. Estimation methods prior to 1996 reported in EP

Aircraft Refueling1 1985-2001 VOC Grew 1996 emissions to each year using SIC 45-Air Transportation growth fac

current draft version of EGAS. Estimation methods prior to 1996 reported in EP

Commercial Marine Vessel (CMV)All CMV Categories 2008 VOC, NOx, CO, SO2, 

PM10, PM2.5

OTAQ provided CAP emission estimates for all CMV categories. Note that the changed such that the Diesel category refers to smaller vessels (Category 1 and the Residual category refers to larger (Category 3) vessels using a blend of resiallocated to segments using GIS shapefiles and adjusted based on limited state 

 2008 HAPs OTAQ’s 2008 estimates were speciated into HAP components using SEPA proCMV Diesel 2002 and 

2005 

VOC, NOx, CO, SO2, 

PM10, PM2.5

2001 Estimates carried over. Used state data when provided. (2004) 

HAPs 1999 Estimates carried over. Used state data when provided. (2004) 

1978, 1987, 1990, 1996, 1999, 2000, & 2001 

VOC, NOx, CO, SOx, 

PM10, & PM2.5

Used criteria emission estimates in the background document for marine diesel Adjusted 2000 criteria emission estimates for other used based on fuel usage. Einto port traffic and underway activities. Port emissions were assigned to specifcargo handled. Underway emissions were allocated based on Army Corp of EnState data replaced national estimates. (2003) 

 1970-1998 VOC, NOx, CO, SOx, 

PM10, PM2.5

Estimated emissions for interim years using linear interpolation between availa

 1990, 1996, 

1999 

HAPs VOC and PM emission estimates were speciated into HAP components. State d

estimates. (2003) 

 1996 NH3 Applied NH3 emissions factors to 1996 distillate and residual fuel oil estimates 

1996). 

 1990-1995 NH3 Estimation methods reported in EPA, 1998. 
2-7 

Table 2-2. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources (Continued)

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method*

CMV Steam Powered 

2005 VOC, NOx, CO, SOx, 

PM10, & PM2.5, HAPs 

2002 estimates grown to 2005 (2008). 

2002 VOC, NOx, CO, SOx, 

PM10, & PM2.5, HAPs 

2002 based estimates were developed for port and underway category 3 (C3) veeffort. Emissions were developed separately for near port and underway emissiemissions, inventories for 2002 were developed for 89 deep water and 28 Great Waterway Network Ship Traffic, Energy, and Environmental Model (STEEM) emissions from ships traveling in shipping lanes between and near individual po

1978, 1987, 1990, 1996, 1999, 2000, & 2001 

VOC, NOx, CO, SOx, 

PM10, & PM2.5

Calculated criteria emissions based on EPA SIP guidance. Emissions were disaand under way activities. Port emissions were assigned to specific ports based o

Underway emissions were allocated based on Army Corp of Engineering waternational estimates. (2003) 

 1970-1998 VOC, NOx, CO, SOx, 

PM10, PM2.5

Estimated emissions for interim years using linear interpolation between availab

 1990, 1996, & 

1999 

HAPs VOC and PM emission estimates were speciated into HAP components. State d

estimates. (2003) 

Military Marine 1997-2001 VOC, NOx, CO, SO2, 

PM10, PM2.5

Applied EGAS growth factors to 1996 emissions estimates for this category. 

CMV Coal,2 CMV, 

Steam powered, CMV Gasoline2

1997-1998 VOC, NOx, CO, SO2, 

PM10, PM2.5

Applied EGAS growth factors to 1996 emissions estimates for this category. 

CM Coal, CMV, Steam powered, CMV Gasoline, Military Marine 

1991-1995 VOC, NOx, CO, SO2, 

PM10, PM2.5

Estimation methods reported in EPA, 1998. 

LocomotivesClass I, II, III and Yard operations 

2008 VOC, NOx, CO, PM10, 

PM2.5,SOx & HAPs 

Criteria emission estimates were provided to EPA by ERTAC. These data 

railway segments using DOT shapefiles and guidance from ERTAC. HAP by applying speciation profiles to VOC and PM estimates. (2010) 
2-8 

Table 2-2. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources (Continued)

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method*

Class I, Class II, Commuter, Passenger, and Yard Locomotives 

1978, 1987, 1990, 1996, 1999, 2000, 2000, 2002, & 2005 

VOC, NOx, CO, PM10, 

PM2.5

Criteria pollutants were estimated by using locomotive fuel use data from DOE factors. County-level estimates were obtained by scaling the national estimates DOT. State data replaced national estimates. (2004) 

1978, 1987, 1990, 1996, 1999, 2000, 2001, 2002, & 2005 

SO2 SOx emissions were calculated by using locomotive fuel use and fuel sulfur con

County-level estimates were obtained by scaling the national estimates with the data from DOT. State data replaced national estimates. (2004) 

1970-1998 VOC, NOx, CO, SOx, 

PM10, PM2.5

Estimated emissions for interim years using linear interpolation between availab

1990, 1996, 1999, & 2002 

HAPs HAP emissions were calculated by applying speciation profiles to VOC and PM 

estimates were obtained by scaling the national estimates with the county level State data replaced national estimates. (2004) 

 1997-1998 NH3 Grew 1996 base year emissions using EGAS growth indicators.  1996 NH3 Applied NH3 emissions factors to diesel consumption estimates for 1996.  1990-1995 NH3 Estimation methods reported in EPA, 1998. 

Notes: * Dates included at the end of Estimation Method represent the year that the section was revised. 

1 Emission estimates for unpaved airstrips and aircraft refueling are included in the area source NEI, since they represent non-engine emis

2 National Emission estimates for CMV Coal and CMV Gasoline were not developed though states and local agencies may have submitted 

categories. EPA, 1998. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Emission Factors and Inventory GrouEmission Trends, Procedures Document, 1900–1996, EPA-454/R-98-008. May 1998. 
3-1 

3.0 HOW WERE LOCOMOTIVE EMISSIONS ESTIMATED? 

ERTAC Rail used confidential railroad-provided data to generate railroad-specific 

criteria emission estimates for line haul and rail yards at the rail segment and rail yard level, 

respectively. Appendices A-C provide more detail on how emissions were developed and 

includes critical data used in calculating these estimates. This section of the report describes the 

emission estimating methods used in general terms as well as the approach for reallocating the 

emissions to protect confidential data. The data and documentation provided with respect to 

ERTAC Rail’s emission estimates pertain to the version that was incorporated into the NEI and 

does not reflect recent revisions. 

3.1 Line Haul Criteria Emissions Estimates 

Criteria pollutant emissions were estimated by applying emission factors to the total 

amount of distillate fuel oil used by line haul locomotives. Fuel usage was obtained from 

publically available Class I Railroad Annual Reports (Form R-1). The R-1 reports are submitted 

to the Surface Transportation Board annually and include financial and operations data to be 

used in monitoring rail industry health and identifying changes that may affect national 

transportation policy. Additionally, each railroad provided fleet mix information that allowed 

ERTAC Rail to calculate railroad-specific emission factors. Weighted Emission Factors (EF) 

per pollutant for each gallon of fuel used (gm/gal or lbs/gal) were calculated for each Class I 

railroad fleet based on its fraction of line haul locomotives at each regulated Tier level. EPA 

emission factors were used for PM2.5, SO2, and NH3. 

The weighted emission factors were then applied to the link-specific fuel consumption to 

obtain emissions for each rail segment. Given the confidentiality of the activity data, emissions 

for criteria pollutants were provided to EPA by ERTAC Rail by county for Class I line haul. 

Class II/III rail was provided by railroad company and county. Appendices A and B provide 

more detail on the Class I and Class II/III line haul emission development, respectively. 

3.2 Rail Yard Criteria Emissions Estimates 

Rail yard locations were identified using a database from the Federal Railroad 

Administration. Criteria pollutant emissions were estimated by applying emission factors to the 

total amount of distillate fuel used by locomotives. Each railroad provided fleet mix information 

that allowed ERTAC to calculate railroad-specific emission factors. The company-specific, 

system wide fleet mix was used to calculate weighted average emissions factors for switchers 

operated by each Class I railroad. EPA emission factors were used for PM2.5, SO2, and NH3. 

R-1 report-derived fuel use was allocated to rail yards using an approximation of line 

haul activity data within the yard; see Appendix C for more details. These fuel consumption 

values were further revised by direct input from the Class I railroads. The weighted emission 

factors were then applied to the yard-specific fuel consumption to obtain emissions for each 

yard. Since the rail yard inventory was based on publically-available data, the final criteria 

emission estimates were provided per rail yard. 
3-2 

3.3 Hazardous Air Pollutant Emissions Estimates 

HAP emissions were estimated by applying speciation profiles to the VOC or PM 

estimates. The speciation profiles were derived from Evaluation of Factors that Affect Diesel 

Exhaust Toxicity (Truex and Norbeck, 1998), and data provided by OTAQ (Scarbro, 2001 and 

2002). It should be noted that since California uses low sulfur diesel fuel and emission factors 

specific for California railroad fuels were available, calculations of the state’s emissions were 

done separately from the other states. The HAP speciation profile used in this effort is shown in 

Table 3-1. HAP estimates were calculated at the yard and link level, after the criteria emissions 

had been allocated. 

Table 3-1. Hazardous Air Pollutant Speciation Profile for 2008 Locomotive Emission 

Estimation 

Pollutant Name California All Other 

States 

Speciation 

Base 

1,3 Butadiene 0.0000615 0.0047735 PM10

2-2-4 Trimethylpentane 0.0022425 0.0022425 VOC 

Acenaphthene 0.0000080 0.0000306 PM10

Acenaphthylene 0.0002182 0.0004275 PM10

Acetaldehyde 0.0004492 0.0276274 PM10

Acrolein 0.0000855 0.0045943 PM10

Anthracene 0.0000535 0.0001009 PM10

Arsenic 0.0000004 0.0000004 PM10

Benzene 0.0000517 0.0038020 PM10

Benzo(a)anthracene 0.0000121 0.0000160 PM10

Benzo(a)pyrene 0.0000044 0.0000027 PM10

Benzo(b)fluoranthene 0.0000044 0.0000064 PM10

Benzo(ghi)perylene 0.0000044 0.0000031 PM10

Benzo(k)fluoranthene 0.0000044 0.0000052 PM10

Beryllium 0.0000280 0.0000280 PM10

Cadium 0.0000280 0.0000280 PM10

Chromium (III) 0.0000001 0.0000040 PM10

Chromium (VI) 0.0000000 0.0000021 PM10

Chrysene 0.0000092 0.0000119 PM10

Dibenz(a,h)anthracene 0.0000000 0.0000000 PM10

Ethylbenzene 0.0020000 0.0020000 VOC 

Fluoranthene 0.0000601 0.0000746 PM10

Fluorene 0.0000619 0.0001407 PM10

Formaldehyde 0.0009451 0.0636582 PM10

Indeno(1,2,3-cd)pyrene 0.0000033 0.0000027 PM10

Lead 0.0000840 0.0000840 PM10

Manganese 0.0000020 0.0000020 PM10

Mercury 0.0000280 0.0000280 PM10

Napthalene 0.0018505 0.0025756 PM10

n-Hexane 0.0055000 0.0055000 VOC 
3-3 

Table 3-1. Hazardous Air Pollutant Speciation Profile for 2008 Locomotive Emission 

Estimation (Cont.) 

Pollutant Name California All Other 

States 

Speciation 

Base 

Nickel 0.0000066 0.0000066 PM10

Phenanthrene 0.0002822 0.0005671 PM10

Propionaldehyde 0.0061000 0.0061000 VOC 

Pyrene 0.0000771 0.0001054 PM10

Styrene 0.0021000 0.0021000 VOC 

Toluene 0.0032000 0.0032000 VOC 

Xylene 0.0048000 0.0048000 VOC 
4-1 

4.0 HOW WERE COUNTY LINE HAUL EMISSIONS REALLOCATED 

TO INDIVIDUAL RAIL SEGMENTS? 

4.1 Class I Line Haul Emissions Allocation 

Class I line haul emissions were allocated to rail segments based on segment-specific 

railroad traffic data (ton miles) obtained from the Department of Transportation (BTS, 2009). 

This dataset categorizes the segments’ level of activity into ranges of MGTM and is populated 

by FRA. Emissions were divided between all mainline segments using these activity ranges as a 

proxy to allocate more emissions to segments with higher activity. 

Since the activity data were provided as ranges, a single “allocation value”, typically the 

midpoint of the range, was selected for use in the emissions allocation. The exception to this 

was the “0” activity category, which by definition had “unknown” activity. As a result, most 

mainline segments with the “0” activity category were not included in the emissions 

calculation/allocation. However, there was a small subset of segments that did have known 

activity values in the confidential data set but were labeled as “unknown” in the publically 

available data set. Those segment IDs were provided by ERTAC Rail for inclusion in the 

emission allocation; however, the activity of these segments was averaged to protect confidential 

data. Table 4-1 lists the activity categories along with their ranges in MGTM/mi and the 

allocation value used in the emissions spatial allocation. 

Table 4-1. Line Haul Segment Activity (MGTM/Mi) Categories 

Category 

Range 

Minimum

Range 

Maximum

Allocation 

Value Used

0* 0.0003 0.09 0.01233

1 0.1 4.9 2.5

2 5 9.9 7.45

3 10 19.9 14.95

4 20 39.9 29.95

5 40 59.9 49.95

6 60 99.9 79.95

7 100 1000000 100

* The “0” category has “unknown” activity in the publically 

available segment data. As a result, this table lists the minimum, 

maximum, and average of the confidential activity data greater 

than zero that were categorized as “unknown” in the public data. 

The county emission sums were reallocated to the segments by multiplying the county 

emissions by the segment’s allocation value divided by the sum of the allocation values for all 

links within the county. 
4-2 

∑=

= ∗

N

C

LC

L

iL iC

A

A

E E

1

Where: 

EiL = Emissions of pollutant i per link L (tons/year). 

EiC = Emissions of pollutant i per county C (tons/year). 

AL = Allocation value for link L per activity category from public BTS dataset 

ALC = Sum of allocation values for all links in county C from public BTS dataset 

 Note that rail line data for Puerto Rico, U.S. Virgin Islands, and Hawaii data were not 

included in ERTAC Rail’s shapefile and were developed separately; however, since these areas 

have exclusively Class II/III railroads present, these efforts are discussed in the following 

section. 

4.2 Class II/III Line Haul Emissions Allocation 

ERTAC Rail created a shapefile of Class II/III mainline rail segments from their FRAprovided proprietary shapefile as described in Appendix B for the contiguous 48 states and 

Alaska. Raw rail line data for Puerto Rico were obtained from USGS (Scanlon and Briere, 

2000), and rail line data for Hawaii was obtained from ESRI’s Digital Chart of the World (ESRI 

2010). The U.S. Virgin Islands have no rail lines. Because Class II/III railroads are less likely to 

use rail segments that are heavily traveled by Class I railroads, the activity-based approach used 

for Class I lines was not appropriate. Instead, Class II/III line haul emissions were allocated to 

rail segments using segment length as a proxy. 

The county emission sums were reallocated to the segments by multiplying the county 

emissions by the segment’s length divided by the sum of the length for all links within the 

county. 

∑=

= ∗

N

C

LC

L

iL iC

l

l E E

1

Where: 

EiL = Emissions of pollutant i per link L (tons/year). 

EiC = Emissions of pollutant i per county C (tons/year). 

lL = Allocation value for link L per activity category from public BTS dataset 

lLC = Sum of allocation values for all links in county C from public BTS dataset 

Since ERTAC Rail used proprietary data to develop the shapefile, some segment IDs 

were not found in the EIS data set. These segments were manually identified, and their 

emissions were allocated to the nearest segment within the EIS data set. 
4-3 

4.3 Rail Yard Emissions Allocation 

Rail yard emissions were developed based on yard name and ownership properties. As a 

result, unique yards needed to be identified and emissions summed. Unfortunately, the yard data 

lacked detail necessary for confident duplicate checks and yard matching such as address, 

detailed yard name, etc. As a result, a GIS was used to find the centroid of the yards based on 

the latest public BTS rail network, using the yard name and FIPS. The list of unique yards was 

further examined against ERTAC’s data and within Google Earth to identify any yards that 

required further revision. A crosswalk of original ERTAC data to new, consolidated yard IDs 

facilitated the summing of activity and emissions. 753 unique yards were identified nationwide. 

This underestimate of the total number of yards is most likely due to using line-haul-focused data 

to identify locations and develop rail yard emissions. 

 Once the unique yards were identified and criteria emissions were summed at the yard, 

the PM and VOC-based HAP speciation profile was applied to estimate HAP emissions at each 

yard. 

4.4 State Provided Data 

In this version of NEI, state and local agencies were invited to provide locomotive data 

that replaced the estimates based on national fuel consumption. However, only a small rail yard 

dataset was received from Kentucky. Their rail yard list was compared with the ERTAC/ERG 

yard list, and 2 yards were found in both sets. These yards were merged so as to avoid 

duplication in activity or emissions. 

4.5 What are the Results? 

Table 3 summarizes the 2008 locomotive mobile source emission estimates. 

Table 3. 2008 Locomotive Emissions Data 

2008 Locomotive Criteria Emissions 

Pollutant Name Class I 

Line Haul 

Class II/III 

Line Haul Rail Yard TOTAL 

CO 110,969 5,055 9,152 125,176

NH3 347 16 27 390

NOX 754,433 51,342 73,741 879,516

PM10-PRI 25,477 1,264 2,086 28,827

PM25-PRI 23,439 1,163 2,024 26,626

SO2 7,836 357 619 8,811

VOC 37,941 1,896 4,824 44,661

2008 Locomotive Hazardous Air Pollutant Emissions 

Pollutant Name Class I Line 

Haul 

Class II/III 

Line Haul Rail Yard TOTAL 

1,3 Butadiene 116.7941 5.7969 9.3296 131.9206

2-2-4 Trimethylpentane 85.0832 4.2511 10.8178 100.1521

Acenaphthene 0.7569 0.0376 0.0609 0.8554
4-4 

Table 3. 2008 Locomotive Emissions Data (Cont.) 

2008 Locomotive Hazardous Air Pollutant Emissions 

Pollutant Name Class I Line 

Haul 

Class II/III 

Line Haul Rail Yard TOTAL 

Acenaphthylene 10.6772 0.5298 0.8639 12.0709

Acetaldehyde 676.0572 33.5552 54.0089 763.6213

Acrolein 112.4351 5.5806 8.9828 126.9985

Anthracene 2.5231 0.1252 0.2042 2.8525

Arsenic 0.0091 0.0005 0.0007 0.0103

Benzene 93.0272 4.6173 7.4312 105.0757

Benzo(a)anthracene 0.4047 0.0201 0.0329 0.4577

Benzo(a)pyrene 0.0717 0.0036 0.0059 0.0812

Benzo(b)fluoranthene 0.1607 0.0079 0.0131 0.1817

Benzo(ghi)perylene 0.0798 0.0040 0.0066 0.0904

Benzo(k)fluoranthene 0.1312 0.0065 0.0107 0.1484

Beryllium 0.7138 0.0354 0.0584 0.8076

Cadium 0.7138 0.0354 0.0584 0.8076

Chromium (III) 0.0985 0.0049 0.0079 0.1113

Chromium (VI) 0.0508 0.0025 0.0041 0.0574

Chrysene 0.2998 0.0149 0.0244 0.3391

Ethylbenzene 75.8814 3.7914 9.6479 89.3207

Fluoranthene 1.8868 0.0936 0.1538 2.1342

Fluorene 3.5039 0.1739 0.2830 3.9608

Formaldehyde 1,557.66 77.3124 124.4335 1759.4059 

Indeno(1,2,3-cd)pyrene 0.0684 0.0034 0.0056 0.0774

Lead 2.1413 0.1062 0.1753 2.4228

Manganese 0.0520 0.0026 0.0043 0.0589

Mercury 0.7138 0.0354 0.0584 0.8076

Napthalene 64.8766 3.2187 5.2765 73.3718

n-Hexane 208.6739 10.4263 26.5317 245.6319

Nickel 0.1669 0.00983 0.0137 0.19043

Phenanthrene 14.1555 0.7024 1.1450 16.0029

Propionaldehyde 231.4383 11.5637 29.4261 272.4281

Pyrene 2.6566 0.1318 0.2161 3.0045

Styrene 79.6755 3.9809 10.1303 93.7867

Toluene 121.4103 6.0662 15.4366 142.9131

Xylene 182.1154 9.0993 23.1549 214.3696
5-1 

5.0 REFERENCES 

Bureau of Transportation Statistics, 2009. National Transportation Atlas Databases - National 

Rail Network 1:2,000,000. Washington, DC, Publisher: Bureau of Transportation Statistics. 

Energy Information Administration Form EIA-821, “Annual Fuel Oil and Kerosene Sales 

Report” for 1999. Table 23: Adjusted Sales for Transportation Use: Distillate Fuel Oil Residual 

Fuel Oil, 1999, U.S. 

ESRI, Digital Chart of the World Hawaii Rail line dataset 

http://data.geocomm.com/catalog/US/61094/group103.html July 27, 2010 

Fritz, Steve, Diesel Fuel Effects on Locomotive Exhaust Emissions, California Air Resource 

Board. SwRI 08.02062, October 2000. 

Porter, Fred L., U.S. Environmental Protection Agency, Emission Standards Division. Note to 

Anne Pope, U.S. EPA/Emissions, Monitoring and Analysis Division. Comments on combustion 

source information in the Baseline Emission Inventory of HAP Emissions from MACT Sources - 

Interim final Report (September, 18, 1998. November 13, 1998) 

Scanlon, Kathryn and Peter R. Briere, U.S. Geological Survey Open-File Report 00-006. Puerto 

Rico Marine Sediments, Terrestrial and Seafloor Imagery, and Tectonic Interpretations, 2000. 

http://pubs.usgs.gov/of/2000/of00-006/htm/index.htm 

Scarbro, Carl, E-mail entitled A Few Questions on the Rail Emissions - Reply, to Richard 

Billings, and Roger Chang, Eastern Research Group, Inc., United States Environmental 

Protection Agency Office of Transport and Air Quality. July 19, 2001

Scarbro, Carl, E-mail entitled Chromium in Loco’s - Reply, to Richard Billings, Eastern Research 

Group, Inc., United States Environmental Protection Agency Office of Transport and Air 

Quality. June 1, 2001

Scarbro, Carl, E-mail entitled Better Railroad Numbers This Will Disaggregate Class I Work, to 

Roger Chang, Eastern Research Group, Inc., United States Environmental Protection Agency 

Office of Transport and Air Quality. May 8, 2001

Scarbro, Carl, E-mail entitled CMV SOx corrections - Reply, to Richard Billings, Eastern 

Research Group, Inc., United States Environmental Protection Agency Office of Transport and 

Air Quality. May 28, 2002

Scarbro, Carl, E-mail entitled 2, 2, 4-trimethylpentane, to Richard Billings, Eastern Research 

Group, Inc., United States Environmental Protection Agency Office of Transport and Air 

Quality. June 1, 2001

Scarbro, Carl, E-mail entitled 2, 2, 4-trimethylpentane, to Roger Chang, Eastern Research Group, 

Inc., United States Environmental Protection Agency Office of Transport and Air Quality. 

March 26, 2002
5-2 

Truex, Timothy J. and Joseph M. Norbeck. Evaluation of Factors that Affect Diesel Exhaust 

Toxicity. University of California-Riverside, Center for Environmental Research and 

Technology. Riverside, CA. March 16, 1998. 

U.S. Environmental Protection Agency Form APR420-F-97-051, Emission Factors for 

Locomotives, for 1996 Table 9: Fleet Average Emission Factors for All Locomotives (Projected 

1999), December 1997 

U.S. Environmental Protection Agency, Locomotive Emission Standards Regulatory Support 

Document, page 109 April 1998. 

U.S. Environmental Protection Agency, Procedures for Emission Inventory Preparation, Volume 

IV: Mobile Sources.1992. 

U.S. Environmental Protection Agency. Procedures for Emission Inventory Preparation, 

Volume IV: Mobile Sources. Office of Air Quality Planning and Standards. Research Triangle 

Park, NC. 1989. 
Appendix A 

ERTAC Class I Line Haul Documentation 
A-1 

DRAFT 

ERTAC Rail Emissions Inventory 

Part 1: Class I Line-Haul Locomotives 

Michelle Bergin, GA Environmental Protection Division 

Matthew Harrell, IL Environmental Protection Agency 

Mark Janssen, Lake Michigan Air Directors Consortium 

Acknowledgments: 

Robert Fronczak, Association of American Railroads 

Raquel Wright, Federal Railroad Administration 

Julie McDill, Mid-Atlantic Regional Air Management Association 

Patrick Davis, Mid-Atlantic Regional Air Management Association 

Laurel Driver, US EPA, Office of Air Quality Planning and Support 

Byeong Kim, GA Environmental Protection Division 

Introduction 

Air protection agencies from twenty-seven states, coordinated through the Eastern Regional 

Technical Advisory Committee (ERTAC) and headed by the Lake Michigan Air Directors 

Consortium (LADCO), identified a need to better quantify and characterize rail-related emissions 

inventories. Traditional locomotives largely utilize diesel engines, resulting in emissions of 

NOx, diesel PM, hydrocarbons, greenhouse gases, and other pollutants. These emissions are 

sometimes concentrated in areas exceeding National Ambient Air Quality Standards. No 

cohesive nationwide railroad emission estimates based on local operations are known to have 

been made previously. Inventory development methods for locomotive emissions estimates vary 

from state to state and, in general, lack the spatial or temporal resolution needed to support air 

quality modeling and planning 1-5. 

The ERTAC Rail Subcommittee (ERTAC Rail) was established with active representatives from 

twelve member states, three regional planning offices, and the US EPA. The subcommittee’s 

goals are to (1) standardize agencies’ inventory development methods through a collaborative 

effort, (2) improve the quality of data received and the resulting emission inventories, and (3) 

reduce the administrative burden on railroad companies of providing data. 

With support from the Rail industry and assistance from the ERTAC Rail Data Workgroup 

(Appendix A), ERTAC Rail has developed 3 inventories of locomotive emissions (Table 1); 

from Class I line-haul, Shortline and Regional Railroads (Class II and III operations), and Class I 

railyard switchers. Because of the difficulty in obtaining data and differences in states’ needs for 

inventory years, sources from both 2007 and 2008 were utilized (Appendix B.) Due to the 

variability and uncertainty in much of the data, the results are considered applicable for either 

2007 or 2008. 
A-2 

The Surface Transportation Board (STB) defines Class I Railroads as having had minimum 

carrier operating revenues of $401.4 million (USD) in 2008. There are 8 Class I Railroads 

operating in the United States (Table 2), about 12 Regional Railroads (Class II), and 

approximately 530 Class III Railroads (Shortlines). While categorized as a Class I Railroad, 

Amtrak was excluded from these inventories because of significant differences in equipment and 

operation characteristics. Line-haul locomotives travel long distances (e.g. between cities) while 

switcher locomotives largely operate in railyards, splitting and joining rail cars with varying 

destinations. Passenger and Commuter Rail (including Amtrak), industrial locomotives, and 

associated non-locomotive equipment are not included in these inventories. 

This paper documents the data sources and methodologies used for calculating the Class I linehaul emissions inventory. Class I line-haul activities are the largest source of rail-related 

emissions, with estimates of Class I line-haul fuel consumption totals to be from 74 to 84% of all 

rail sources combined4, 5. For this reason, characterizing Class I line-haul emissions were a focal 

point of ERTAC Rail’s inventory development efforts. Information on ERTAC Rail, Railroad 

participation, the Rail industry, and effects of rail on air quality are available elsewhere6

. 

Table 1. Summary of ERTAC Rail Inventories: U.S. Locomotive Emissions and Fuel Use 

for either 2007 or 2008*. 

 Fuel Use** 

(gal/yr) 

Emissions (tons/yr) 

NOx PM2.5 HC SO2 CO NH3

Class I*** linehaul 3,770,914,002 754,443 23,439 37,941 7,836 110,969 347 

Class I switcher 300,492,223 73,741 2,024 4,824 619 9,152 27 

Class II and III 157,800,000 51,367 1,163 1,897 357 5,058 16 

*See Appendix B for a description of the year and source of data utilized for each inventory. 

**Locomotive grade diesel 

***Excluding Amtrak and including work train fuel use 

Table 2. Class I Railroads, Reported Locomotive Fuel Use, 

and Railroad Fuel Consumption Index (RFCI) 7. 

Class I Railroads* 

R-1 Reported Locomotive Fuel 

Use (gal/yr) RFCI 

Line-Haul (ton-miles/gal) 

(2007)** 

Switcher 

(2008) 

BNSF 1,393,874,954 52,497,057 883.14 

Canadian National 93,830,751 12,290,022 1190.79 

Canadian Pacific*** 50,320,233 4,594,067 1096.28 

CSX 514,687,186 53,717,674 963.81 

Kansas City Southern 69,787,071 1,816,759 785.89 

Norfolk Southern 463,267,278 32,317,375 865.75 

Union Pacific 1,185,146,529 143,470,336 974.64 

Total 3,770,914,002 300,492,223 929.47 
A-3 

* Excluding Amtrak 

** Includes work trains 

*** CP’s line-haul fuel use values include 2008 data (rather than 2007) for their Delaware and 

Hudson subsidiary. 

Method 

Earlier efforts to characterize line-haul railroad emissions relied on highly aggregated activity 

data (Figure 1), and generally apportioned annual system-wide fuel use equally across all route 

miles of track operated by a Class I railroad. However, the majority of freight tonnage carried by 

Class I railroads is concentrated on a disproportionately small number of route miles. In 

addition, emissions calculations were previously based on an estimate of annual nationwideaverage locomotive fleet mix to create one set of emissions factors. 

For this inventory, the Class I Railroads allowed ERTAC Rail access under a confidentiality 

agreement to a link-level (single lengths of track) line-haul GIS layer activity dataset managed 

by the Federal Railroad Administration9. Each railroad also provided fleet mix information that 

allowed ERTAC Rail to calculate weighted emission factors based on the fraction of their linehaul fleet meeting each Tier level category. The use of this data, largely following a line-haul 

inventory methodology recommended by Sierra Research2, 3, resulted in a link-level line-haul 

locomotive emission inventory using railroad-specific emission factors. This segment-level 

inventory is nationwide, aggregated to state and county level files, and will be released as 

gridded emissions files for use in photochemical and dispersion modeling. Link-level emissions 

may be provided for special study requests pending approval of any Class I railroads operating in 

the study domain. The calculations are described below as a two-part process, calculating 

railroad-specific factors and emissions per rail link. 

Figure 1. US Railroad Traffic Density in 2006.8

 MGT is million gross tons. 
A-4 

1. Calculate Railroad-Specific Factors.

The EPA provides annual default Emission Factors for locomotives based on characteristic 

operating cycles (‘duty cycles’) and the estimated nationwide fleet mixes for both switcher and 

line-haul locomotives. However, fleet mixes vary from railroad to railroad and, as can be seen in 

Figure 2, Class I railroad activity is highly regionalized in nature and subject to issues of local 

terrain such as operation on plains vs. mountainous areas, which can have a significant impact on 

fuel consumption and emissions. 

Figure 2. Class I Railroad Territories in the United States10. 

As an alternative approach to using a single nationwide set of emission factors, ERTAC Rail 

requested each Class I company to provide a description of their line-haul fleet mix based on 

Tier rating, which each company provided under a confidentiality agreement. An engine’s Tier 

level is based on the year the engine was built and determines allowable emission limits (Table 

3). 
A-5 

Table 3. EPA line-haul locomotive Emission Factors by Tier, 1997 standards (grams/gal). 

Note that the new standards released in 2008 did not apply to fleets in the year 2008. 11 

PM10 HC NOx CO 

Uncontrolled (pre-1973) 6.656 9.984 270.4 26.624 

Tier 0 (1973-2001) 6.656 9.984 178.88 26.624 

Tier 1 (2002-2004) 6.656 9.776 139.36 26.624 

Tier 2 (2005 + ) 3.744 5.408 102.96 26.624 

Based on values in EPA Technical Highlights: Emission Factors for Locomotives, EPA Office of 

Transportation and Air Quality, EPA-420-F-09-025, April 2009. 

Weighted Emission Factors (EF) per pollutant for each gallon of fuel used (gm/gal or lbs/gal) 

were calculated for each Class I railroad fleet based on its fraction of line-haul locomotives at 

each regulated Tier level (Eqn 1; Table 3). 

∑=

=

4

1

( * )

T

iRR iT TRR EF EF f Equation 1 

 EFiRR = Weighted Emission Factor for pollutant i for Class I railroad RR (gm/gal). 

 EFiT = Emission Factor for pollutant i for locomotives in Tier T (gm/gal) (Table 3). 

There were 4 Tiers of locomotives in the 2008 fleets. 

fTRR = Fraction of railroad RR fleet in Tier T. 

While engine emissions are variable within Tier categories, this approach likely provides better 

regional estimates than uniformly applying the nationwide average emission factors. This 

approach likely provides conservative emission estimates as locomotive engines are certified to 

meet or exceed the emissions standard for each Tier, although emission levels may increase after 

certification. 

Other emission factors are not engine specific. For locomotives, PM2.5 is assumed to be 97% of 

PM10

11, and emission factors applied for SO2 and NH3 are 1.88 g/gal 11 and 83.3 mg/gal 12

respectively. Greenhouse gases are estimated using emission factors shown in Table 4. 

Table 4. EPA greenhouse gas emission factors for locomotive diesel fuel (grams/gal). 13

CO2 N2O CH4

Locomotive diesel 1.015E4 0.26 0.80 

A Railroad Fuel Consumption Index (RFCI) was also calculated for each Class I railroad using 

their system-wide line-haul fuel consumption (FC) and gross ton-mile (GTM) data reported in 

their annual R-1 reports submitted to the Surface Transportation Board7

 (Eqn 2). This value 

represents the average number of GTM produced per gallon of diesel fuel used over their system 

in a year, and varies between railroad carriers depending on factors such as fleet mix, system 
A-6 

terrain, speeds, loading/weight of cargo, train type (e.g., intermodal, unit, and manifest), and 

operating practices. (Table 2). 

RR

RR

RR FC

GTM RFCI = Equation 2 

RFCIRR = Railroad Fuel Consumption Index (gross ton-miles/gal) per Class I railroad 

(RR). GTMRR = Gross Ton-Miles (GTM), annual system-wide gross ton miles of freight 

 transported per RR. (R-1 Report Schedule 755, Line 104) 

 FCRR = Annual system-wide fuel consumption by line-haul and work trains per RR 

(gal) (R-1 Report Schedule 750, Lines 1 and 6). 

2. Calculate Emissions per Link.

Emissions of pollutant i per link L (EiL) are then calculated by multiplying the gallons of diesel 

fuel consumed by each Class I railroad on the link by that railroad’s weighted Emission Factor 

for the pollutant, and summed over all railroads operating on the link (Eqn 3). This approach 

splits the activity on each link (represented by MGT) evenly between all railroads operating on 

the link. Note that the weighted Emission Factors are converted to tons/gal for these 

calculations, and that variables with units in tons may represent tons of freight hauled (MGT, 

RFCI) or tons of pollutants (EF, E). 

∑=

⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛

=

N

RR

iRR

RR

L

L

iL EF

RFCI

l

N

MGT

E

1

6

*

*

*10

 Equation 3 

EiL = Emissions of pollutant i per link L (tons/year). 

N = Number of Class I railroads operating on link L. 

MGTL = Millions of Gross Tons hauled per link per year from the FRA database 

 (106

 tons/yr)9. 

lL = Link length from the FRA database (miles). 

 EFiRR = Weighted Emission Factor for pollutant i per railroad RR (Eqn 1; tons/gal). 

 RFCIRR = Railroad Fuel Consumption Index per railroad RR (Eqn 2; gross 

 ton-miles/gal). 

Note that approximately 36% of Class I route miles in the United States are shared by more than 

one Class I carrier, a fraction that drops to 26% when neglecting track only shared between one 

Class I freight railroad and Amtrak. Accurately apportioning the specific fractions of tonnage 

(MGT) per carrier per link was considered, but after comparing likely worst-case areas, the 

difficultly of merging carrier-specific MGT with the aggregated FRA MGT dataset was 

considered too great considering the potential gain in accuracy. Where warranted, MGT data 

may be apportioned more accurately in the future. 
A-7 

Limitations, Conclusions, and Future Work 

Rail-related emissions can be important components of emissions inventories used to support 

effective air quality management practices, at local, state, regional, and national levels. This linehaul inventory, as well as the companion Class I railyard inventory and Class II/III inventory, 

greatly improve our estimates of rail-related emissions. However, a systematic study of 

variability and uncertainty in line-haul locomotive emissions and activity, by fleets, locations, 

and through time, would give valuable information for identifying how to best improve this 

inventory as well provide an indication of how representative the inventory may be. An 

uncertainty study on the data used for this inventory, including the R-1 reported fuel use and the 

confidential link-level tonnage data, would also help in evaluating the quality of this inventory. 

Localized studies should also examine how shared tracks are apportioned between multiple 

carriers. 

Early ERTAC Rail discussions concluded that link-level tonnage was the most important data to 

obtain, while other variables such as track grade and track speed could not be addressed at this 

time. ERTAC Rail calculated railroad-specific fleet-averaged emission factors rather than 

applying the estimated national average; however, it is recognized that emissions from individual 

engines are highly variable even within Tier categories depending on variables such as the 

specific locomotive model, operation cycle, and conditions of operation. Future evaluation of 

emission variability within Tiers and between certain types of operation and locations would also 

be valuable. 

Emissions inventory preparation guidance from the U.S. EPA describes locomotive activity as 

relatively constant throughout the year (e.g. no daily, weekly, or seasonal variability); however, 

actual activity levels do vary seasonally and annual averaging may dilute or exaggerate 

concentrations during pollution episodes. ERTAC Rail and the Class I railroad community had 

some discussions addressing if incorporating more specific fleet mix or monthly or seasonal 

variation may be worthwhile, and these topics should be looked into further. 

Finally, it is important to reiterate that the link-level MGT data maintained by the FRA is 

proprietary and can only be released to agencies/groups outside the FRA with the express 

permission of each Class I railroad. It is possible that one or more Class I railroads could 

withhold permission for access, but data for specialized studies may be provided if requested. 

This database can also be improved by better distinguishing between haulage and trackage rights, 

and by apportioning tonnage hauled on links to specific carriers. 

We would like to thank the Class I Railroads and their representatives for their assistance and 

support in the development of this inventory. 

References 

1. Eastern Research Group (ERG) for E.H. Pechan & Associates, Inc., “Documentation for 

Aircraft, Commercial Marine Vessel, Locomotive, and Other Nonroad Components of 

the National Emissions Inventory, Volume I – Methodology”; EPA Contract No.: 68-D02-063. Prepared for the US EPA Emissions, Monitoring and Analysis Division, Sept. 
A-8 

30, 2005. 

ftp://ftp.epa.gov/EmisInventory/2002finalnei/documentation/mobile/2002nei_mobile_no

nroad_methods.pdf. Related documents at 

ftp://ftp.epa.gov/EmisInventory/2002finalnei/documentation/mobile/2002nei_mobile_no

nroad_train.pdf 

2. Sierra Research, Inc., “Revised Inventory Guidance For Locomotive Emissions”; Report 

No. SR2004-06-01. Prepared for Southeastern States Air Resource Managers 

(SESARM), June 2004. http://www.metro4-sesarm.org/pubs/railroad/FinalGuidance.pdf 

3. Sierra Research, Inc., “Research Project: Development of Railroad Emission Inventory 

Methodologies”; Report No. SR2004-06-02. Prepared for Southeastern States Air 

Resource Managers (SESARM), June 2004. http://www.metro4-

sesarm.org/pubs/railroad/FinalMethodologies.pdf 

4. Environ, “Draft LADCO 2005 Locomotive Emissions”. Prepared for Lake Michigan Air 

Director Consortium, Feb 2007. 

http://www.ladco.org/reports/technical_support_document/references/ladco_2005_locom

otive_emissions.021406.pdf 

5. Southern Research Institute, “NYSERDA Clean Diesel Technology: Non-Road Field 

Demonstration Program, Development of the 2002 Locomotive Survey for New York 

State”; Agreement Number 8958. Prepared for the New York State Energy Research And 

Development Authority (NYSERDA), Feb. 09, 2007. 

http://www.nyserda.org/publications/LocomotiveSurveyReportwithAppendices.pdf

6. M. Bergin; M. Harrell; J. McDill; M. Janssen; L. Driver; R. Fronczak; R. Nath,; and D. 

Seep. "ERTAC Rail: A Collaborative Effort in Building a Railroad-Related Emissions 

Inventory Between Eastern States Air Protection Agencies and Participation with the 

Railroad Industry," 18th Annual International Emission Inventory Conference. 

Baltimore, MD. April 14 - 17, 2009. Paper and presentation available at: 

http://www.epa.gov/ttn/chief/conference/ei18/session6/bergin.pdf

7. Surface Transportation Board R-1 Reports, available at:

http://www.stb.dot.gov/stb/industry/econ_reports.html. 

8. US DOT Bureau of Transportation Statistics’ 2008 National Transportation Atlas 

Database. 

9. Confidential database was provided with assistance from Raquel Wright of the Federal 

Railroad Administration. Similar public data providing ranges of tonnage hauled rather 

than link-level tonnage is available from the Bureau of Transportation Statistics in the 

NTAD 2009 shapefile data (data is representative for the year 2007): 

http://www.bts.gov/publications/national_transportation_atlas_database/2009 . 

10. Freight Railroads in the United States 2008. Association of American Railroads. 

Available at: 

http://www.aar.org/~/media/AAR/InCongress_RailroadsStates/2008unitedstates.ashx . 

11. EPA Technical Highlights: Emission Factors for Locomotives, EPA Office of 

Transportation and Air Quality, EPA-420-F-09-025, April 2009. 

http://www.epa.gov/otaq/regs/nonroad/locomotv/420f09025.pdf 
A-9 

12. Estimating Ammonia Emissions From Anthropogenic Nonagricultural Sources - Draft 

Final Report by E.H. Pechan & Assoc. April 2004. Prepared for EPA/STAPPAALAPCO Emission Inventory Improvement Program. Supported by personal 

communication (5/6/2010) with Craig Harvey, US EPA, OTAQ, and Robert Wooten, NC 

DENR. http://www.epa.gov/ttnchie1/eiip/techreport/volume03/eiip_areasourcesnh3.pdf

13. U.S. Environmental Protection Agency. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 

1990-2005, EPA 430-R-07-002, Annex 3.2, (April 2007), web site: 

http://www.epa.gov/climatechange/emissions/usinventoryreport.html.

Appendix A: ERTAC Rail Data Workgroup

REPRESENTATIVE ORGANIZATION 

Matt Harrell IL EPA 

Michelle Bergin (Co-Chair) and Byeong Kim GA EPD 

Mark Janssen (Co-Chair) LADCO 

Julie McDill and Patrick Davis MARAMA 

Laurel Driver US EPA OAQPS 

Robert Fronczak AAR 

Steven Sullivan ASLRRA 

Rick Nath CSX 

David Seep and Lyle Staley BNSF 

Ken Roberge CPR 

Carl Akins and Peter Conlon KCS 

Erika Akkerman CN 

M. John Germer UP 

Brent Mason and Richard Russell NS 

Joanne Maxwell Amtrak 
A-10 

Appendix B: Source and Year of Data Utilized for Each Inventory 

Data Year Source 

Class I Line-Haul 

Annual Line-Haul Fuel Use 

and Gross Ton-Miles 2007 STB R-1 Reports (CP data for 

D&H is for 2008.) 

Line-haul fleet mix for 

emission factors 2008 Each Class I railroad 

Link-level tonnage 2007 FRA confidential database 

Class I Railyards (Switcher Locomotives) 

Annual Switcher Fuel Use 2008 R-1 Reports 

Switcher fleet mix for 

emission factors 2008 Each Class I railroad 

Link-level tonnage or 

Density Code (for activity 

estimate) 

2007 FRA confidential database 

Class II and III Locomotives 

Annual Total Fuel Use 2008 ASLRRA Annual Report (2008) 

Track length and railroad 2008 ASLRRA Annual Report (2008) 

Estimated fleet mix for 

emission factors 

Discussions with ASLRRA and 

Class II and III representatives. 
Appendix B 

ERTAC Class II/III Line Haul Documentation 
B-1 

DRAFT 

ERTAC – Class 2/3 Shapefile Documentation 

13 Jul 2009 

Introduction 

This document outlines the methods and procedures used to compile a shapefile representing the 

links in the FRA 1:100,000 railroad dataset that are owned or operated by Class II and III 

railroad companies. It is important to note that there is a considerable amount of overlap 

between the Class II’s and III’s and the Class I and passenger railroads. Class II’s and III’s can 

operate on Class I or passenger rail links and vice versa. Although the final shapefile 

specifically represents Class II and III links, there are many Class I and passenger railroads 

represented as well. 

Procedure 

1. Started with all proprietary FRA links where “NET = ‘M’ and “STCNTYFIPS” <> ‘ ‘ 

(this definition query selects all active mainline links located within the United 

States). 

2. Ran 12 queries, one for each ownership and trackage rights field, to select all links 

not associated with a Class I freight railroad or Amtrak and not containing a null 

value (e.g., "RROWNER1" <> 'AMTK' AND "RROWNER1" <> 'BNSF' AND 

"RROWNER1" <> 'CN' AND "RROWNER1" <> 'CPRS' AND "RROWNER1" <> 

'CSXT' AND "RROWNER1" <> 'KCS' AND "RROWNER1" <> 'NS' AND 

"RROWNER1" <> 'UP' AND "RROWNER1" <> ' '). The first query was setup as a 

new selection. Each of the 11 subsequent queries were setup to add records to initial 

set of records. 26,261 links were selected and exported to a new shapefile. 

3. Due to the multitude of railroad codes used to represent commuter rail operations 

across the country, additional processing was required to remove any links that were 

not operated by a Class II or III freight railroad. Each commuter railroad was queried 

out of the new shapefile and the links analyzed to eliminate all links where no Class II 

or III operations were occurring. The following commuter rail operations were 

evaluated: NJT (New Jersey Transit), MNCW (Metro-North Commuter Railroad), LI 

(Long Island Railroad), CDOT (Connecticut DOT), MBTA (Massachusetts Bay 

Transportation Authority), SEPA (Southeastern Pennsylvania Transportation 

Authority), MARC (Maryland Area Rail Commuter), VRE (Virginia Railway 

Express), MTRA (Northeastern Illinois Regional Commuter Railroad), CSS 

(Northern Indiana Commuter Transportation District), DART (Dallas Area Rapid 

Transit), SCRA (Southern California Regional Rail Authority – including also SCAX, 

LACM, LAPT, and LATC), TCRA (South Florida Regional Transportation 

Authority), PJPB (Caltrain), and ACE (Altamont Commuter Express). 
B-2 

Approximately 1581 links were identified with no Class II or III operations and were 

deleted from the Class 2/3 shapefile. 

4. The remaining Class II and III links were then compared to the regional maps 

contained in the July-August issue of The Official Railway Guide to assess the 

completeness of the Class 2/3 shapefile. Six specific edits were made to the shapefile 

to correct the most glaring errors: 1) BMLP links deleted (Black Mesa & Lake 

Powell, an electric coal hauling railway in Arizona); 2) DSNG links deleted (Durango 

& Silverton steam tourist railroad in Colorado; 3) CIC haulage rights links on CN 

from Chicago to Omaha deleted; 4) DMIR links deleted (Duluth, Missabe & Iron 

Range, now owned and operated by CN in Minnesota; 5) EVWR’s ex-CSXT links 

coded from Evansville, IN to Okawville, IL (Evansville Western Railroad); 6) INRD 

ex-CP links coded from Chicago, IL to Louisville, IN (Indiana Rail Road). 

5. During the course of reviewing the FRA dataset, 555 “active” links were found to 

have no ownership or trackage rights codes. 1005 links have no codes listed in the 3 

ownership fields. In most cases these links are very short and scattered across the 

country. Only the links representing the EVWR and INRD spanned large distances 

and were fixed. The other problem links were deemed to be insignificant. A listing of 

these links will be provided back to the FRA to assist with their coding in 1:100K 

railway shapefile. 
Appendix C 

ERTAC Rail Yard Documentation 
C-1 

DRAFT 

ERTAC Rail Emissions Inventory 

Part 2: Class I Railyard Switcher Locomotives 

Michelle Bergin, GA Environmental Protection Division 

Matthew Harrell, IL Environmental Protection Agency 

Mark Janssen, Lake Michigan Air Directors Consortium 

Acknowledgments: Robert Fronczak, Association of American Railroads 

 Laurel Driver, US EPA, Office of Air Quality Planning and Support 

 Byeong Kim, GA Environmental Protection Division 

Introduction 

Air protection agencies from twenty-seven states, coordinated through the Eastern Regional 

Technical Advisory Committee (ERTAC) and headed by the Lake Michigan Air Directors 

Consortium (LADCO), identified a need to better quantify and characterize rail-related emissions 

inventories. Traditional locomotives largely utilize diesel engines, resulting in emissions of 

NOx, diesel PM, hydrocarbons, greenhouse gases, and other pollutants. These emissions are 

sometimes concentrated in areas exceeding National Ambient Air Quality Standards. No 

cohesive nationwide railroad emission estimates are known to have been made previously. 

Inventory development methods for locomotive emissions estimates vary from state to state and, 

in general, lack the spatial or temporal resolution needed to support air quality modeling and 

planning 1-5. 

The ERTAC Rail Subcommittee (ERTAC Rail) was established with active representatives from 

twelve member states, three regional planning offices, and the US EPA. The subcommittee’s 

goals are to (1) standardize agencies’ inventory development methods through a collaborative 

effort, (2) improve the quality of data received and the resulting emission inventories, and (3) 

reduce the administrative burden on railroad companies of providing data. With support from 

the Rail industry and assistance from the ERTAC Rail Data Workgroup (Appendix), ERTAC 

Rail has developed 3 inventories of locomotive emissions; from Class I line-haul, Shortline and 

Regional Railroads, and Class I railyard switchers, for the year 2008 (Table 1). 

The Surface Transportation Board (STB) defines Class I Railroads as having had minimum 

carrier operating revenues of $401.4 million (USD) in 2008. There are 8 Class I Railroads 

operating in the United States (Table 2), about 12 Regional Railroads (Class II), and 

approximately 530 Class III Railroads (Shortlines). While categorized as a Class I Railroad, 

Amtrak was excluded from these inventories because of significant differences in equipment and 

operation characteristics. Line-haul locomotives travel long distances (e.g. between cities) while 

switcher locomotives largely operate in railyards, splitting and joining rail cars with varying 

destinations. Passenger and Commuter Rail (including Amtrak), industrial locomotives, and 

associated non-locomotive equipment are not included in these inventories. 
C-2 

Table 1. Summary of ERTAC Rail Inventories: U.S. Locomotive Emissions and Fuel Use for 

either 2007 or 2008*. 

 Fuel Use** 

(gal/yr) 

Emissions (tons/yr) 

NOx PM2.5 HC SO2 CO NH3

Class I*** linehaul 3,770,914,002 754,443 23,439 37,941 7,836 110,969 347 

Class I switcher 300,492,223 73,741 2,024 4,824 619 9,152 27 

Class II and III 157,800,000 51,367 1,163 1,897 357 5,058 16 

*See Appendix B for a description of the year and source of data utilized for each inventory. 

**Locomotive grade diesel 

***Excluding Amtrak and including work train fuel use 

Table 2. Class I Railroads and Reported Locomotive Fuel Use7

. 

Class I Railroads* 

R-1 Reported Locomotive Fuel 

Use (gal/yr) 

Line-Haul 

(2007)** 

Switcher 

(2008) 

BNSF 1,393,874,954 52,497,057 

Canadian National 93,830,751 12,290,022 

Canadian Pacific*** 50,320,233 4,594,067 

CSX 514,687,186 53,717,674 

Kansas City Southern 69,787,071 1,816,759 

Norfolk Southern 463,267,278 32,317,375 

Union Pacific 1,185,146,529 143,470,336 

Total 3,770,914,002 300,492,223 

* Excluding Amtrak 

** Includes work trains 

*** CP’s line-haul fuel use values include 2008 data (rather than 2007) for 

their Delaware and Hudson subsidiary. 

This paper documents the data sources and methodologies used for calculating the Class I 

switcher (“Railyard”) inventory. Information on ERTAC Rail, Railroad participation, the Rail 

industry, and effects of rail on air quality are available elsewhere6

. 

Method 

Switcher locomotives are expected to be the single largest source of air emissions in railyards. 

Therefore, as a starting point for a comprehensive railyard inventory, a Class I switcher emission 

inventory was developed. It is assumed that estimates for yards of interest, associated equipment 

and activity, and smaller railroads could be refined later. 

While ERTAC Rail represents states east of the Mississippi River, the railroad companies 

specified they wanted this effort to result in a consistent nationwide inventory. ERTAC Rail 

agreed to calculate emissions for all states when the data was available and when additional 
C-3 

significant effort was not required. Because both the dataset of railyards and switcher fuel use 

was nationwide in scope, the resulting initial railyard inventory is a nationwide, ‘top-down’ 

derivation. However, railroad companies may have different levels and quality of data available, 

and may have interpreted some data requests differently. Also, states are requested to update 

yards they have detailed information on when possible, and a few states (i.e. California) have 

unique railroad operations and equipment. Therefore, data for some areas will be more accurate 

than for others, and locally-derived inventories may be more accurate. 

This documentation describes development of the initial top-down inventory, which consisted of 

three main activities: 

1. Locate Class I Railyards 

2. Select/Calculate Emission Factors 

3. Estimate Locomotive Activity 

4. Improve Estimates 

1. Locate Class I Railyards. 

Identification and correct placement of railyards was an important first step, requiring a 

comprehensive electronic dataset. A confidential database was obtained from the Federal 

Railroad Administration (FRA) with permission from the Class I Railroads (FRA database). A 

similar public database compiled by the Bureau of Transportation Statistics is also available7

 . 

Data from this source will not match the confidential data exactly, but will be very similar. The 

FRA database has rail links (track lengths) individually identified as parts of specific railyards. 

While there may be discrepancies in how each railroad defined railyard links, this dataset 

appears to identify most Class I railyards in the U.S., and shows a high density of yards in the 

eastern states (Figure 1). The database gives length, up to 3 owners and 3 operators, and a 

Federal Density Code (explained below) for each railyard link. 

Figure 1. Class I Railyards in the United States and estimates of Annual NOx 

emissions from switcher locomotives (tons/yr in 2008). 
C-4 

2. Select/Calculate Emission Factors.

The EPA provides annual default emission factors based on characteristic operating cycles (‘duty 

cycles’) and the estimated nationwide fleet mix for both switcher and line-haul locomotives. 

However, switcher fleet mix is not uniform from company to company and, as can be seen in 

Figure 2, Class I railroad activity is highly regional. 

As an alternative approach, ERTAC Rail requested each Class I rail company to provide a 

description of their switcher fleet mix based on Tier rating, which each company provided under 

a confidentiality agreement. An engine’s Tier determines allowable emission limits based on the 

year the engine was built (Table 3). While engine emissions are variable within Tier categories, 

this estimate likely provides a better regional estimate than the nationwide average. The 

company-specific systemwide fleet mix was used to calculate weighted average emissions 

factors for switchers operated by each Class I railroad. 

Figure 2. Class I Railroad Territories in the United States. 

Table 3. EPA switcher locomotive emission factors by Tier, 1997 standards (grams/gal). 

PM10 HC NOx CO 

Uncontrolled (pre-1973) 6.688 15.352 264.48 27.816 

Tier 0 (1973-2001) 6.688 15.352 191.52 27.816 

Tier 1 (2002-2004) 6.536 15.352 150.48 27.816 

Tier 2 (2005 + ) 2.888 7.752 110.96 27.816 

Listed years apply to the year the engine was built. Table based on values from 8. Note that the new standards 

released in 2008 did not apply to existing fleets in the year 2008. 
C-5 

For locomotives, PM2.5 is assumed to be 97% of PM10

8

, and emission factors for SO2 and NH3

are 1.88 g/gal and 83.3 mg/gal respectively (add cites). Greenhouse gases are also estimated 

using emission factors shown in Table 4. 

Table 4. EPA greenhouse gas emission factors for locomotive diesel fuel (grams/gal). 

CO2 N2O CH4

Locomotive diesel 1.015E4 0.26 0.80 

Source: U.S. Environmental Protection Agency. Inventory of U.S. Greenhouse Gas Emissions and 

Sinks: 1990-2005, EPA 430-R-07-002, Annex 3.2, (April 2007), web site: 

http://www.epa.gov/climatechange/emissions/usinventoryreport.html

These emission factors are based on a characteristic duty cycle for switchers which assumes 

operation over 24-hour per day 365 days per year. An evaluation of the effect of variability in 

railyards and switching duties on emissions would be useful for future inventories. 

3. Estimate Locomotive Activity.

Class I railroads report total annual switcher locomotive fuel use to the STB, which is reported in 

publicly available ‘R-1’ reports (Table 2). There may be inconsistencies between railroads in 

how fuel use is estimated to be apportioned between line-haul and switcher locomotive use, and 

possibly in the total locomotive fuel use, so these values may be adjusted in the future. 

However, the use of these values provides a starting point for estimating total U.S. Class I 

locomotive-related emissions segregated by Class I carrier. The R-1 report was used by ERTAC 

for both the line-haul and switcher locomotive emissions inventories. 

The next step for inventory development is to allocate switcher fuel use to each railyard. Two 

methods were applied, one that relies on publicly available line-haul activity (the ‘Dencode’ 

method), and the other using confidential line-haul activity (the ‘MGT’ method.) At this time, 

Norfolk Southern and Kansas City Southern have provided input for use of the MGT method and 

the Dencode method is applied for the other five railroads. 

The Dencode Method – Publicly available data 

Each link in both the publicly available BTS database and the confidential FRA database has a 

‘Federal Density Code’ (Dencode) ranging from 1 to 7 assigned based on the cumulative annual 

freight tonnage hauled on the link (track). Total Switcher Fuel Use in each railyard Y (SFUY) is 

estimated as follows: 

First the Switcher Activity Indicator per yard (SAIY) is estimated by multiplying the average 

dencode of the links identified as part of the same railyard by the sum of the length of the links 

for that railyard (Eqn 1). 

SAIY = ( * ) nY FDCnY ∑ l Equation 1 

SAIY = Switcher Activity Indicator in Railyard Y 
C-6 

nY = number of links identified as part of railyard Y 

lnY = length of link n in miles 

FDCn = Federal Density Code (1 to 7) of link n 

Next, this value is then weighted (SAIY’) based on an ownership factor (OF) set between 0 and 1. 

The OF depends on the number of owners listed for each railyard: if there is one owner the OF 

is set to 1, if there are two owners the primary owner is set to 0.8 and the secondary is 0.2, and if 

there are 3 owners the primary is 0.6, the secondary is 0.2, and the tertiary is 0.1. 

SAIY’ = OFY* SAIY Equation 2 

Next, the SAIY’ of all railyards belonging to a Class I railroad (RR) were summed, and the 

fraction of the railroads total SAI associated with each railyard was multiplied by the railroads 

total annual switcher fuel use reported in the R-1 (TFURR), resulting in the total Switcher Fuel 

Use for each railyard Y (Eqn 2). 

SFUY = RR

RR

Y

Y TFU

SAI

SAI *

'

'

∑ Equation 3 

SFUY = Switcher Fuel Use at railyard Y 

Finally, the SFUY is multiplied by the emission factors described in the previous section to 

obtain annual switcher emissions at each railyard. 

The MGT Method – Confidential data 

Two railroads, Norfolk Southern and Kansas City Southern, provided confidential link-level 

tonnage information and weighting factors to correct skewed estimates to improve estimated 

switcher activity at important yards. Other railroads may also allow the use of this technique for 

their inventories in the future. 

The MGT Method also uses the FRA database for railyard identification and link lengths. 

However, rather than using the average dencode per link, confidential annual gross tonnage 

(MGT) hauled per link in the railyard was used to calculate the railyard switcher activity (SAIY). 

This is calculated by replacing FDCn in Equation 2 with link-specific tonnage MGTn (Equation 

4). 

SAIY = ( * ) nY MGTnY ∑ l Equation 4 

SAIY = Switcher Activity Indicator in Railyard Y 

nY = number of links identified as part of railyard Y 
C-7 

lnY = length of link n in miles 

MGTnY = million gross tons on link n 

This method provides a more refined comparison between railyards than the use of the 7-

category dencodes; however, is more susceptible to errors for yards where tonnage is not 

correlated to switching activity. For example, a yard with large coal trains pulling through used 

for crews to change over would be assigned an overly high level of emissions for switching 

activity. To account for this, a discretionary Switching Activity Factor (SAF) was introduced to 

allow railroads to roughly weight yards with clearly higher or lower levels of switching activity 

than what results from the mathematical allocation. Therefore, SAIY is weighted based on both 

the ownership factor (OF) as well as the SAF (Equation 5). For example, a yard used for crew 

changes and not switching may have an SAF of 0, while a yard at a major interchange between 

cities may have an SAF of 3. 

SAIY’ = OFY*SAFY* SAIY Equation 5 

Again, the SAIY’ of all railyards belonging to a Class I railroad (RR) are summed, and the 

fraction of the railroads total SAI associated with each railyard was multiplied by the railroads 

total annual switcher fuel use reported in the R-1 (TFURR), resulting in the total Switcher Fuel 

Use for each railyard Y (Eqn 6). 

SFUY = RR

RR

Y

Y TFU

SAI

SAI *

'

'

∑ Equation 6 

While the SAF allows estimates of yard-specfic emissions to be adjusted, the total level of 

emissions for each railroad, which is based on systemwide fuel use and systemwide emission 

factors, remains unchanged. The MGT method SFUY is also later multiplied by the emission 

factors described in the previous section to obtain annual switcher emissions at each railyard. 

4. Improve estimates.

In addition to the Switching Activity Factor described above, direct input was also used to 

improve emission estimates for important railyards. Each Class I railroad provided an estimate 

of annual average switcher fuel use (generally much lower than the EPA default of 82,490 

gal/yr) as well as the name, location, and number of operating switchers for railyards with 8 or 

more switchers operating in ozone or PM2.5 nonattainment areas. This data was used to 

overwrite the dencode or MGT derived emissions estimates for those railyards. 

The difference in estimated fuel use for those railyards was re-allocated (added or removed) 

between the remaining railyards belonging to that Class I railroad. It is important to note that 

there are some discrepancies in how this data was reported for the large railyards by each 

railroad. For example, some railroads reported all switchers located at a railyard while others 

reported ‘full time equivalent’ switchers, meaning the number of switchers normalized to a full 

working cycle (24-hours per day year-round.) This process should be standardized for future 

inventory versions. 
C-8 

States also have the option of updating specific railyard emissions estimates. Because this 

inventory is derived ‘top-down’, local studies and familiarity with specific railyards is expected 

to provide better estimates, which can be used to adjust this inventory. Care must be taken to 

ensure the other railyard estimates are adjusted to account for increases or decreases in estimated 

fuel use per yard. 

Limitations, Conclusions, and Future Work 

What this ERTAC Rail railyard inventory does well is provide a comprehensive overview of 

where railyards are, who owns them, and gives a geographical allocation of switcher emissions 

bounded by what is reported as nationwide switcher fuel usage by the Class I railroads. These 

sources can be important for air quality management in nonattainment areas, as well as in 

regional analysis and for future transportation planning. This inventory will be useful for 

regional and some local modeling, helps identify where railyards need to be better characterized, 

and provides a strong foundation for future development of a meaningful nationwide Class I 

switcher emissions inventory. 

There are important uncertainties associated with estimates from this method, including, but not 

limited to, the use of tonnage hauled as an indicator of the amount of switching activity, and, for 

a few of the railroads, how the amount of switcher fuel use was determined to be reported in the 

R-1. The R-1 reported values are currently under examination. 

There is also likely significant variability in actual switching duty-cycles and, potentially, in the 

number of switchers operating at some railyards at different times of the year. ‘Road-switching’, 

or the use of what are considered switching locomotives to move between nearby yards, should 

be addressed in either this or the ERTAC line-haul inventory. 

It must be noted that freight-related rail activity is not always routine and no annual emissions 

inventory will ever be able to capture the innate variability of the source. However, as other 

large emission sources are reduced, and if rail activity increases as expected, it is important to 

include our best estimates of these sources in air quality analysis. In the future, on-line data 

loggers and other tracking technologies, combined with ambient studies and detailed modeling, 

will hopefully provide more insight to the emissions of locomotives and other railyard sources. 

References 

1. E.H. Pechan & Associates, Inc., “Documentation for Aircraft, Commercial Marine 

Vessel, Locomotive, and Other Nonroad Components of the National Emissions 

Inventory, Volume I – Methodology”; EPA Contract No.: 68-D-02-063. Prepared for the 

US EPA Emissions, Monitoring and Analysis Division, Sept. 30, 2005. 

ftp://ftp.epa.gov/EmisInventory/2002finalnei/documentation/mobile/2002nei_mobile_no

nroad_methods.pdf. Related documents at 

ftp://ftp.epa.gov/EmisInventory/2002finalnei/documentation/mobile/2002nei_mobile_no

nroad_train.pdf 
C-9 

2. Sierra Research, Inc., “Revised Inventory Guidance For Locomotive Emissions”; Report 

No. SR2004-06-01. Prepared for Southeastern States Air Resource Managers 

(SESARM), June 2004. http://www.metro4-sesarm.org/pubs/railroad/FinalGuidance.pdf 

3. Sierra Research, Inc., “Research Project: Development of Railroad Emission Inventory 

Methodologies”; Report No. SR2004-06-02. Prepared for Southeastern States Air 

Resource Managers (SESARM), June 2004. http://www.metro4-

sesarm.org/pubs/railroad/FinalMethodologies.pdf 

14. Environ, “Draft LADCO 2005 Locomotive Emissions”. Prepared for Lake Michigan Air 

Director Consortium, Feb 2007. 

http://www.ladco.org/reports/technical_support_document/references/ladco_2005_locom

otive_emissions.021406.pdf 

15. Southern Research Institute, “NYSERDA Clean Diesel Technology: Non-Road Field 

Demonstration Program, Development of the 2002 Locomotive Survey for New York 

State”; Agreement Number 8958. Prepared for the New York State Energy Research And 

Development Authority (NYSERDA), Feb. 09, 2007. 

http://www.nyserda.org/publications/LocomotiveSurveyReportwithAppendices.pdf

16. M. Bergin; M. Harrell; J. McDill; M. Janssen; L. Driver; R. Fronczak; R. Nath,; and D. 

Seep. "ERTAC Rail: A Collaborative Effort in Building a Railroad-Related Emissions 

Inventory Between Eastern States Air Protection Agencies and Participation with the 

Railroad Industry," 18th Annual International Emission Inventory Conference. 

Baltimore, MD. April 14 - 17, 2009. Paper and presentation available at: 

http://www.epa.gov/ttn/chief/conference/ei18/session6/bergin.pdf

17. Confidential database was provided with assistance from Raquel Wright of the Federal 

Railroad Administration. Similar public data is available from the Bureau of 

Transportation Statistics, in the NTAD 2009 shapefile data (data is representative for the 

year 2007): http://www.bts.gov/publications/national_transportation_atlas_database/2009

. 

18. EPA Technical Highlights: Emission Factors for Locomotives, EPA Office of 

Transportation and Air Quality, EPA-420-F-09-025, April 2009. 

http://www.epa.gov/otaq/regs/nonroad/locomotv/420f09025.pdf 

Appendix: ERTAC Rail Data Workgroup 

REPRESENTATIVE ORGANIZATION 

Matt Harrell IL EPA 

Michelle Bergin (Co-Chair) and Byeong Kim GA EPD 

Mark Janssen (Co-Chair) LADCO 

Julie McDill and Patrick Davis MARAMA 

Laurel Driver US EPA OAQPS 

Robert Fronczak AAR 

Steven Sullivan ASLRRA 

Rick Nath CSX 
C-10 

David Seep and Lyle Staley BNSF 

Ken Roberge CPR 

Carl Akins and Peter Conlon KCS 

Erika Akkerman CN 

M. John Germer UP 

Brent Mason and Richard Russell NS 

Joanne Maxwell Amtrak 
ERG No.: 0245.03.402.001 

Contract No.: EP-D-07-097 

Documentation for Aircraft Component of the National Emissions 

Inventory Methodology 

Prepared by: 

Eastern Research Group 

1600 Perimeter Park Drive 

Morrisville, North Carolina 27560 

Under Contract to: 

E.H. Pechan & Associates, Inc. 

3622 Lyckan Parkway 

Suite 2002 

Durham, North Carolina 27707 

For Submittal to: 

Laurel Driver 

Emissions, Monitoring and Analysis Division 

U.S. Environmental Protection Agency 

Research Triangle Park, North Carolina 27711 

January 27, 2011 
i 

TABLE OF CONTENTS 

Section Page No. 

1.0 INTRODUCTION ........................................................................................................... 1-1

1.1 What is the National Emission Inventory? .......................................................... 1-1

1.2 Why Did the EPA Create the NEI? ...................................................................... 1-1

1.3 How is the EPA Going to Use This Version of the NEI? .................................... 1-1

1.4 Report Organization ............................................................................................. 1-2

2.0 DEVELOPMENT OF THE AIRCRAFT COMPONENT FOR THE NEI ..................... 2-1

2.1 How does this aircraft study fit into the NEI? ..................................................... 2-1

2.2 What are Aircraft Sources? ................................................................................ 2-11

2.3 What Pollutants are Included in the National Emission Estimates for 

Aircraft? ............................................................................................................. 2-11

2.4 How Were the Aircraft Emissions Estimated? .................................................. 2-12

2.5 How Were Emissions Allocated? ...................................................................... 2-17

2.6 QA/QC ............................................................................................................... 2-17

2.7 What are the Results?......................................................................................... 2-17

2.8 Aircraft References ............................................................................................ 2-20

Appendix A – Generic Aircraft Emission Factors 

Appendix B – Calculating Piston-Engine Aircraft Airport Inventories for Lead for the 2008 

National Emissions Inventory 
ii 

LIST OF TABLES AND FIGURES 

Tables Page No. 

Table 2-1a. Methods Used to Develop Emission Estimates for Onroad Vehicle Sources .......... 2-2

Table 2-1b. Methods Used to Develop Annual Emission Estimates for Nonroad 

Mobile Sources ............................................................................................................................ 2-4

Table 2-2. Aircraft Pollutant List ............................................................................................... 2-12

Table 2-3. National-Scale GSE Engine Distribution ................................................................. 2-14

Table 2-4. Aircraft Criteria Emission Estimates 2008 (tons per year) ...................................... 2-18

Table 2-5. Aircraft HAP Emission Estimates 2008 (tons per year) ........................................... 2-18

Figures Page No. 

Figure 2-1. Procedures for Estimating Emissions from Commercial Air Carriers .................... 2-14

Figure 2-2. Procedures for Estimating Emissions from Commercial Air Taxis and General 

Aviation...................................................................................................................................... 2-15
1-1 

1.0 INTRODUCTION 

1.1 What is the National Emission Inventory? 

 The National Emission Inventory (NEI) is a comprehensive inventory covering all 

anthropogenic sources of criteria pollutants and hazardous air pollutants (HAPs) for all areas of 

the United States. The NEI was created by the U.S. Environmental Protection Agency’s 

Emission Inventory and Analysis Group (EIAG) in Research Triangle Park, North Carolina. The 

NEI will be used to support air quality modeling and other activities. To this end, the EPA 

established a goal to compile comprehensive emissions data in the NEI for criteria and HAPs for 

mobile, point, and nonpoint sources. This report presents an overview of how emission estimates 

for the aircraft component of the NEI were compiled. 

1.2 Why Did the EPA Create the NEI? 

 The Clean Air Act (CAA), as amended in 1990, includes mandates for the EPA related to 

criteria and hazardous air pollutants. The CAA defines criteria pollutants as being one of the 

following air pollutants: 

 Carbon monoxide (CO); 

 Sulfur oxides (SOx); 

 Nitrogen oxides (NOx); 

 Ozone; and 

 Particulate matter (PM). 

 Hazardous air pollutants are also delineated in the CAA, see 

http://www.epa.gov/ttn/atw/188polls.html for a complete list of regulated pollutants and their 

chemical abstract service [CAS] numbers. 

 The CAA requires the EPA to identify emission sources of these pollutants, quantify 

emissions, develop regulations for the identified source categories, and assess the public health 

and environmental impacts after the regulations are put into effect. The NEI is a tool that EPA 

can use to meet the CAA mandates. In this report, criteria and HAP emission estimates are 

discussed for aircraft sources. 

1.3 How is the EPA Going to Use This Version of the NEI? 

 It is anticipated that the emission inventory developed from this effort will have multiple 

end uses. The data have been formatted according to protocols established for the EPA’s NEI 

submittals. The common data structure on which the NEI platform is based will allow the NEI 

emission data to be transferred to multiple end-users for a variety of purposes. 
1-2 

The criteria and HAP emission estimates developed for the NEI will be used to evaluate 

air pollution trends, air quality modeling analysis, and impacts of potential regulations. 

1.4 Report Organization 

 Following this introduction, Section 2.0 provides information on how the national aircraft 

emission estimates were developed. This inventory effort was coordinated by the EPA’s Office 

of Transportation and Air Quality (OTAQ) and EIAG. The appendixes were created to provide 

the supporting references from OTAQ. 
2-1 

2.0 DEVELOPMENT OF THE AIRCRAFT COMPONENT FOR THE 

NEI 

2.1 How does this aircraft study fit into the NEI? 

 The NEI was developed to include all point, nonpoint (sometimes referenced as “area”), 

and mobile sources. The approaches used in the point and nonpoint source categories are 

documented in other reports. Table 2-1 summarizes the approaches used to estimate emissions 

from all nonroad sources included in the NEI program. Those source categories and years that 

are included in this report are noted in bold. 

 The scope of this inventory component of the NEI was to compile criteria and HAP 

emissions data for aircraft operating in United States air space. In this effort, national emission 

estimates were often developed as point sources for each airport. The methodologies used to 

estimate emissions are discussed in this report. 

The target inventory area includes every state in the United States and every county 

within a state, including Washington, DC, Puerto Rico, and US Virgin Islands. There are no 

boundary limitations pertaining to traditional criteria pollutant nonattainment areas or to 

designated urban areas. The pollutants inventoried included all criteria pollutants (and the 

188 HAPs identified in Section 112(b) of the CAA). 

 In addition to numerous specific chemical compounds, the list of 188 HAPs includes 

several compound groups [e.g., individual metals and their compounds, polycyclic organic 

matter (POM)]; the NEI includes emission estimates for the individual compounds wherever 

possible. Many of the uses of the NEI depend upon data (e.g., toxicity) for individual compounds 

within these groups rather than aggregated data on each group as a whole. 

 The intent in presenting the following emission inventory approach is to provide 

sufficient and transparent documentation such that states and local agencies can use these 

approaches, in conjunction with their specific local activity data to develop more accurate and 

comparable emission estimates in future submittals. 

This documentation is not meant to provide an exhaustive analysis on the derivation of all 

the inputs. For example, an emission factor used for a national estimate may be given in the 

appendix, but the source test data that were evaluated to obtain this factor may not be presented 

or discussed. The goal of the documentation provided is to show in a brief and concise manner 

how a given estimate was derived. 
2-2 

Table 2-1a. Methods Used to Develop Emission Estimates for Onroad Vehicle Sources 

(Years addressed in this report are noted in bold print) 

Base Year(s) Pollutant(s) Geographic Area Emission Estimation Method 

2008 All Criteria, HAPs US, Puerto Rico, Virgin Islands Emission estimates for all pollutants were developed usi

Inventory Model (NMIM), which uses MOBILE6 (specM6203ChcOxFixNMIM.exe) to calculate onroad emissiprovided alternate onroad MOBILE6 inputs or VMT, thinputs. Default VMT is based on FHWA 2008 data and estimates. 

2005 All Criteria, HAPs US, Puerto Rico, Virgin Islands Emission estimates for all pollutants were developed usi

MOBILE6 to calculate onroad emission factors. Where 

onroad MOBILE6 inputs or VMT, these data replaced EVMT is based on FHWA 2005 data and 2005 Census po

2002 All Criteria, HAPs US, Puerto Rico, Virgin Islands Emission estimates for all pollutants were developed usi

MOBILE6 to calculate onroad emission factors. Where 

onroad MOBILE6 inputs or VMT, these data replaced Esupplied emissions data which replaced default EPA em

Default VMT is based on FHWA 2002 data and populat

2001 VOC, NOx, CO, SO2, PM10, 

PM2.5

California Emissions and VMT provided by California at county/v

provided emissions expanded to county/SCC level by E

2001 NH3 California Calculated at State/county/SCC level by month using M

State-provided VMT data. 

2001 All Criteria AL; CO; ME; MA; MS; OR; UT; VA; 

WV; Maricopa County, AZ; Hamilton 

County, TN 

State-provided VMT grown to 2001; emissions calculatemission factors. 

2001 All Criteria Rest of US Calculated at State/county/SCC level by month using M

VMT. 

1999 All Criteria AL; ME; MA; MS; UT; VA; WV; 

Maricopa County, AZ; Hamilton 

County, TN 

Calculated at State/county/SCC level by month using MVMT data used. 

1999 VOC, NOx, CO, SO2, PM10, 

PM2.5

California Emissions and VMT provided by California at county/v

provided emissions expanded to county/SCC level by E

1999 NH3 California Calculated at State/county/SCC level by month using M

State-provided VMT data. 

1999 PM10 Exhaust Colorado PM10 emissions and VMT provided by State. 
2-3 

Table 2-1a. Methods Used to Develop Emission Estimates for Onroad Vehicle Sources 

(Years addressed in this report are noted in bold print) 

Base Year(s) Pollutant(s) Geographic Area Emission Estimation Method 

1999 VOC, NOx, CO, SO2, PM10

brake and tire wear, PM2.5, 

NH3

Colorado Calculated at State/county/SCC level by month using M

VMT data used. 

1999 All Criteria Oregon Emissions and VMT provided by Oregon at county/vehi

emissions expanded to county/SCC level by EPA. 

1999 All Criteria Rest of US, Puerto Rico, and US 

Virgin Islands 

Calculated at State/county/SCC level by month using MVMT. 

1999 HAPs California HAP emissions and VMT provided by California at cou

emissions allocated to SCC level by EPA. 

1999 HAPs Rest of US, Puerto Rico, and US 

Virgin Islands 

MOBILE6 emission factors calculated at State/county/SFHWA-based VMT. 

1997-1998 All Criteria US 2-step linear interpolation at State/count/SCC level base

State/count/SCC level data. 

1990, 1996 HAPs US MOBILE6 emission factors calculated at State/county/S

Federal Highway Administration (FHWA)-based vehicl

1991-1995 All Criteria US Linear interpolation at State/count/SCC level based on 1

State/count/SCC level data. 

1988-1989 All Criteria US Linear interpolation at State/count/SCC level based on 1

State/count/SCC level data. 

1979-1986 All Criteria US Linear interpolation at State/count/SCC level based on 1

State/count/SCC level data. 

1978, 1987, 1990, 1996, 

2000 

All Criteria US Calculated at State/county/source classification code (SC

MOBILE6, no State data incorporated. 

1970, 1975 All Criteria US Linear extrapolation at national vehicle type level based 

data. 
2-4 

Table 2-1b. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources 

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method* 

NONROAD CategoriesNonroad Gasoline, 

Diesel, LPG, CNG 

2008 VOC, NOx, CO, SO2, 

PM10, PM2.5, NH3, & 

HAPs 

Emission estimates for NONROAD model engines were developed using EPAModel (NMIM), which incorporates NONROAD2008. Where states provided 

inputs, these data replaced EPA default inputs. 

2005 VOC, NOx, CO, SO2, , 

PM10, PM2.5, NH3, & 

HAPs 

Emission estimates for NONROAD model engines were developed using EPANONROAD2005. Where States provided alternate nonroad inputs, these data 

2002 VOC, NOx, CO, SO2, 

PM10, PM2.5, NH3, & 

HAPs 

Emission estimates for NONROAD model engines were developed using EPANONROAD2004. Where states provided alternate nonroad inputs, these data rState-supplied emissions data also replaced default EPA emission estimates. 

 1999 VOC, NOx, CO, SO2, 

PM10, PM2.5

Using emission estimates from two emission inventories including: 1) a 1996 developed using EPA’s October 2001 draft NONROAD model; and 2) an updbased on EPA’s draft Lockdown C NONROAD model (dated May 2002). Usiemission estimates, seasonal and daily county-to-national ratios were then devupdated national estimates per season estimated from the Lockdown C model. 

for California for all NONROAD model categories; Pennsylvania for recreatiosupport equipment, and Texas for select equipment categories. 

 1996, 1997, 

1998, 2000 & 2001 

VOC, NOx, CO, SO2, 

PM10, PM2.5

Using emission estimates from two emission inventories including: 1) a 1996 developed using EPA’s October 2001 draft NONROAD model; and 2) updateCalifornia inventories, based on EPA’s draft Lockdown C NONROAD model 1996 county-level emission estimates, seasonal and daily county-to-national rastate ratios were then developed for application to updated national estimates pLockdown C model. California results replace the diesel equipment emissions application of county-to-national ratios. 
2-5 

Table 2-1b. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources (Continued)

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method*

Nonroad Gasoline, 

Diesel, LPG, and CNG (Continued) 

1991-1995 VOC, NOx, CO, SO2, 

PM10, PM2.5, NH3

Using 1990 and 1996 county-level emissions inventories, estimated emissions national emissions between 1990 and 1996. From these emissions, calculated tfor each pollutant/SCC combination for each year, and then applied the growth 

emissions to estimate 1991-1995 emissions. 

 1990 VOC, NOx, CO, SO2, 

PM10, PM2.5

Using emission estimates from two emission inventories including: 1) a 1996 developed using EPA’s October 2001 draft NONROAD model; and 2) updatebased on EPA’s draft Lockdown C NONROAD model (dated May 2002). Usiemission estimates, seasonal and daily county-to-national ratios were then devupdated national estimates per season estimated from the Lockdown C model. 

 1986, 1988, & 

1989 

VOC, NOx, CO, SO2, 

PM10, PM2.5, NH3

Using 1985 and 1990 county-level emissions inventories, estimated emissions national emissions between 1985 and 1990. From these emissions, calculated tfor each pollutant/SCC combination for each year, and then applied the growth 

emissions to estimate 1986-1989 emissions. 

 1987 VOC, NOx, CO, SO2, 

PM10, PM2.5

Using EPA’s draft Lockdown C NONROAD model (dated May 2002), develoemissions for 1987 by running 4 seasonal NONROAD model runs to estimate emissions. Also performed national NONROAD model runs to estimate typica

1985 VOC, NOx, CO, SO2, 

PM10, PM2.5

Using emission estimates from two emission inventories including: 1) a 1996 developed using EPA’s October 2001 draft NONROAD model; and 2) updatebased on EPA’s draft Lockdown C NONROAD model (dated May 2002). Usiemission estimates, seasonal and daily county-to-national ratios were then devupdated national estimates per season estimated from the Lockdown C model. 

 1970, 1975, 

1978, & 1980 

VOC, NOx, CO, SO2, 

PM10, PM2.5

Using EPA’s draft Lockdown C NONROAD model (dated May 2002), develoemissions for all years by running 4 seasonal NONROAD model runs to estimemissions. Also performed national NONROAD model runs to estimate typica
2-6 

Table 2-1b. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources (Continued)

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method*

Nonroad Gasoline, 

Diesel, LPG, and CNG (Continued) 

1996, 1997, 1998, 1999, 2000, & 2001 

NH3 Obtaining national fuel consumption estimates from the Lockdown C NONRO

NH3 emission factors, and distributing to counties using 1996 inventory, based 

NONROAD. NH3 emissions for California were also recalculated using updat

values generated for California-specific runs, and assuming the 1996 county-le

1985 & 1990 NH3 Obtaining national fuel consumption estimates from the Lockdown C NONRO

NH3 emission factors, and distributing to counties using 1996 inventory, based 

NONROAD. 

1987 NH3 Obtaining 1987 national fuel consumption estimates from Lockdown C NONR

by NH3 emission factors. 

1970, 1975, 1978, & 1980 

NH3 Obtaining national fuel consumption estimates from the Lockdown C NONRO

NH3 emission factors. 

 1990, 1996, & 

1999 

HAPs Speciation profiles applied to county VOC and PM estimates. Metal HAPs we

activity-based emission factors. Some state data were provided and replaced n

AircraftCommercial Aircraft 

2008 Criteria and HAPs Federal Aviation Administration (FAA) Emissions and Dispersion Modeli

5.1.was run using BTS T-100 LTO data. (2009) 

2002 and 2005 Criteria and HAPs Federal Aviation Administration (FAA) Emissions and Dispersion and Modeli

for criteria pollutants, VOC and PM emissions were speciated into HAP comp

1990, 1996, 1999, 2000, 2001 

VOC, NOx, CO, SOx Input landing and take-off (LTO) data into FAA EDMS. National emissions w

on airport specific LTO data and BTS GIS data. State data replaced national es

1970-1998 VOC, NOx, CO, SOx Estimated emissions for interim years using linear interpolation between avail1990, 1996, 1999 

HAPs Speciation profiles were applied to VOC estimates to get national HAP estima

national estimates. (2003) 

General Aviation, Air Taxis 

2008 Criteria and HAPs Federal Aviation Administration (FAA) Emissions and Dispersion Modeli

5.1.was run using BTS T-100 LTO for aircraft identified as Air taxis. (201

Used FAA LTO data from TAF and OTAQ provided activity data for smFAA 5010 master plans. EPA approved generic emission factors for criterprofiles were applied to VOC and PM estimates to get national HAP estim
2-7 

Table 2-1b. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources (Continued)

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method*

General Aviation, Air Taxis (Continued) 

2005 VOC, NOx, CO, SO2, 

PM10, PM2.5

2002 emissions for approximately 4,000 largest airports were calculated via EDincluded in the 2005 NEI as point sources. Only airports in FAA’s T100 and TState point source submittals were incorporated. 

1978, 1987, 1990, 1996, 1999, 2000, 2001, & 2002 

VOC, NOx, CO, SO2, 

PM10, PM2.5

Used FAA LTO data and EPA approved emission factors for criteria estimatesapplied to VOC estimates to get national HAP estimates. State data replaced n

 1970-1998 VOC, NOx, CO, SOx, 

PM10, PM2.5

Estimated emissions for interim years using linear interpolation between avail

 1990, 1996, 

1999, & 2002 

HAPs Used FAA LTO data and EPA approved emission factors for criteria estimates

applied to VOC estimates to develop national HAP estimates. (2004) 

 1990, 1996, 

1999, & 2002 

Pb Used Department of Energy (DOE) aviation gasoline usage data with lead con

(2004) 

 1996 NH3 Applied NH3 emissions factors to 1996 national jet fuel and aviation gasoline Military Aircraft 2008 VOC, NOx, CO, SO2, 

PM10, PM2.5

Used FAA LTO data as reported in TAF and EPA approved emission facRepresentative HAP profiles were not readily available, therefore HAP es(2010) 

2005 VOC, NOx, CO, SO2, 

PM10, PM2.5

2002 emissions were included in the 2005 NEI as point sources similar to othe

1978, 1987, 1990, 1996, 1999, 2000, 2001, 2002, 2008 

VOC, NOx, CO, SO2, 

PM10, PM2.5

Used FAA LTO data as reported in TAF and EPA approved emission factors fRepresentative HAP profiles were not readily available, therefore HAP estima

 1970-1998 VOC, NOx, CO, SOX, 

PM10, PM2.5

Estimated emissions for interim years using linear interpolation between avail

Auxiliary Power Units and Ground Support Equipment 

2008 VOC, NOx, CO, SO2, 

PM10, PM2.5, HAPs 

Federal Aviation Administration (FAA) Emissions and Dispersion and MVersion 5.1.was run using BTS T-100 LTO data. (2009) 

2002 and 2005 VOC, NOx, CO, SO2, 

PM10, PM2.5, HAPs 

Computed via NONROAD2005 model runs. 

1985-2001 VOC, NOx, CO, SO2, 

PM10, PM2.5

Grew 1996 emissions to each year using LTO operations data from the FAA. E1996 reported in EPA, 1998. 
2-8 

Table 2-1b. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources (Continued)

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method*

Unpaved Airstrips1 1985-2001 PM10, PM2.5 Grew 1996 emissions to each year using SIC 45-Air Transportation growth fa

current draft version of EGAS. Estimation methods prior to 1996 reported in E

Aircraft Refueling1 1985-2001 VOC Grew 1996 emissions to each year using SIC 45-Air Transportation growth fa

current draft version of EGAS. Estimation methods prior to 1996 reported in E

Commercial Marine Vessel (CMV)All CMV Categories 2008 VOC, NOx, CO, SO2, 

PM10, PM2.5

OTAQ provided CAP emission estimates for all CMV categories. Note that thchanged such that the Diesel category refers to smaller vessels (Category 1 anthe Residual category refers to larger (Category 3) vessels using a blend of resallocated to segments using GIS shapefiles and adjusted based on limited state 

 2008 HAPs OTAQ’s 2008 estimates were speciated into HAP components using SEPA pr

CMV Diesel 2002 and 

2005 

VOC, NOx, CO, SO2, 

PM10, PM2.5

2001 Estimates carried over. Used state data when provided. (2004) 

HAPs 1999 Estimates carried over. Used state data when provided. (2004) 

1978, 1987, 1990, 1996, 1999, 2000, & 2001 

VOC, NOx, CO, SOx, 

PM10, & PM2.5

Used criteria emission estimates in the background document for marine dieseAdjusted 2000 criteria emission estimates for other used based on fuel usage. into port traffic and underway activities. Port emissions were assigned to spec

cargo handled. Underway emissions were allocated based on Army Corp of EState data replaced national estimates. (2003) 

 1970-1998 VOC, NOx, CO, SOx, 

PM10, PM2.5

Estimated emissions for interim years using linear interpolation between avail

 1990, 1996, 

1999 

HAPs VOC and PM emission estimates were speciated into HAP components. State 

estimates. (2003) 

 1996 NH3 Applied NH3 emissions factors to 1996 distillate and residual fuel oil estimate

1996). 

 1990-1995 NH3 Estimation methods reported in EPA, 1998. 
2-9 

Table 2-1b. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources (Continued)

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method*

CMV Steam Powered 

2005 VOC, NOx, CO, SOx, 

PM10, & PM2.5, HAPs 

2002 estimates grown to 2005 (2008). 

2002 VOC, NOx, CO, SOx, 

PM10, & PM2.5, HAPs 

2002 based estimates were developed for port and underway category 3 (C3) v

effort. Emissions were developed separately for near port and underway emisinventories for 2002 were developed for 89 deep water and 28 Great Lake porNetwork Ship Traffic, Energy, and Environmental Model (STEEM) was used ships traveling in shipping lanes between and near individual ports (2008) 

1978, 1987, 1990, 1996, 1999, 2000, & 2001 

VOC, NOx, CO, SOx, 

PM10, & PM2.5

Calculated criteria emissions based on EPA SIP guidance. Emissions were disand under way activities. Port emissions were assigned to specific ports based 

Underway emissions were allocated based on Army Corp of Engineering watenational estimates. (2003) 

 1970-1998 VOC, NOx, CO, SOx, 

PM10, PM2.5

Estimated emissions for interim years using linear interpolation between avail

 1990, 1996, & 

1999 

HAPs VOC and PM emission estimates were speciated into HAP components. State 

estimates. (2003) 

Military Marine 1997-2001 VOC, NOx, CO, SO2, 

PM10, PM2.5

Applied EGAS growth factors to 1996 emissions estimates for this category. 

CMV Coal,2 CMV, 

Steam powered, CMV Gasoline2

1997-1998 VOC, NOx, CO, SO2, 

PM10, PM2.5

Applied EGAS growth factors to 1996 emissions estimates for this category. 

CM Coal, CMV, Steam powered, CMV Gasoline, Military Marine 

1991-1995 VOC, NOx, CO, SO2, 

PM10, PM2.5

Estimation methods reported in EPA, 1998. 

LocomotivesClass I, II, III and Yard operations 

2008 VOC, NOx, CO, PM10, 

PM2.5,SOx & HAPs 

Criteria emission estimates were provided to EPA by ERTAC. These data werrailway segments using DOT shapefiles and guidance from ERTAC. HAP emapplying speciation profiles to VOC and PM estimates. (2010) 
2-10 

Table 2-1b. Methods Used to Develop Annual Emission Estimates for 

Nonroad Mobile Sources (Continued)

(Categories included in this report are noted in bold print) 

Category Base Year Pollutant(s) Estimation Method*

Class I, Class II, Commuter, Passenger, and Yard Locomotives 

1978, 1987, 1990, 1996, 1999, 2000, 2000, 2002, & 2005 

VOC, NOx, CO, PM10, 

PM2.5

Criteria pollutants were estimated by using locomotive fuel use data from DOfactors. County-level estimates were obtained by scaling the national estimateDOT. State data replaced national estimates. (2004) 

1978, 1987, 1990, 1996, 1999, 2000, 2001, 2002, & 2005 

SO2 SOx emissions were calculated by using locomotive fuel use and fuel sulfur co

County-level estimates were obtained by scaling the national estimates with thdata from DOT. State data replaced national estimates. (2004) 

1970-1998 VOC, NOx, CO, SOx, 

PM10, PM2.5

Estimated emissions for interim years using linear interpolation between avail

1990, 1996, 1999, & 2002 

HAPs HAP emissions were calculated by applying speciation profiles to VOC and P

estimates were obtained by scaling the national estimates with the county levedata replaced national estimates. (2004) 

 1997-1998 NH3 Grew 1996 base year emissions using EGAS growth indicators. 

 1996 NH3 Applied NH3 emissions factors to diesel consumption estimates for 1996.  1990-1995 NH3 Estimation methods reported in EPA, 1998. 

Notes: * Dates included at the end of Estimation Method represent the year that the section was revised. 

1 Emission estimates for unpaved airstrips and aircraft refueling are included in the area source NEI, since they represent non-engine e

2 National Emission estimates for CMV Coal and CMV Gasoline were not developed though states and local agencies may have subm

source categories. EPA, 1998. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Emission Factors and Inventory GPollutant Emission Trends, Procedures Document, 1900–1996, EPA-454/R-98-008. May 1998. 
2-11 

2.2 What are Aircraft Sources? 

The aircraft source category includes all aircraft types used for public, private, and 

military purposes. This includes four types of aircraft (EPA, 1992): 1) Commercial; 2) Air Taxis; 

3) General Aviation; and 4) Military. 

Commercial aircraft include those used for transporting passengers, freight, or both. 

Commercial aircraft tend to be larger aircraft powered with jet engines. Air Taxis (AT) carry 

passengers, freight, or both, but usually are smaller aircraft and operate on a more limited basis 

than the commercial carriers. General Aviation (GA) includes most other aircraft used for 

recreational flying and personal transportation. Aircraft that support business travel, usually on 

an unscheduled basis, are included in the category of general aviation. 

The national AT and GA fleet includes both jet and piston-powered aircraft. Most of the 

AT and GA fleet are made up of piston powered aircraft, though smaller business jets can also be 

found in these categories. According to a 2008 Federal Aviation Administration GA and AT 

Activity Survey, 66% of all GA and AT activity are powered by piston-powered aircraft and 

34% are jet (or turbine) driven. EPA has used this estimate as a national-scale default value in 

recently published studies investigating lead emissions from aviation sources (EPA, 2008). The 

piston powered aircraft tend to have higher VOC, PM, and CO emissions and lower NOX

emissions than larger jet-powered aircraft (EPA, 1992). Military aircraft cover a wide range of 

aircraft types such as training aircraft, fighter jets, helicopters, and jet- and a small number of 

piston powered planes of varying sizes. 

It should be noted that this inventory effort also includes criteria and Hazardous Air 

Pollutants (HAP) emission estimates for aircraft Auxiliary Power Units (APU) and aircraft 

Ground Support Equipment (GSE) typically found at airports, such as aircraft refueling vehicles, 

baggage handling vehicles, and equipment, aircraft towing vehicles, and passenger buses. 

2.3 What Pollutants are Included in the National Emission Estimates for Aircraft? 

Emissions estimates were developed for all criteria pollutants including volatile organic 

compounds (VOC), nitrogen oxides (NOx), carbon monoxide (CO), sulfur oxides (SOx), 

particulate matter less than 10 microns (PM10), particulate matter less than 2.5 microns (PM2.5) 

and hazardous air pollutants (HAP) (Cook, 1997; Cook, 1998; EPA/FAA, 2009). The HAPs that 

are included in the national aircraft inventory are shown in Table 2-2 and are based on available 

test data and accepted emission estimation procedures. 

 
2-12 

Table 2-2. Aircraft Pollutant List 

1,3-Butadiene Carbon Dioxide Naphthalene 

1-Methylnaphthalene* Carbon Monoxide Nitrogen Oxides 

2,2,4-Trimethylpentane Chrysene* O-xylene* 

2-Methylnaphthalene* Cumene* Phenanthrene* 

Acenaphthene* Dibenzo[a,h]Anthracene* Phenol 

Acenaphthylene* Ethyl Benzene PM10 Primary 

Acetaldehyde Fluoranthene* PM2.5 Primary 

Acrolein Fluorene* Propionaldehyde 

Anthracene* Formaldehyde Pyrene* 

Benz[a]Anthracene* Hexane* Styrene 

Benzene Indeno[1,2,3-c,d]Pyrene* Sulfur Dioxide 

Benzo[a]Pyrene* Lead Toluene 

Benzo[b]Fluoranthene* Methane* VOCs 

Benzo[g,h,i,]Perylene* Methanol* Xylene 

Benzo[k]Fluoranthene* M-xylene* 

* Added to 2008 Inventory

2.4 How Were the Aircraft Emissions Estimated? 

EPA has developed guidance for inventorying aircraft emissions associated with an 

aircraft’s landing and takeoff (LTO) cycle. The cycle begins when the aircraft approaches the 

airport on its descent from cruising altitude, lands, taxis to the gate, and idles during passenger 

deplaning. It continues as the aircraft idles during passenger boarding, taxis back out onto the 

runway for subsequent takeoff, and ascent (climbout) to cruising altitude. Thus, the five specific 

operating modes in an LTO are (EPA, 1992): 1) Approach; 2) Taxi/idle-in; 3) Taxi/idle-out; 

4) Takeoff; and 5) Climbout. 

The LTO cycle provides a basis for calculating aircraft emissions. During each mode of 

operation, an aircraft engine operates at a fairly standard power setting for a given aircraft 

category. Emissions for one complete cycle are calculated using emission factors for each 

operating mode for each specific aircraft engine combined with the typical period of time the 

aircraft is in the operating mode. 

On March 20, 2009, the EPA posted preliminary LTO data intended to be will use to 

calculate emissions for review prior to developing the aircraft inventory. State and local agencies 

were encouraged to review the materials posted at ftp://ftp.epa.gov/EmisInventory/2008_nei/ and 

provide comments on any necessary corrections to: 
2-13 

 Airport names and locations for approximately 20,000 airports to be included in the 

Emission Inventory System (EIS) facility inventory; 

 Landing and Takeoff (LTO) information that will be used to estimate emissions for 

each airport; 

 Aircraft/engine combinations to link to FAA LTO data including default assumptions 

and AircraftEngineCodeTypes for EIS submittals; and 

 Lead estimates and lead estimation methodology. 

This preliminary review by state, local, and tribal groups provided information that EPA used to 

improve EPA’s work. EPA received comments from four states (i.e., Minnesota Pollution 

Control Agency - Environmental Analysis and Outcomes Division; New Jersey Department of 

Environmental Protection; Bureau of Air Management, Connecticut Department of 

Environmental Protection; and Wisconsin Department of Natural Resources (specifically related 

to Volk Field Air National Guard Base (VOK) in Juneau County Wittman Regional Airport 

(OSH)) and three local agencies (i.e., Mecklenburg County North Carolina; Ventura County 

California Air Pollution Control District (Specifically related to Oxnard (OXR), Camarillo 

(CMA) and Santa Paula (SZP); and - Regional Air Pollution Control Agency (Dayton and 

Montgomery County Ohio)). 

Criteria emission estimates are presented here for four different aircraft types: 

commercial air carrier, air taxis, general aviation, and military. HAP emission estimates were 

developed for all aircraft types. 

Emissions for commercial air carriers for which detailed aircraft-specific activity data 

were available, were calculated differently than the other three aircraft categories (See Figure 2-

1). Criteria and HAP emissions were estimated for commercial aircraft by applying aircraft make 

and model (e.g., Boeing 747-200 series) specific LTO activity data from FAA’s Form 41, 

Schedules T100 and T100(f) Air Carrier Data to the FAA’s Emissions and Dispersion Modeling 

System (EDMS), Version 5.1 (DOT, 2008). It should be noted that due to the reporting 

requirements of T-100, only commercial activities are included in the dataset, and therefore does 

not include activity data for non-air carrier applications such as general aviation and military. 

This distinction lead to a revision to EPA’s original aircraft crosswalk table, also known as the 

aircraft engine type code, used to match aircraft to EDMS aircraft and to account for double 

counting between the T-100 data and the TAF data. In the revised crosswalk, aircraft that were 

previously considered general aviation and military based on aircraft model were changed to air 

taxi and commercial air carrier aircraft types based on the definition of air taxis (i.e., any aircraft 

that was not considered an air taxi was classified as an air carrier aircraft). The FAA reviewed 

the cross walk tables and made additional changes that moved some of the larger air taxis to the 

commercial air carrier category and some of the smaller commercial air carriers to the air taxi 

category. The revised crosswalk table is provided in an electronic file as supporting data for this 

study. 
2-14 

Emissions were calculated for each airport individually using airport specific mixing 

height. The national-scale default values for taxi in and out are seven and nineteen minutes, 

respectfully. It should be noted that EDMS incorporates the latest aircraft engine emission 

factors from the International Civil Aviation Organization Engine Exhaust Emissions Data Bank. 

The EDMS output includes organic HAPs, but not metals. 

Figure 2-1. Procedures for Estimating Emissions from Commercial Air Carriers 

Emissions for GSE and APU associated with commercial air carriers and air taxis for 

which T-100 data were available were estimated by EDMS, using the assumptions and defaults 

incorporated in the model. This is significant change from previous NEI year’s emissions where 

GSE estimates came from the NONROAD model and APUs were not included in EPA’s 

estimates. With EDMS, GSE that are assigned to an aircraft are given times (minutes per arrival, 

minutes per departure) based upon the type of service. For example, a fuel truck servicing a large 

commercial aircraft will have a different operating time than the same fuel truck servicing a 

commuter aircraft. All EDMS defaults for GSE duration and type (e.g., fuel truck, cabin service 

truck, baggage belt loader) were used. GSE emission factors used by EDMS are derived from 

EPA’s NONROAD2005 model and are based on the following variables: fuel, brake horsepower 

and load factor. GSE engines burn gasoline, diesel, compressed natural gas (CNG), and liquefied 

petroleum gas (LPG). EPA has used a national-scale value to characterize engines type. The GSE 

engine distribution is shown below in Table 2-3. Like GSE, APU emissions are the product of 

operating time. The purpose of an aircraft APU is to provide power to start the main engines and 

run the heating, cooling, and ventilation systems prior to starting the main engines. 

Table 2-3. National-Scale GSE Engine Distribution 

GSE Engines Type Percent of 

Total 

Gasoline Fired, 4-Stroke 16.9 

Liquefied Petroleum Gas (LPG) Fired 1.65 

Compressed Natural Gas (CNG) Fired 1.25 

Diesel Fired 80.2 

Emissions of criteria pollutants for air taxis, general aviation, and military aircraft were 

calculated by combining aircraft operations data from FAA’s Terminal Area Forecasts (TAF) 

and 5010 Forms. To avoid double counting between the T-100 data set and the TAF/5010 data, 
2-15 

LTOs by airport and aircraft type were summed in the T-100 data and compared with data in the 

TAF/5010 data. If the TAF/5010 LTO estimates were larger than the T-100 estimates for a 

specified aircraft type then the T-100 values were subtracted from the TAF/5010 values. If the 

T-100 values were larger than the TAF values, then the TAF values were set to zero. A data set 

of adjusted TAF/5010 LTOs were provided to OTAQ where additional adjustments were made 

to address older data in the TAF and 5010 datasets and to incorporate other insights provided by 

FAA reviewers. 

The TAF/5010 LTO data were dividing into jet and piston powered fractions based on the 

national observation that 66 percent of all general aviation and air taxi activities are associated 

with piston powered aircraft and the remaining 34 percent of general aviation and air taxi 

activities are associated with jet powered aircraft. The adjusted and split TAF/5010 activity data 

were applied to emission factors as appropriate (See Figure 2-2). It should be noted that EDMS 

calculates organic HAP emissions in the model (metal HAPs are currently not included in the 

EDMS output). HAP emission estimates for air taxis, general aviation, and military aircraft were 

estimated by applying speciation profiles to VOC or PM10 emissions estimates. The following 

equation was used (emission factor are included as Appendix A). 

Eixj = LTOi × FRpro-i × EFij

Where: 

Eixj = Emission estimate for aircraft type i equipped with engine type x 

and pollutant j (lbs/year) 

LTOi = Annual count of LTO cycles for aircraft type i 

FRx = Fraction of LTOs equipped with engine type x 

EFij = Generic emission factor for aircraft type i equipped with engine 

type x and pollutant j (lbs/LTO) 

i = Aircraft type (i.e., air taxi, general aviation, and military) 

x = Engine type (i.e., jet or turboprop, and piston engine) 

j = Criteria pollutant j 

Figure 2-2. Procedures for Estimating Emissions from Commercial Air Taxis and 

General Aviation 

Split into: 

Jet-Propelled and 

Piston-Driven 

Aircraft

FAA LTO Data 

for Air Taxis 

and General 

Aviation

(5010 and TAF)

Apply Criteria and 

HAP Pollutant 

Emission Factors

Apportion 

Emissions Based 

on Airport Activity 

for Air Taxis and 

General Aviation

Split into: 

Jet-Propelled and 

Piston-Driven 

Aircraft

FAA LTO Data 

for Air Taxis 

and General 

Aviation

(5010 and TAF)

Apply Criteria and 

HAP Pollutant 

Emission Factors

Apportion 

Emissions Based 

on Airport Activity 

for Air Taxis and 

General Aviation
2-16 

Lead emission estimates were handled differently. Lead emissions are associated with 

leaded aviation fuel used in piston driven aircraft associated with general aviation. Lead 

emissions per LTO are calculated using the following equation: 

Pb(tons) = (piston-engine LTO) (7.34 g Pb/LTO) (0.95) / 907,180 (g/ton) 

Where the lead content of aviation gasoline is assumed to be 0.56 grams per liter or 

2.12 grams per gallon. 

In flight lead emissions were calculate based on national aviation gasoline consumption 

and similar assumptions noted above about lead fuel content and retention rates. Lead emissions 

associated with airport LTO activities were subtracted from the national fuel based lead 

emissions to approximate in flight lead emissions which were allocated to individual counties 

and noted with the code 777. 

For additional details on EPA lead emission calculation procedures see Calculating 

Piston-Engine Aircraft Airport Inventories for Lead for the 2008 National Emissions Inventory 

(included in Appendix B). 

HAP Emission Estimates 

As noted earlier, EDMS calculates organic HAP emissions for aircraft activity reported in 

the T-100 dataset. Representative HAP speciation profiles were used to estimate the individual 

chemical species for each aircraft type included in the TAF/5010 dataset. Profiles are used to 

split (or speciate) organic gases, hydrocarbons, and particulate matter emissions estimates into 

more individual HAP compounds using the following equation: 

Eixj = LTOix × SPixj

Where: 

Eixj = Emission estimate for aircraft type i equipped with engine type x 

and pollutant j (tons/year) 

LTOix = Annual count of LTO cycles for aircraft type i and engine type x 

SPixj = Generic speciation profiles for aircraft type i equipped with engine 

type x and pollutant j (tons/LTO) 

i = Aircraft type (i.e., air taxi, general aviation, and military) 

x = Engine type (i.e., jet or turboprop, and piston engine) 

j = Pollutant j 

Appendix A contains the HAP profiles converted to emissions factors used for this 2008 

inventory. In this version of the NEI aircraft emissions inventory the following corrections to the 

HAP emission estimates were made: 

 Acenpthylene was removed from this inventory for SCC 2275050012. 
2-17 

 To avoid double counting total xylene emissions were removed if speciated xylene 

factors were also available. 

2.5 How Were Emissions Allocated? 

For the 2008 inventory, emissions were individually estimated for each airport. A GIS 

database obtained from the Bureau of Transportation Statistics (BTS) contained airport level data 

with latitude and longitude coordinates. 

2.6 QA/QC 

Given the significant methodological changes over previous inventory efforts, several 

quality checks were implemented to ensure that these data were developed and allocated in a 

clear and reproducible manner. Some of the quality checks implemented include the following: 

Emissions allocations and estimations 

 All original data importations and transcriptions into the database were doublechecked for errors. 

 All calculation methods and approaches were evaluated for technical soundness. 

 All unit conversions and equations used to generate results were double-checked for 

errors. 

 All sources of original data are referenced in the spreadsheet. 

 Emission factors were compiled from a variety of sources. Each emission factor 

development methodologies were evaluated to identify the most accurate emission 

factor for use in this inventory effort. 

 Emission sums were evaluated across activity types (e.g., Aircraft, APU, and GSE) to 

ensure they consistently mirror LTO activity levels. 

 2008 pollutants and emissions were checked against the 2005 inventory to identify 

any missing pollutants or major changes compared to previous inventories. 

Discrepancies were investigated and revisions were made as needed. 

 The validity of SCC codes, FIP county codes, and pollutant codes were confirmed. 

 The validity of Airport and plane identification codes were confirmed. 

2.7 What are the Results? 

Table 2-4 summarizes the emission estimates for Aircraft, ground support equipment and 

APUs for criteria pollutants. Table 2-5 summarizes the emission estimates for individual HAPs. 

Both tables aggregate the data for all states, including the District of Columbia. Note that the 

2008 estimates do not include state submitted emissions data. 
2-18 

Table 2-4. Aircraft Criteria Emission Estimates 2008 (tons per year) 

Pollutant 

2008 

Military 

(2275001000) 

Commercial 

(2275020000) 

GA, Piston 

(2275050011)

GA, Turbine

(2275050012)

AT, Piston 

(2275060011)

AT, Turbine

(2275060012)

GSE, Gas 

(2265008005)

GSE, LPG 

(2267008005)

GSE, C

(226800

CO 33,161.20 75,463.61 192,510.69 56,532.07 19,116.38 10,180.90 18,005.13 1,768.69 1NOX 284.92 102,561.46 1,041.55 1,911.11 465.64 2,274.10 1,927.90 189.38 PM10-PRI 709.12 1,782.43 3,792.85 1,397.21 242.12 797.03 55.87 5.49 PM2.5-PRI 92.60 1,776.37 493.07 181.64 44.81 103.65 53.63 5.27 SO2 27.32 10,179.67 160.24 434.33 53.76 439.43 53.21 5.23 VOC 1,652.02 13,608.67 2,399.79 3,223.93 310.48 2,610.94 615.80 60.49 

Table 2-5. Aircraft HAP Emission Estimates 2008 (tons per year) 

Pollutant 

2008 

Military 

(2275001000) 

Commercial 

(2275020000) 

GA, Piston 

(2275050011)

GA, Turbine 

(2275050012) 

AT, Piston 

(2275060011) 

AT, Turbine 

(2275060012) 

GSE, Gas 

(2265008005) 

GSE, LPG 

(2267008005)

GSE, 

(22680

1,3-Butadiene 0.87 184.14 29.75 61.04 5.01 44.44 1-Methylnaphthalene 0.13 26.96 8.94 0.23 6.20 2,2,4-Trimethylpentane 0.69 1.09 1.55 0.03 0.51 8.95 0.88 2-methylnaphthalene 0.11 22.48 7.45 0.20 5.17 Acenaphthene 0.36 0.17 Acenaphthylene 2.03 0.93 Acetaldehyde 2.21 466.29 18.82 154.57 11.97 113.00 2.43 0.24 Acrolein 0.02 37.70 1.82 88.61 0.04 32.72 Anthracene 0.42 6.16E-04 0.19 3.52E-04 Benz[a]Anthracene 6.09E-04 0.05 9.33E-05 0.02 5.32E-05 Benzene 0.87 183.48 122.97 60.82 7.58 44.59 10.44 1.03 Benzo[a]Pyrene 4.52E-04 0.05 5.11E-05 0.02 2.91E-05 Benzo[b]Fluoranthene 8.89E-04 0.06 0.03 Benzo[g,h,i,]Perylene 8.11E-06 0.13 8.47E-06 0.06 4.83E-06 Benzo[k]Fluoranthene 8.89E-04 0.06 0.03 Chrysene 6.17E-04 0.05 8.69E-05 0.02 4.96E-05 
2-19 

Table 2-5. Aircraft HAP Emission Estimates 2008 (tons per year) (Continued) 

Pollutant 

2008 

Military 

(2275001000) 

Commercial 

(2275020000) 

GA, Piston 

(2275050011)

GA, Turbine 

(2275050012) 

AT, Piston 

(2275060011) 

AT, Turbine 

(2275060012) 

GSE, Gas 

(2265008005) 

GSE, LPG 

(2267008005)

GSE, 

(22680

Cumene 2.68E-05 0.05 0.11 0.04 Ethyl Benzene 1.55E-03 2.68 44.63 6.30 1.05 2.32 Fluoranthene 1.17E-03 0.45 1.29E-03 0.21 7.35E-04 Fluorene 0.74 0.34 Formaldehyde 6.36 1,343.45 81.67 445.41 38.06 327.87 7.20 0.71 Hexane 21.25 0.50 Indeno[1,2,3-c,d]Pyrene 0.00 0.04 0.02 Lead ** 245.48 8.97 Methane 0.01 18.96 14.79 14.61 1.44 Methanol 0.02 27.78 65.31 24.11 m-Xylene 0.14 26.44 0.36 1.58E-04 0.88 3.66 11.09 1.09 Naphthalene 0.28 54.17 21.11 20.42 5.05 13.86 O-xylene 0.08 15.56 2.03 9.30E-05 1.40 2.19 5.43 0.53 Phenanthrene 0.01 1.25 0.01 0.58 3.27E-03 Phenol 0.01 11.17 26.27 9.70 Propionaldehyde 0.38 79.35 1.82 26.30 2.29 19.45 1.48 0.15 Pyrene 1.42E-03 0.61 1.58E-03 0.28 8.99E-04 Styrene 0.16 33.73 10.32 11.18 1.18 8.25 Toluene 0.33 70.07 315.76 23.23 8.87 16.77 17.77 1.75 Xylenes (Mixed Isomers) 4.85 177.92 19.04 4.18 6.21 

** The lead estimated provided above represent emissions at individual airports, for 2008, there is an additional 296 tons of lead emitted as

combustion of leaded aviation gasoline during in flight operations which is not attributed to airports.
2-20 

2.8 Aircraft References 

Cook, Rich. Memorandum entitled Guidance on Mobile Source Emission Estimates in the 1996 

National Toxics Inventory, to Laurel Driver and Anne Pope, U.S. EPA Office of Air Quality 

Planning and Standards. U.S. EPA Office of Mobile Sources. Ann Arbor, MI. June 9, 1998. 

Cook, Rich. Memorandum entitled Source Identification and Base Year 1990 Emission Inventory 

Guidance for Mobile Source HAPs on the OAQPS List of 40 Priority HAPs, to Laurel Driver and 

Anne Pope, U.S. EPA Office of Air Quality Planning and Standards (OAQPS). U.S. EPA Office 

of Mobile Sources. Ann Arbor, MI. June 11, 1997. 

Billings, Richard and Roger Chang, Eastern Research Group, Inc. Memorandum entitled Revised 

HAP Speciation Profiles for Commercial Aircraft, to Laurel Driver and Rich Cook, U.S. 

Environmental Protection Agency. October 25, 2004. 

Federal Aviation Administration. General Aviation and Part 135 Activity Survey - Calendar 

Year 2008. Downloaded from the following Internet site: 

http://www.faa.gov/data_research/aviation_data_statistics/general_aviation/. 

Federal Aviation Administration. Emissions and Dispersion Modeling System (EDMS), Version 

5.1 released September 2008. Downloaded from the following Internet site: 

http://www.faa.gov/about/office_org/headquarters_offices/aep/models/edms_model/. 

U.S. Department of Transportation. Emissions and Dispersion Modeling System, Version 5.1. 

Federal Aviation Administration. September 2008. Downloaded from the following Internet site: 

http://www.faa.gov/about/office_org/headquarters_offices/aep/models/edms_model/. 

U.S. Department of Transportation. Terminal Area Forecast System. Federal Aviation 

Administration, Aviation Policy and Plans. Downloaded from the following Internet Site: 

http//www.apo.data.faa.gov/. 

U.S. Department of Transportation. T-100 Segment (All Carriers). Bureau of Transportation 

Statistics. Downloaded from the following Internet site: http://transtats.bts.gov/. 

U.S. Environmental Protection Agency and Federal Aviation Administration. Recommended Best 

Practice for Quantifying Speciated Organic Gas Emissions from Aircraft Equipped with 

Turbofan, Turbojet, and Turboprop Engines - Version 1.0. EPA-420-R-09-901. Assessment and 

Standards Division, Office of Transportation and Air Quality, U.S. Environmental Protection 

Agency in collaboration with the AEE-300 - Emissions Division, Office of Environment and 

Energy, Federal Aviation Administration. May 2009. 

U.S. Environmental Protection Agency. Lead Emissions from the Use of Leaded Aviation 

Gasoline in the United States - Technical Support Document. EPA-420-R-08-020. Assessment 

and Standards Division, Office of Transportation and Air Quality. October 2008. 

U.S. Environmental Protection Agency. Calculating Aviation Gasoline Lead Emissions in the 

Draft 2008 NEI. Assessment and Standards Division, Office of Transportation and Air Quality. 

December 2009. 
2-21 

U.S. Environmental Protection Agency. Procedures for Emission Inventory Preparation, Volume 

IV: Mobile Sources. EPA-450/4-81-026d (Revised). Office of Air and Radiation. Research 

Triangle Park, NC, and Ann Arbor, MI. 1992. 
Appendix A 

Generic Aircraft Emission Factors/ Speciation Profiles 
A-1 

Commercial Aircraft Emission Factors 

Pollutant CAS No. 

CAA 

"187" 

or IRIS 

HAP? 

Emission 

Factors 

(tons/LTO) 

THC 2.680E-03 

VOC 2.934E-03 

TOG 3.276E-03 

NOx 9.288E-03 

CO 1.119E-02 

SOx 8.910E-04 

PM10 5.385E-04 

PM2.5 5.256E-04 

Acetaldehyde 75070 CAA 1.400E-04 

Acetone 67641 1.025E-05 

Acetylene 74862 1.290E-04 

Acrolein 107028 CAA 8.023E-05 

Benzaldehyde 100527 IRIS 1.540E-05 

Benzene 71432 CAA 5.507E-05 

Benzo(a)anthracene 56553 1.297E-09 

Benzo(a)pyrene 50328 9.621E-10 

Benzo(b)fluoranthene 205992 1.892E-09 

Benzo(ghi)perylene 191242 1.726E-11 

Benzo(k)fluoranthene 207089 1.892E-09 

1,3-Butadiene 101314 CAA 5.527E-05 

1-Butene 101389 5.746E-05 

Butyraldehyde 123728 3.899E-06 

C14-Alkane No CAS 6.094E-06 

C15-Alkane No CAS 5.799E-06 

C16 Branched Alkane No CAS 4.783E-06 

C18-Alkane No CAS 6.552E-08 

C4-Benzene + C3-Aroald No CAS 2.149E-05 

C5-Benzene+C4-Aroald No CAS 1.061E-05 

Chrysene 218019 1.313E-09 

Cis-2-Butene 514181 6.880E-06 

Cis-2-Pentene 627203 9.042E-06 

Crotonaldehyde 4170303 3.384E-05 

1-Decene 872059 6.061E-06 

Dibenzo(ah)anthracene 53703 2.551E-09 

Dimethylnapthalenes 28804888 2.949E-06 

Ethane 74840 1.707E-05 

Ethylbenzene 100414 CAA 5.701E-06 

Ethylene 74851 5.065E-04 

Fluoranthene 206440 2.492E-09 
A-2 

Commercial Aircraft Emission Factors 

Pollutant CAS No. 

CAA 

"187" 

or IRIS 

HAP? 

Emission 

Factors 

(tons/LTO) 

Formaldehyde 50000 CAA 4.033E-04 

Glyoxal 107222 5.950E-05 

Heptene 25339564 1.435E-05 

Hexadecane 544763 1.605E-06 

1-Hexene 592416 2.411E-05 

Indeno(1,2,3-cd)pyrene 193395 2.050E-09 

Isopropylbenzene 98828 CAA 9.829E-08 

Isovaleraldehyde 514863 1.048E-06 

Methacrolein 78853 1.405E-05 

Methanol 67561 CAA 5.913E-05 

Methyl Glyoxal 78988 4.924E-05 

1-Methyl Naphthalene 14120 8.092E-06 

2-Methyl Naphthalene 91576 IRIS 6.749E-06 

3-Methyl-1-Butene 563451 3.669E-06 

4-Methyl-1-Pentene 131372 4.259E-07 

2-Methyl-1-Butene 563462 4.587E-06 

2-Methyl-2-Butene 513359 6.061E-06 

2-Methylpentane 107835 1.337E-05 

2-Methyl-1-Pentene 763291 1.114E-06 

M-Ethyltoluene 620144 5.045E-06 

M-Tolualdehyde 620235 9.108E-06 

Naphthalene (gas phase) 91203 CAA 6.084E-06 

Naphthalene (solid phase) 91203 CAA 1.260E-06 

Napthalene 91203 CAA 1.772E-05 

N-Decane 124185 1.048E-05 

N-Dodecane 112403 1.514E-05 

N-Heptadecane 629787 2.949E-07 

N-Heptane 142825 2.097E-06 

N-Nonane 111842 2.031E-06 

N-Octane 111659 2.031E-06 

1-Nonene 124118 8.059E-06 

N-Pentadecane 629629 5.668E-06 

N-Pentane 109660 6.487E-06 

N-Propylbenzene 103651 1.736E-06 

N-Tetradecane 629594 1.363E-05 

N-Tridecane 629505 1.753E-05 

N-Undecane 1120214 1.455E-05 

Octene 111660 9.042E-06 

O-Ethyltoluene 611143 2.130E-06 

 
A-3 

Commercial Aircraft Emission Factors 

Pollutant CAS No. 

CAA 

"187" 

or IRIS 

HAP? 

Emission 

Factors 

(tons/LTO) 

O-Tolualdehyde 529204 7.535E-06 

1-Pentene 109671 2.542E-05 

P-Ethyltoluene 622968 2.097E-06 

Phenanthrene 85018 1.112E-08 

Phenol 108952 CAA 2.378E-05 

Propane 74986 2.555E-06 

Propionaldehyde 123386 CAA 2.382E-05 

Propylene 115071 1.485E-04 

P-Tolualdehyde 104870 1.573E-06 

Pyrene 121400 3.028E-09 

Styrene 100425 CAA 1.012E-05 

Toluene 108883 CAA 2.103E-05 

Trans-2-Hexene 4050457 9.829E-07 

Trans-2-Pentene 646048 1.176E-05 

1,2,3-Trimethylbenzene 526738 3.473E-06 

1,2,4-Trimethylbenzene 95636 1.147E-05 

1,3,5-Trimethylbenzene 108678 1.769E-06 

2,2,4-Trimethylpentane 540841 CAA 1.466E-06 

Valeraldehyde 110623 8.027E-06 

Xylene 1330207 CAA 1.032E-05 

 
A-4 

Air Taxi Emission Factors - Jet 

Pollutant CAS No. 

CAA 

"187" 

or IRIS 

HAP? 

Emission 

Factors 

(tons/LTO) 

THC 4.37E-04 

VOC 5.03E-04 

TOG 5.06E-04 

NOx 3.88E-04 

CO 1.81E-03 

SOx 8.12E-05 

PM10 3.017E-04 

PM2.5 3.922E-05 

Acetaldehyde 75070 CAA 2.160E-05 

Acetone 67641 1.583E-06 

Acetylene 74862 1.992E-05 

Acrolein 107028 CAA 1.238E-05 

Anthracene 120127 1.331E-10 

Benzaldehyde 100527 IRIS 2.377E-06 

Benzene 71432 CAA 8.500E-06 

Benzo(a)anthracene 56553 2.014E-11 

Benzo(a)pyrene 50328 1.103E-11 

Benzo(ghi)perylene 191242 1.829E-12 

1,3-Butadiene 101314 CAA 8.531E-06 

1-Butene 101389 8.869E-06 

Butyraldehyde 123728 6.017E-07 

C14-Alkane No CAS 9.405E-07 

C15-Alkane No CAS 8.950E-07 

C16 Branched Alkane No CAS 7.383E-07 

C18-Alkane No CAS 1.011E-08 

C4-Benzene + C3-Aroald No CAS 3.317E-06 

C5-Benzene+C4-Aroald No CAS 1.638E-06 

Chrysene 218019 1.876E-11 

Cis-2-Butene 514181 1.062E-06 

Cis-2-Pentene 627203 1.396E-06 

Crotonaldehyde 4170303 5.224E-06 

1-Decene 872059 9.355E-07 

Dimethylnapthalenes 28804888 4.551E-07 

Ethane 74840 2.635E-06 

Ethylbenzene 100414 CAA 8.799E-07 

Ethylene 74851 7.818E-05 

Fluoranthene 206440 2.784E-10 

Formaldehyde 50000 CAA 6.225E-05 

Glyoxal 107222 9.183E-06 

 
A-5 

Air Taxi Emission Factors - Jet 

Pollutant CAS No. 

CAA 

"187" 

or IRIS 

HAP? 

Emission 

Factors 

(tons/LTO) 

Heptene 25339564 2.215E-06 

Hexadecane 544763 2.478E-07 

1-Hexene 592416 3.722E-06 

Isopropylbenzene 98828 CAA 1.517E-08 

Isovaleraldehyde 514863 1.618E-07 

Methacrolein 78853 2.169E-06 

Methanol 67561 CAA 9.127E-06 

Methyl Glyoxal 78988 7.600E-06 

1-Methyl Naphthalene 14120 1.249E-06 

2-Methyl Naphthalene 91576 IRIS 1.042E-06 

3-Methyl-1-Butene 563451 5.663E-07 

4-Methyl-1-Pentene 131372 6.574E-08 

2-Methyl-1-Butene 563462 7.079E-07 

2-Methyl-2-Butene 513359 9.355E-07 

2-Methylpentane 107835 2.063E-06 

2-Methyl-1-Pentene 763291 1.719E-07 

M-Ethyltoluene 620144 7.787E-07 

M-Tolualdehyde 620235 1.406E-06 

Napthalene 91203 CAA 2.736E-06 

N-Decane 124185 1.618E-06 

N-Dodecane 112403 2.336E-06 

N-Heptadecane 629787 4.551E-08 

N-Heptane 142825 3.236E-07 

N-Nonane 111842 3.135E-07 

N-Octane 111659 3.135E-07 

1-Nonene 124118 1.244E-06 

N-Pentadecane 629629 8.748E-07 

N-Pentane 109660 1.001E-06 

N-Propylbenzene 103651 2.680E-07 

N-Tetradecane 629594 2.104E-06 

N-Tridecane 629505 2.705E-06 

N-Undecane 1120214 2.245E-06 

Octene 111660 1.396E-06 

O-Ethyltoluene 611143 3.287E-07 

O-Tolualdehyde 529204 1.163E-06 

1-Pentene 109671 3.924E-06 

P-Ethyltoluene 622968 3.236E-07 

Phenanthrene 85018 1.238E-09 

Phenol 108952 CAA 3.671E-06 

 
A-6 

Air Taxi Emission Factors - Jet 

Pollutant CAS No. 

CAA 

"187" 

or IRIS 

HAP? 

Emission 

Factors 

(tons/LTO) 

Propane 74986 3.944E-07 

Propionaldehyde 123386 CAA 3.676E-06 

Propylene 115071 2.293E-05 

P-Tolualdehyde 104870 2.427E-07 

Pyrene 121400 3.401E-10 

Styrene 100425 CAA 1.563E-06 

Toluene 108883 CAA 3.246E-06 

Trans-2-Hexene 4050457 1.517E-07 

Trans-2-Pentene 646048 1.815E-06 

1,2,3-Trimethylbenzene 526738 5.360E-07 

1,2,4-Trimethylbenzene 95636 1.770E-06 

1,3,5-Trimethylbenzene 108678 2.731E-07 

2,2,4-Trimethylpentane 540841 CAA 1.915E-07 

Valeraldehyde 110623 1.239E-06 

Xylene 1330207 CAA 2.352E-06 

 
A-7 

Air Taxi Emission Factors - Piston 

Pollutant CAS No. 

CAA 

"187" 

or IRIS 

HAP? 

Emission 

Factors 

(tons/LTO) 

THC 7.750E-05 

VOC 8.484E-05 

TOG 9.474E-05 

NOx 7.900E-05 

CO 1.407E-02 

SOx 7.500E-06 

PM10 3.015E-04 

PM2.5 3.920E-05 

Acenaphthene 83329 2.201E-07 

Acenaphthylene 208968 1.242E-06 

Acetaldehyde 75070 CAA 5.874E-07 

Acrolein 107028 CAA 5.684E-08 

Anthracene 120127 2.563E-07 

Benzene 71432 CAA 3.837E-06 

Benzo(a)anthracene 56553 3.015E-08 

Benzo(a)pyrene 50328 3.015E-08 

Benzo(b)fluoranthene 205992 3.618E-08 

Benzo(ghi)perylene 191242 7.839E-08 

Benzo(k)fluoranthene 207089 3.618E-08 

1,3-Butadiene 101314 CAA 9.285E-07 

Chrysene 218019 3.015E-08 

Ethylbenzene 100414 CAA 1.393E-06 

Fluoranthene 206440 2.744E-07 

Fluorene 86737 4.553E-07 

Formaldehyde 50000 CAA 2.548E-06 

Indeno(1,2,3-cd)pyrene 193395 2.412E-08 

M-Xylene and P-Xylene 108383 CAA 2.201E-07 

Naphthalene (gas phase) 91203 CAA 4.327E-07 

Naphthalene (solid phase) 91203 CAA 4.432E-06 

N-Hexane 110543 6.632E-07 

O-Xylene 95476 CAA 1.242E-06 

Phenanthrene 85018 7.658E-07 

Propionaldehyde 123386 CAA 5.684E-08 

Pyrene 121400 3.739E-07 

Styrene 100425 CAA 3.221E-07 

Toluene 108883 CAA 9.853E-06 

2,2,4-Trimethylpentane 540841 CAA 3.394E-08 

 
A-8 

General Aviation Emission Factors - Jet 

Pollutant CAS No. 

CAA 

"187" 

or IRIS 

HAP? 

Emission 

Factors 

(tons/LTO) 

THC 3.00E-04 

VOC 2.73E-04 

TOG 3.06E-04 

NOx 1.62E-04 

CO 4.79E-03 

SOx 3.68E-05 

PM10 1.184E-04 

PM2.5 1.539E-05 

Acetaldehyde 75070 CAA 1.309E-05 

Acetone 67641 9.593E-07 

Acetylene 74862 1.207E-05 

Acrolein 107028 CAA 7.506E-06 

Anthracene 120127 5.221E-11 

Benzaldehyde 100527 IRIS 1.440E-06 

Benzene 71432 CAA 5.152E-06 

Benzo(a)anthracene 56553 7.903E-12 

Benzo(a)pyrene 50328 4.327E-12 

Benzo(ghi)perylene 191242 7.178E-13 

1,3-Butadiene 101314 CAA 5.170E-06 

1-Butene 101389 5.376E-06 

Butyraldehyde 123728 3.647E-07 

C14-Alkane No CAS 5.700E-07 

C15-Alkane No CAS 5.425E-07 

C16 Branched Alkane No CAS 4.475E-07 

C18-Alkane No CAS 6.130E-09 

C4-Benzene + C3-Aroald No CAS 2.010E-06 

C5-Benzene+C4-Aroald No CAS 9.930E-07 

Chrysene 218019 7.359E-12 

Cis-2-Butene 514181 6.436E-07 

Cis-2-Pentene 627203 8.459E-07 

Crotonaldehyde 4170303 3.166E-06 

1-Decene 872059 5.670E-07 

Dimethylnapthalenes 28804888 2.758E-07 

Ethane 74840 1.597E-06 

Ethylbenzene 100414 CAA 5.333E-07 

Ethylene 74851 4.738E-05 

Fluoranthene 206440 1.092E-10 

Formaldehyde 50000 CAA 3.773E-05 

Glyoxal 107222 5.566E-06 
A-9 

General Aviation Emission Factors - Jet 

Pollutant CAS No. 

CAA 

"187" 

or IRIS 

HAP? 

Emission 

Factors 

(tons/LTO) 

Heptene 25339564 1.342E-06 

Hexadecane 544763 1.502E-07 

1-Hexene 592416 2.256E-06 

Isopropylbenzene 98828 CAA 9.194E-09 

Isovaleraldehyde 514863 9.807E-08 

Methacrolein 78853 1.315E-06 

Methanol 67561 CAA 5.532E-06 

Methyl Glyoxal 78988 4.606E-06 

1-Methyl Naphthalene 14120 7.570E-07 

2-Methyl Naphthalene 91576 IRIS 6.313E-07 

3-Methyl-1-Butene 563451 3.433E-07 

4-Methyl-1-Pentene 131372 3.984E-08 

2-Methyl-1-Butene 563462 4.291E-07 

2-Methyl-2-Butene 513359 5.670E-07 

2-Methylpentane 107835 1.250E-06 

2-Methyl-1-Pentene 763291 1.042E-07 

M-Ethyltoluene 620144 4.720E-07 

M-Tolualdehyde 620235 8.520E-07 

Naphthalene (gas phase) 91203 CAA 1.674E-06 

Naphthalene (solid phase) 91203 CAA 5.571E-08 

Napthalene 91203 CAA 1.658E-06 

N-Decane 124185 9.807E-07 

N-Dodecane 112403 1.416E-06 

N-Heptadecane 629787 2.758E-08 

N-Heptane 142825 1.961E-07 

N-Nonane 111842 1.900E-07 

N-Octane 111659 1.900E-07 

1-Nonene 124118 7.539E-07 

N-Pentadecane 629629 5.302E-07 

N-Pentane 109660 6.068E-07 

N-Propylbenzene 103651 1.624E-07 

N-Tetradecane 629594 1.275E-06 

N-Tridecane 629505 1.640E-06 

N-Undecane 1120214 1.361E-06 

Octene 111660 8.459E-07 

O-Ethyltoluene 611143 1.992E-07 

O-Tolualdehyde 529204 7.049E-07 

1-Pentene 109671 2.378E-06 

P-Ethyltoluene 622968 1.961E-07 

Phenanthrene 85018 4.858E-10 
A-10 

General Aviation Emission Factors - Jet 

Pollutant CAS No. 

CAA 

"187" 

or IRIS 

HAP? 

Emission 

Factors 

(tons/LTO) 

Phenol 108952 CAA 2.225E-06 

Propane 74986 2.391E-07 

Propionaldehyde 123386 CAA 2.228E-06 

Propylene 115071 1.390E-05 

P-Tolualdehyde 104870 1.471E-07 

Pyrene 121400 1.334E-10 

Styrene 100425 CAA 9.470E-07 

Toluene 108883 CAA 1.968E-06 

Trans-2-Hexene 4050457 9.194E-08 

Trans-2-Pentene 646048 1.100E-06 

1,2,3-Trimethylbenzene 526738 3.249E-07 

1,2,4-Trimethylbenzene 95636 1.073E-06 

1,3,5-Trimethylbenzene 108678 1.655E-07 

2,2,4-Trimethylpentane 540841 CAA 1.313E-07 

Valeraldehyde 110623 7.509E-07 

Xylene 1330207 CAA 1.612E-06 

 
A-11 

General Aviation Emission Factors - Piston 

Pollutant CAS No. 

CAA 

"187" 

or IRIS 

HAP? 

Emission 

Factors 

(tons/LTO) 

THC 7.750E-05 

VOC 7.524E-05 

TOG 8.537E-05 

NOx 3.250E-05 

CO 6.007E-03 

SOx 5.000E-06 

PM10 1.184E-04 

PM2.5 1.539E-05 

Acenaphthene 83329 1.123E-08 

Acenaphthylene 208968 6.339E-08 

Acetaldehyde 75070 CAA 5.874E-07 

Acrolein 107028 CAA 5.684E-08 

Anthracene 120127 1.308E-08 

Benzene 71432 CAA 3.837E-06 

Benzo(a)anthracene 56553 1.539E-09 

Benzo(a)pyrene 50328 1.539E-09 

Benzo(b)fluoranthene 205992 1.846E-09 

Benzo(ghi)perylene 191242 4.000E-09 

Benzo(k)fluoranthene 207089 1.846E-09 

1,3-Butadiene 101314 CAA 9.285E-07 

Chrysene 218019 1.539E-09 

Ethylbenzene 100414 CAA 1.393E-06 

Fluoranthene 206440 1.400E-08 

Fluorene 86737 2.323E-08 

Formaldehyde 50000 CAA 2.548E-06 

Indeno(1,2,3-cd)pyrene 193395 1.231E-09 

M-Xylene and P-Xylene 108383 CAA 1.123E-08 

Naphthalene (gas phase) 91203 CAA 4.327E-07 

Naphthalene (solid phase) 91203 CAA 2.262E-07 

N-Hexane 110543 6.632E-07 

O-Xylene 95476 CAA 6.339E-08 

Phenanthrene 85018 3.908E-08 

Propionaldehyde 123386 CAA 5.684E-08 

Pyrene 121400 1.908E-08 

Styrene 100425 CAA 3.221E-07 

Toluene 108883 CAA 9.853E-06 

2,2,4-Trimethylpentane 540841 CAA 3.394E-08 

 
A-12 

Military Emission Factor 

Pollutant CAS No. 

CAA 

"187" 

or IRIS 

HAP? 

Emission 

Factors 

(tons/LTO) 

THC 6.170E-04 

VOC 6.815E-04 

TOG 7.597E-04 

NOx 7.900E-05 

CO 1.407E-02 

SOx 7.500E-06 

PM10 3.017E-04 

PM2.5 3.922E-05 

Acetaldehyde 75070 CAA 3.245E-05 

Acetone 67641 2.378E-06 

Acetylene 74862 2.993E-05 

Acrolein 107028 CAA 1.861E-05 

Benzaldehyde 100527 IRIS 3.571E-06 

Benzene 71432 CAA 1.277E-05 

1,3-Butadiene 101314 CAA 1.282E-05 

1-Butene 101389 1.333E-05 

Butyraldehyde 123728 9.041E-07 

C14-Alkane No CAS 1.413E-06 

C15-Alkane No CAS 1.345E-06 

C16 Branched Alkane No CAS 1.109E-06 

C18-Alkane No CAS 1.519E-08 

C4-Benzene + C3-Aroald No CAS 4.984E-06 

C5-Benzene+C4-Aroald No CAS 2.461E-06 

Cis-2-Butene 514181 1.595E-06 

Cis-2-Pentene 627203 2.097E-06 

Crotonaldehyde 4170303 7.848E-06 

1-Decene 872059 1.405E-06 

Dimethylnapthalenes 28804888 6.837E-07 

Ethane 74840 3.958E-06 

Ethylbenzene 100414 CAA 1.322E-06 

Ethylene 74851 1.175E-04 

Formaldehyde 50000 CAA 9.352E-05 

Glyoxal 107222 1.380E-05 

Heptene 25339564 3.328E-06 

Hexadecane 544763 3.723E-07 

1-Hexene 592416 5.591E-06 

Isopropylbenzene 98828 CAA 2.279E-08 

Isovaleraldehyde 514863 2.431E-07 

Methacrolein 78853 3.259E-06 
A-13 

Military Emission Factor 

Pollutant CAS No. 

CAA 

"187" 

or IRIS 

HAP? 

Emission 

Factors 

(tons/LTO) 

Methanol 67561 CAA 1.371E-05 

Methyl Glyoxal 78988 1.142E-05 

1-Methyl Naphthalene 14120 1.876E-06 

2-Methyl Naphthalene 91576 IRIS 1.565E-06 

3-Methyl-1-Butene 563451 8.509E-07 

4-Methyl-1-Pentene 131372 9.876E-08 

2-Methyl-1-Butene 563462 1.064E-06 

2-Methyl-2-Butene 513359 1.405E-06 

2-Methylpentane 107835 3.100E-06 

2-Methyl-1-Pentene 763291 2.583E-07 

M-Ethyltoluene 620144 1.170E-06 

M-Tolualdehyde 620235 2.112E-06 

Napthalene 91203 CAA 4.110E-06 

N-Decane 124185 2.431E-06 

N-Dodecane 112403 3.510E-06 

N-Heptadecane 629787 6.837E-08 

N-Heptane 142825 4.862E-07 

N-Nonane 111842 4.710E-07 

N-Octane 111659 4.710E-07 

1-Nonene 124118 1.869E-06 

N-Pentadecane 629629 1.314E-06 

N-Pentane 109660 1.504E-06 

N-Propylbenzene 103651 4.026E-07 

N-Tetradecane 629594 3.160E-06 

N-Tridecane 629505 4.064E-06 

N-Undecane 1120214 3.373E-06 

Octene 111660 2.097E-06 

O-Ethyltoluene 611143 4.938E-07 

O-Tolualdehyde 529204 1.747E-06 

1-Pentene 109671 5.895E-06 

P-Ethyltoluene 622968 4.862E-07 

Phenol 108952 CAA 5.515E-06 

Propane 74986 5.926E-07 

Propionaldehyde 123386 CAA 5.523E-06 

Propylene 115071 3.445E-05 

P-Tolualdehyde 104870 3.647E-07 

Styrene 100425 CAA 2.348E-06 

Toluene 108883 CAA 4.877E-06 

Trans-2-Hexene 4050457 2.279E-07 

Trans-2-Pentene 646048 2.727E-06 
A-14 

Military Emission Factor 

Pollutant CAS No. 

CAA 

"187" 

or IRIS 

HAP? 

Emission 

Factors 

(tons/LTO) 

1,2,3-Trimethylbenzene 526738 8.053E-07 

1,2,4-Trimethylbenzene 95636 2.659E-06 

1,3,5-Trimethylbenzene 108678 4.102E-07 

Valeraldehyde 110623 1.861E-06 
Appendix B 

Calculating Piston-Engine Aircraft Airport Inventories for Lead for the 2008 

National Emissions Inventory 
B-1 

Calculating Piston-Engine Aircraft Airport Inventories for Lead for the 2008

National Emissions Inventory

December 2010 

Section 1. Introduction

The main purpose of this document is to describe the methods the Environmental 

Protection Agency (EPA) used to calculate airport lead (Pb) inventories for the 2008 

National Emissions Inventory (NEI).1 These methods focus on the development of 

approaches to estimate piston-engine aircraft activity at airports in the U.S. since the 

activity of this fleet is reported to the Federal Aviation Administration (FAA) as general 

aviation (GA) or air taxi (AT) activity – categories that also include jet-engine aircraft 

activity. The methods described here reflect improvements to the methods used in 

developing the airport-specific piston-engine aircraft inventories in the 2002 NEI and the 

2005 NEI. 

Background information regarding the use of leaded aviation gasoline (avgas) in 

piston-engine powered aircraft is available in other documents.2,3 Briefly, most pistonengine aircraft operations fall into the categories of either GA or AT. Aircraft used in 

GA and AT activities include a diverse set of aircraft types and engine models and are 

used in a wide variety of applications.4 Lead emissions associated with GA and AT 

aircraft stem from the use of one hundred octane low lead (100LL) avgas. The lead is 

added to the fuel in the form of tetraethyl lead (TEL). This lead additive helps boost fuel 

octane, prevent engine knock, and prevent valve seat recession and subsequent loss of 

compression for engines without hardened valves. Today, 100LL is the most commonly 

available type of aviation gasoline in the United States.5 Lead is not added to jet fuel that 

is used in commercial aircraft, most military aircraft, or other turbine-engine powered 

aircraft. Lead emissions from the use of leaded avgas comprised 45% of the national 

inventory for emissions of lead in 2002.6 

1

 In this document ‘2008 NEI’ refers to 2008 NEI version 1 (January 2011), available at 

http://www.epa.gov/ttn/chief/net/2008inventory.html

2

 EPA (2007) Review of the National Ambient Air Quality Standards for Lead: Policy Assessment of 

Scientific and Technical Information. OAQPS Staff Paper. EPA-452/R-07-013 November 2007. pp 2-8 and 

2-9. 

3

FAA William J. Hughes Technical Center 

http://www.tc.faa.gov/act4/insidethefence/2006/0609_06_AvFuels.htm 4

 Commercial aircraft include those used for scheduled service transporting passengers, freight, or both. 

Air taxis fly scheduled and for-hire service carrying passengers, freight or both, but they usually are smaller 

aircraft than those operated by commercial air carriers. General aviation includes most other aircraft (fixed 

and rotary wing) used for personal transportation, business, instructional flying, and aerial application. 5

 ChevronTexaco (2005) Aviation Fuels Technical Review. FTR-3. 

http://www.chevronglobalaviation.com/docs/aviation_tech_review.pdf 6

 U.S. Environmental Protection Agency (2008) EPA’s Report on the Environment EPA/600/R-07/045F. 

Available at: http://www.epa.gov/roe
B-2 

This document is organized into eight sections. Section 2 describes the data we 

use to calculate the national inventory for the amount of lead released to the air from the 

combustion of leaded avgas. Section 3 describes the landing and takeoff data we use to 

calculate airport-specific inventories for lead. Section 4 describes how we estimate 

landing and takeoff data for the airport facilities that do not report it to the FAA. 

Section 5 describes the estimate of landing and takeoff activity occurring at heliports in the 

U.S. Section 6 describes the methods used to calculate the airport-specific inventories for 

lead. Section 7 describes data that would be needed to improve the estimates of airportspecific inventories for lead and Section 8 describes the estimates of the amount of lead 

emitted in-flight that are in the 2008 NEI. 

In this document, units of tons (i.e., U.S. short tons) are used when discussing the 

national and airport-specific lead inventory in order to be consistent with the manner in 

which the NEI reports inventories for lead and other pollutants. The unit of grams is used 

in describing the concentration of lead in avgas and in describing emission factors. 

Conversion factors are provided for clarity. 

Section 2. Calculating the National Avgas Lead Inventory

Because lead is a persistent pollutant and accumulates in the environment, we 

include all lead emissions from piston-engine aircraft in the NEI – emissions occurring 

during the landing and take-off cycle at airports as well as emissions occurring at 

altitude.7 To calculate the national avgas lead inventory, we use information provided by 

the U.S. Department of Transportation’s (DOT’s) Federal Aviation Administration 

(FAA) regarding the volume of leaded avgas consumed in the U.S. in 2008.8 The U.S. 

Department of Energy’s (DOE’s) Energy Information Administration (EIA) provides 

information regarding the volume of leaded avgas produced in a given year. EPA has 

historically used the DOE EIA avgas fuel volume produced to calculate national lead 

inventories from the consumption of leaded avgas. However, since EPA uses DOT 

airport activity and aircraft data, we are using the DOT fuel volume data in the 2008 NEI 

to calculate the national lead inventory in order to use a consistent data source. In this 

document, when we refer to avgas fuel volume data it is data supplied by DOT, except 

where noted. 

As demonstrated in the equation below, to calculate the annual emission of lead 

from the consumption of leaded avgas, we multiply the volume of avgas used by the 

concentration of lead in the avgas, minus the small amount of lead that is retained in the 

engine, engine oil and/or exhaust system. The volume of avgas used in the U.S. in 2008 

7

 U.S. EPA, 2006. Air Quality: Criteria for Lead: 2006; EPA/600/R-5/144aF; U.S. Government Printing 

Office, Washington, DC, October, 2006. 

8

 U.S. Department of Transportation Federal Aviation Administration Aviation Policy and Plans. FAA 

Aerospace Forecast Fiscal Years 2010-2030. p.99. Available at: 

http://www.faa.gov/data_research/aviation/aerospace_forecasts/2010-

2030/media/2010%20Forecast%20Doc.pdf This document provides historical data for 2000-2008 as well 

as forecast data. 
B-3 

was 248,100,000 gallons.9

 The concentration of lead in avgas ([Pb] in the equation 

below) can be one of four levels (ranging from 0.14 to 1.12 grams of lead per liter) as 

specified by the American Society for Testing and Materials (ASTM). By far the most 

common avgas supplied is “100 Low Lead” or 100LL.10,11 The maximum lead 

concentration specified by ASTM for 100LL is 0.56 grams per liter or 2.12 grams per 

gallon.12 A fraction of lead is retained in the engine, engine oil and/or exhaust system 

which we currently estimate at 5%.13

For the 2008 NEI, the national estimate of lead emissions from the consumption 

of avgas was 551 tons (see equation below). 

(248,100,000 gal)(2.12 g Pb/gal)(0.95) = 551 tons Pb 

907,180 g/ton 

As described above, DOE’s EIA also provides estimates of the annual volume of 

leaded avgas produced in a given year. For 2008, the volume of avgas produced in the 

U.S. was 5,603 thousand barrels or 235,326,000 gallons.14 Consumption of this volume 

of avgas equates to a national lead emissions estimate for this source of 522 short tons. 

Section 3. Landing and Takeoff Data Sources and Uses

Airport-specific inventories require information regarding landing and takeoff 

(LTO) activity by aircraft type.15 According to FAA records, there are approximately 

20,000 airport facilities in the U.S., the vast majority of which are expected to have 

activity by piston-engine aircraft that operate on leaded avgas. Of these facilities, EPA’s 

NEI has in the past, reported emissions of lead (and other criteria pollutants and 

9

 U.S. Department of Transportation Federal Aviation Administration Aviation Policy and Plans. FAA

Aerospace Forecast Fiscal Years 2010-2030. p.99. Available at: 

http://www.faa.gov/data_research/aviation/aerospace_forecasts/2010-

2030/media/2010%20Forecast%20Doc.pdf This document provides historical data for 2000-2008 as well

as forecast data.

10 ChevronTexaco (2005) Aviation Fuels Technical Review. FTR-3. 11 The 2008 General Aviation Statistical Databook & Industry Outlook report by General Aviation

Manufactures Association (GAMA) found that over 90% of avgas is 100LL. 12 ASTM International (2005) Annual Book of ASTM Standards Section 5: Petroleum Products,

Lubricants, and Fossil Fuels Volume 05.01 Petroleum Products and Lubricants (I): D 56 – D 3230. 13 The information used to develop this estimate is from the following references: (a) Todd L. Petersen,

Petersen Aviation, Inc, Aviation Oil Lead Content Analysis, Report # EPA 1-2008, January 2, 2008, 

available at William J. Hughes Technical Center Technical Reference and Research Library at

http://actlibrary.tc.faa.gov/ and (b) E-mail from Theo Rindlisbacher of Switzerland Federal Office of Civil

Aviation to Bryan Manning of U.S. EPA, regarding lead retained in engine, September 28, 2007. 14 DOE Energy Information Administration. Fuel production volume data obtained from

http://tonto.eia.doe.gov/dnav/pet/hist/mgaupus1A.htm accessed November 2006. 15 An aircraft operation is defined as any landing or takeoff event, therefore, to calculate LTOs, operations

are divided by two. Most data sources from FAA report aircraft activity in numbers of operations which,

for the purposes of calculating lead emissions using the method described in this document, need to be

converted to LTO events.
B-4 

hazardous air pollutants) at 3,410 airports.16 While the 3,410 airport facilities are among 

the most active in the U.S., they comprise only a small fraction of the total airport 

facilities where leaded avgas is used. 

FAA’s Office of Air Traffic provides a complete listing of operational airport 

facilities in the National Airspace System Resources (NASR) database. The electronic 

NASR data report, referred to here as the 5010 airport data report, can be generated from 

the NASR database and is available for download from the FAA website.17 This report is 

updated every 56 days. EPA obtains airport information (including operations) for a 

subset of the facilities in the NASR database from FAA’s Terminal Area Forecast (TAF) 

database that is prepared by FAA’s Office of Aviation Policy and Plans.18 The TAF 

database currently includes information for airports in FAA’s National Plan of Integrated 

Airport Systems (NPIAS), which identifies airports that are significant to national air 

transportation. Approximately 500 of the airports that are in the TAF database have 

either an FAA air traffic control tower or an FAA contract tower where controllers count 

operations. The operations data from the control towers is reported to The Operations 

Network (OPSNET)19 which is publically available in the Air Traffic Activity System 

(ATADS) database.20 The operations data for the towered airports that is reported in 

OPSNET and ATADS is then reported to the TAF database. The operations data for the 

airports in the TAF database that do not have control towers represent estimates.21 The 

operations supplied in the 5010 airport data report for facilities not reported in the TAF 

may be self-reported by airport operators through data collection accomplished by airport 

inspectors who work for the State Aviation Agency, or operations data can be obtained 

through other means.22

The 5010 airport data report supplies the date that the associated operations data 

represents.23 Because airports that are not in the TAF database submit data voluntarily to 

FAA for the 5010 data report, many of the airports have operations data that represent 

data for years earlier than 2008. Nationally, GA and AT piston-engine operations have 

decreased in recent years,24 therefore EPA did not use operations data from years prior to 

2008 as it is reported. Instead, EPA multiplied the older GA and AT piston-engine data 

(Section 6 describes the method EPA used to calculate the number of piston-engine 

16 These 3,410 facilities are the facilities for which the FAA’s Terminal Area Forecast (TAF) database 

provides information regarding aircraft activity. The TAF database is prepared by FAA’s Office of 

Aviation Policy and Plans and includes information for the airports in FAA’s National Plan of Integrated 

Airport Systems (NPIAS). One of the goals of the NPIAS is to identify airports that are significant to 

national air transportation. 

17 http://www.faa.gov/airports_airtraffic/airports/airport_safety/airportdata_5010/ 18 http://aspm.faa.gov/main/taf.asp 19 http://aspm.faa.gov/opsnet/sys/ 20 http://aspm.faa.gov/opsnet/sys/Airport.asp 21 FAA’s Terminal Area Forecast Summary (Fiscal Years 2009 – 2030), Appendix A (page 28) 

http://www.faa.gov/data_research/aviation/taf_reports/media/TAF%20Summary%20Report%20FY%2020

09%20-%202030.pdf 

22 In the absence of updated information from States, local authorities or Tribes, we are using the LTO data 

provided in the FAA database. 

23 The 12-month ending date on which annual operations data in the report is based. 24 http://www.faa.gov/data_research/aviation_data_statistics/general_aviation/
B-5 

operations from total GA and AT activity data) by scaling factors that were calculated by 

dividing the 2008 national amount of avgas produced by the national amount of avgas 

produced in the year the operations data represents.25 A table with the scaling factors is 

provided in Appendix A. The national volume of avgas produced data comes from the 

DOE, EIA website and is available for 1981 – 2009.26 For operations data older than 

1981, EPA divided the 2008 national amount of avgas produced by the average of the 

national amount of avgas produced from 1981 – 1989. Jet engines do not use avgas, 

therefore EPA did not apply scaling factors to the turbine operations for data from years 

prior to 2008. 

EPA also obtains operations data from the T-100 segment data from the Bureau of 

Transportation Statistics (BTS). The aircraft in the T-100 data are matched to aircraft in 

the FAA’s Emission and Dispersion Modeling System (EDMS) using the crosswalk table 

developed for earlier versions of the NEI. Generally the T-100 data covers commercial 

air carrier operations, but some AT activities are included in the data set that would 

double count with the TAF data at the same airport. To correct for possible double 

counting, first the AT LTOs included in the T-100 data were compiled using the aircraft 

type data included in the aircraft make/models crosswalk.27 The resulting aggregated 

LTOs were compared with the reported TAF LTOs for airports where there were 

overlaps. The T-100 AT LTOs were then subtracted from the TAF AT data to ensure 

that double counting was minimized. Note that if the T-100 AT value was larger than the 

TAF value, the TAF value was set to zero to eliminate the possibility of negative LTOs in 

the dataset. 

The 2008 draft NEI was developed using the January 15, 2009 version of the 

5010 airport data report. In that version of the report there were 19,925 airport facilities 

in the U.S. that had submitted data to the FAA. Among these 19,925 facilities, 99 

facilities were not relevant for the purposes of estimating lead emissions because they 

were either listed as closed (85) or they were balloonports (14).28 Therefore, lead 

inventories were needed for 19,826 facilities. In the January 15, 2009 version of the 5010 

airport data report there were 5,654 airport facilities for which operations data were 

provided (many of which are facilities in FAA’s TAF database).29 There were 14,172 

facilities in the 5010 airport data report for which there were no operations data.30 As a 

25 The FAA General Aviation and Air Taxi (Part 135) Activity Surveys (source of national level pistonengine operations data) are only available annually, starting in 1999. Because there are airports with 

operations data older than 1999, EPA used avgas product supplied data as a surrogate for piston-engine 

operations to estimate the change in piston-engine activity over the last three decades. 

26 http://tonto.eia.doe.gov/dnav/pet/hist/LeafHandler.ashx?n=PET&s=mgaupus1&f=A. DOT recently 

changed the way they estimate fuel consumption data, so while EPA used DOT data to determine the 2008 

national avgas lead inventory, for the purpose of calculating these scaling factors EPA used DOE’s data in 

order to have historical fuel data that is calculated in a consistent manner. 27 The T-100 data does not specify that the operations data is air taxi in nature; however, in discussions with 

FAA, EPA determined that these flights are air taxi in nature and has assigned them in the 2008 NEI as 

such. 

28 Balloon craft do not use avgas 

29 Either Commuter, GA Itinerant, GA Local, or Air Taxi operations data, as these operations can be 

performed by piston-engine aircraft. 30 No Commuter, GA Itinerant, GA Local, or Air Taxi operations data. 
B-6 

part of the review process for the draft 2008 NEI, EPA received updated airport data from 

states and also looked at more recent versions of the 5010 airport data report to update the 

status of airports, so the number of airports for which EPA estimated activity is slightly 

lower in the 2008 NEI than in the draft 2008 NEI. The following section of this 

document describes the method EPA used to estimate operations for the 14,132 airport 

facilities in the 2008 NEI that do not have reported activity data. 

As described in Section 1, most piston-engine aircraft fall into the categories of 

either GA or AT. Some GA and AT activity is conducted by turboprop and turbojet 

aircraft which do not used leaded avgas. There are no national databases that provide 

airport-specific LTO activity data for piston-engine aircraft separately from turbojet and 

turboprop aircraft. The databases described above report total GA and AT activity 

conducted by both piston-engine and jet-engine aircraft. Part (a) in Section 6 describes 

how we estimate piston-engine LTOs at airports in the 2008 NEI. 

Section 4. Estimating LTOs at the 14,132 Airport Facilities with No LTO Data

FAA has used regression models to estimate operations at facilities where 

operations data are not available.31,32 In this work and other work, FAA identified 

characteristics of small towered airports for which there were statistically significant 

relationships with operations at these airports.33 Regression models based on the airport 

characteristics were then used to estimate general aviation operations for a set of nontowered airports. The airport characteristics identified by FAA and used to estimate 

general aviation operations at small airports include: the number of aircraft based at a 

facility (termed ‘based aircraft’), population in the vicinity of the airport, airport regional 

prominence, per capita income, region, and the presence of certificated flight schools. 

In the 2000 report titled ‘Model for Estimating General Aviation Operations at 

Non-towered Airports,’ a model of GA annual activity was developed using information 

from small towered airports to explain GA activity at towered and non-towered airports. 

The model explained GA activity at the towered airports well (R2

 of 0.75) but produced 

higher estimates than state-supplied estimates for non-towered airports.34

The relevant data available in the 5010 airport data report for the purposes of 

estimating airport operations include: facility type (airport, balloonport, seaplane base, 

gliderport, heliport, stolport,35 ultralight); number of GA aircraft based at each airport by 

31 Federal Aviation Administration, Office of Aviation Policy and Plans, Statistics and Forecast Branch.

July 2001. Model for Estimating General Aviation Operations at Non-towered Airports Using Towered 

and Non-towered Airport Data. Prepared by GRA, Inc. 32 Mark Hoekstra, “Model for Estimating General Aviation Operations at Non-Towered Airports” prepared

for FAA Office of Aviation Policy and Plans, April 2000.

33 GRA, Inc. “Review of TAF Methods,” Final Report, prepared for FAA Office of Aviation Policy and 

Plans under Work Order 45, Contract No. DTFA01-93-C-00066, February 25, 1998. 34 The mean absolute difference between the model operations estimate and the state operations estimate 

was 16,940 operations.

35 Stolport is an airport designed with STOL (Short Take-Off and Landing) operations in mind, normally 

having a short single runway.
B-7 

type (glider, helicopter, jet engine, military, multi-engine, single engine, ultralight); 

operations data (air taxi, commercial, commuter, GA itinerant, GA local, military)36; and 

operations date (12-month ending date on which annual operations data is based). 

Census data was also merged with the 5010 airport data report to give population data for 

each airport’s county. 

Using the FAA work referenced above, we explored relationships among the 

airport data variables that best predicted aircraft activity (LTOs). We found that based 

aircraft was a highly significant and positive regressor to LTOs. Table 1 shows that for 

facilities that did not have LTO data in the January 15, 2009 version of the 5010 airport 

data report, 7,856 had based aircraft data while 6,316 did not have based aircraft data.37, 38 

Therefore, as described below, LTO estimates were derived using different methods 

depending on data availability. 

Table 1: Contingency table describing the numbers of airport facilities that have or do 

not have LTO data and/or based aircraft data for airport facilities in the January 15, 2009 

version of the 5010 airport data report 

HAVE LTO DATA 

YES NO 

YES 4,872 7,856 12,728 

NO 782 6,316 7,098 

5,654 14,172 19,826 

36 As explained in footnote 15, an aircraft operation is defined as any landing or takeoff event, therefore, to 

calculate LTOs, operations are divided by two. The 5010 airport data report from FAA reports aircraft 

activity in numbers of operations which, for the purposes of calculating Pb emissions using the method 

described in the TSD, are converted to LTO events. 

37 As described in Section 3, the number of facilities with no LTO data changed slightly from the draft 2008 

NEI to the 2008 NEI. In the 2008 NEI, of the facilities that did not have reported activity data, 7,837 

facilities reported based aircraft data and 6,295 did not report based aircraft data. 

38 These numbers include data for the following types of facilities: airports, balloonports, seaplane bases, 

gliderports, heliports, stolports, and ultralights. 

HAVE

BASED 

AIRCRAFT

DATA
B-8 

(a) Estimating LTOs at Facilities with Based Aircraft Data, but No LTO Data: 

There are 6,414 facilities in the 2008 NEI (not including heliports) for which the 

5010 airport data report supplies the number of based aircraft39 but not activity data to 

which the regression equation (based aircraft vs. LTOs) could be applied. Using the 

4,872 airports for which both LTO and aircraft data is known, the initial relationship 

found between based aircraft and LTOs was: 

Equation 1: 

LTOs = 2494 + 208*aircraft R2 = 0.55

The FAA models found population to be another significant regressor. We used 

the population of the county in which the airport is located as the population variable. 

Adding county population to the model gave the following relationship: 

Equation 2: 

LTOs = 2204 + 194*aircraft + 0.0038*county population R2 = 0.56

EPA received numerous comments to the docket on its Advance Notice of 

Proposed Rulemaking on Lead Emissions from Piston-Engine Aircraft Using Leaded 

Aviation Gasoline40 indicating that aviation in Alaska is different than it is in the 

continental U.S. Commenters pointed out that in Alaska, 82% of communities are not 

accessible by road and rely on air transport for life sustaining goods and services.41

Commenters also noted that Alaskans travel by air eight times more often per capita than 

those in the continental U.S. For those reasons, we added a dummy variable in equation 

3 to identify whether or not an airport is located in Alaska. Because the relationship 

between based aircraft and LTOs is likely different for Alaskan airports than it is for 

airports that aren’t in Alaska, we also added an interaction term to equation 3 (interaction 

of an airport being in Alaska and its sum of based aircraft). 

Equation 3: 

LTOs = 1937 + 205*aircraft + 0.0038*county population + 566*Alaska –

108*(AlaskaXaircraft)

R2 = 0.58 

After analyzing the data and plot for the data underlying equation 3, we found 

many airport facilities identified as commercial airports for which based aircraft was 

extremely low (i.e., less than 10), yet LTOs were quite high (i.e., anywhere from 100,000 

39 Based aircraft for this purpose was limited to single- and multi-engine aircraft, helicopters, and 

ultralights since these aircraft types can use leaded avgas. 40 U.S. Environmental Protection Agency (2010) Advance Notice of Proposed Rulemaking on Lead 

Emissions From Piston-Engine Aircraft Using Leaded Aviation Gasoline. 75 FR 22440 (April 28, 2010). 41 Comments to the docket on EPA’s Advance Notice of Proposed Rulemaking on Lead Emissions from 

Piston-Engine Aircraft Using Leaded Aviation Gasoline from the Alaska Air Carriers Association (dated 18 

June 2010; comment number OAR-2007-0294-0323.1) and Alaska Governor Parnell (dated 25 August 

2010; comment number OAR-2007-0294-0403.1). 
B-9 

to more than 200,000 LTOs/year).42 These facilities were removed from the regression

analysis. Additionally, for reasons described below, heliports were also removed from

the regression. The resulting relationship was:

Equation 4: 

LTOs = 1293 + 203*aircraft + 0.0019*county population - 473*Alaska –

144*(AlaskaXaircraft) R2 = 0.65 

When equation 4 was applied to the 6,414 airport facilities that report based 

aircraft data but not LTO activity, the resulting sum of LTOs was almost 15 million. 

EPA estimates that the number of LTOs at the airports that do not report activity data 

should approximate the number of LTOs from the bottom of the distribution of the set of 

airports that report activity data to the 5010 airport data report but that are not in the TAF 

database. The average number of LTOs per year from airports in the bottom 30% of the 

set of airports that report activity data to the 5010 airport data report but that are not in 

the TAF database is ~63 LTOs/year. Multiplying 63 by the number of airports that do 

not report activity data equals 549,050 LTOs.43 Therefore, EPA used equation 4 to 

generate the distribution of LTOs at the individual airports that report based aircraft data 

but not activity data and then applied a scaling factor of 0.0356 to those LTOs to obtain 

the LTOs that are reported in the 2008 NEI.44 The sum of the LTOs from this set of 

airports plus the sum of the LTOs at the airports that do not report either based aircraft or 

activity data (described below in section (b)) sum to 549,050 LTOs. These LTOs are all 

assigned to the GA, piston-engine category since they are assigned to smaller general 

aviation airports that are assumed to have little to no air taxi or jet aircraft activity. 

Equation 4 and the scaling factor were used to estimate LTO activity for the 

2008 NEI at airport facilities that report based aircraft data but not activity data. 

(b) Estimating LTOs at Facilities with Neither Based-Aircraft Data nor LTO Data: 

There are 2,260 facilities (not including heliports) for which the 5010 airport data 

report supplies neither the number of based aircraft nor activity data. In the absence of 

data to establish a relationship to airport activity, we assign a default value of LTOs to 

the GA, piston-engine category for each of these facilities. 

42 From FAA’s website, “Addresses for Commercial Service Airports”, available at: 

http://www.faa.gov/airports_airtraffic/airports/planning_capacity/passenger_allcargo_stats/addresses/media 

/commercial_service_airports_addresses.xls 43 This rounded number is calculated by multiplying 63.298 LTOs/year by 8,674, which is the number of 

airports that don’t report activity data (6,414 don’t report activity data and 2,260 facilities don’t report 

activity or based aircraft data). 

44 The scaling factor was calculated by dividing 528,710 LTOs by 14,862,767 LTOS; the 528,710 LTOs are 

equal to 549,050 LTOs minus 20,340 LTOs (20,340 LTOs represent the sum of LTOs assigned to the 2,260 

facilities that don’t report either activity data or based aircraft data - the derivation of LTO estimates for 

these facilities is described in Section 4 (b)). The 14,862,767 LTOs are the sum of LTOs that result from 

applying equation 4 to the 6,414 facilities with based aircraft data but no activity data. 
B-10 

The default value was determined by evaluating GA LTOs that are reported at the 

set of 2,471 facilities that report activity data to the 5010 airport data report but that are 

not in the TAF set of airports. The average number of LTOs reported to the bottom ten 

percent of these facilities (when sorted by total GA LTOs) was 9. These facilities are 

assumed to most closely approximate the set of 2,260 facilities that do not report any 

based aircraft or LTO data; therefore, we assigned 9 LTOs to the GA, piston-engine 

category for these airport facilities for purposes of developing inventory estimates. 

Section 5. Calculating LTOs at Heliports:

There were 5,559 heliport facilities in the January 15, 2009 FAA 5010 data report 

that were operational. Of those, only 92 (or 2%) reported LTO data, and of those, only 

31 reported both based aircraft and LTO data. Because of the limited information 

regarding activity at heliports, some municipalities have hired contractors to survey 

activity in their local area.45, 46 

The summary statistics for LTO data provided at the 92 operational heliports is 

presented in Table 2. These facilities report a wide range in activity from 3 LTOs/year to 

more than 18,000 LTOs/year. Some facilities clearly have significant helicopter traffic 

(i.e., thousands of LTOs/year) which is supported by the contractor summaries of heliport 

activity in the Washington Metropolitan area. The little data available to us suggests that 

the median helicopter activity is less than 200 LTOs/year. In the absence of more 

information on which to base estimates of LTO activity, we assigned 141 LTOs (the 

median of the reported heliport LTOs) to the GA category at all of the heliports which do 

not report LTO data. The piston-engine fraction developed in Section 6 is applied to the 

141 LTOs resulting in 51 LTOs assigned to the GA, piston-engine category and 90 

assigned to the GA, turbine-engine category. This is an area of significant uncertainty in 

the inventory and one for which EPA is seeking information from local agencies. 

Table 2: Heliport LTO Data for those Reporting LTO Data in the January 15, 2009 

Version of the 5010 Airport Data Report 

18,250 Maximum LTOs

3 Minimum LTOs

1,123 Average LTOs

141 Median LTOs 

50 Mode LTOs 

45 Executive Summary: Regional Helicopter System Plan, Metropolitan Washington Area, prepared by

Edwards and Kelcey for the Metropolitan Washington Council of Governments, 2005. 46 Alaska Aviation Emission Inventory, prepared by Sierra Research, Inc. for Western Regional Air

Partnership, 2005.
B-11 

Section 6. Methodology for Estimating Airport­Specific Lead Emissions

In 2008, EPA developed a method to calculate lead emissions at airports where 

piston-engine powered aircraft operate. 47 This method brings lead inventories into 

alignment with the manner in which other criteria pollutants emitted by aircraft are 

calculated. This method is described here with changes that were made from previous 

methods (i.e., the method used to develop the 2002 inventory) and applied in developing 

airport lead inventories for the 2008 NEI. In this section we first present the equation 

used to calculate lead emitted during the LTO cycle then we describe each of the 

components of the input data: we describe how we calculate piston-engine LTOs from 

data available in FAA databases, we describe the derivation of the emission factor for the 

amount of lead emitted during the LTO cycle, and we describe the estimate of the amount 

of lead retained in the engine and oil that we do not include in the amount of lead 

released to the air. 

Historically, where aircraft specific activity data are available (such as T-100), 

aircraft gaseous and particulate matter (PM) emissions have been calculated through the 

FAA’s EDMS.48 This modeling system was designed to develop emission inventories 

for the purpose of assessing potential air quality impacts of airport operations and 

proposed airport development projects. However, EDMS has a limited number of pistonengine aircraft in its aircraft data and is currently not set up to calculate metal emissions 

and thus, it is not a readily available tool for determining airport lead inventories related 

to aircraft operations. In developing this approach to determine piston-engine aircraft 

lead emissions, EPA relied upon the basic methodology employed in EDMS. This 

requires as input the activity of piston-engine aircraft at a facility, fuel consumption rates 

by these aircraft during the various modes of the LTO cycle and time in each mode 

(taxi/idle-out, takeoff, climb-out, approach, and taxi/idle-in), the concentration of lead in 

the fuel and the retention of lead in the engine and oil. The equation used to calculate 

airport-specific lead emissions during the LTO cycle is below, followed by a description 

of each of the input parameters. 

LTO Pb (tons) = (piston-engine LTO)(avgas Pb g/LTO)(1-Pb retention)

907,180 g/ton 

(a) Calculating Piston-engine LTO: 

Piston-engine LTOs are used to calculate emissions of lead that are assigned to 

the airport facility where the aircraft operations occur. An aircraft operation is defined as 

any landing or takeoff event, therefore, to calculate LTOs, operations are divided by two. 

Most data sources from FAA report aircraft activity in numbers of operations which, for 

the purposes of calculating lead emissions, need to be converted to LTO events. We 

47 U.S. EPA (2008) Lead Emissions from the Use of Leaded Aviation Gasoline in the United States, 

Technical Support Document. EPA420-R-08-020. Available at: www.epa.gov/otaq/aviation.htm. 48 EDMS available from 

http://www.faa.gov/about/office_org/headquarters_offices/aep/models/edms_model/ 
B-12 

describe here the method used to estimate the fraction of GA and AT LTOs at an airport 

that are conducted by piston-engine aircraft. These fractions are calculated separately 

(one fraction for GA and one for AT). These fractions are multiplied by total LTOs 

reported separately for GA and AT and then summed to arrive at the total LTOs 

conducted by piston-engine aircraft at an airport. 

One use of the 2008 NEI is to identify sources of lead, including airports, that 

have inventories of 0.50 tons per year or more for the purposes of identifying locations 

where lead monitoring may be required to evaluate compliance with the National 

Ambient Air Quality Standard for Lead. To calculate the most airport-specific 

inventories for airports that may potentially exceed this inventory threshold, we used a 

more airport-specific surrogate for this subset of airports than the remainder of the 

airports where we applied national default averages described below. 

We used the fraction of based aircraft at an airport that are single- or multi-engine 

to calculate the number of GA LTOs at an airport that were conducted by piston-engine 

aircraft. The data regarding the population of based aircraft at an airport is available for a 

subset of airports in the FAA 5010 master records data report described in Section 3. For 

example, if an airport reports 150 single-engine aircraft, 20 multi-engine aircraft and a 

total of 180 aircraft based at that facility, then the fraction of based aircraft we would use 

as a surrogate for piston-engine aircraft is 94% ((150+20)/180). We then multiply the 

total GA LTOs for that facility by 0.94 to calculate piston-engine LTOs. 

We evaluated this surrogate by comparing the results of using it with pistonengine aircraft operations reported for airports that supply this information in master 

plans, airport layout plans, noise abatement studies and/or land use compatibility plans. 

We could rarely find data from the same year for comparison purposes; however, for the 

majority of airports, based aircraft and actual observed piston-engine aircraft activity 

agreed within ten percent.49

For the majority of airports in the 2008 NEI we used national average fractions of 

GA and AT LTOs conducted by piston-engine aircraft that were derived using FAA’s 

General Aviation and Part 13550 Activity Surveys – CY 2008 (GAATA).51 Table 2.4 in 

the 2008 GAATA Survey reports that approximately sixty-six percent (66%) of all GA 

and AT LTOs are from piston-engine aircraft which use avgas, and about thirty-four 

49 Documents used to evaluate the use of based aircraft include the following:

Airport Master Plan Update Prescott Municipal Airport (Ernest A Love Field) (2009) Available at: 

www.cityofprescott.net/_d/amp_tablecontents.pdf

Gillespie field Airport Layout Plan Update Narrative Report (2005) Available at: www.co.sandiego.ca.us/dpw/airports/powerpoints/pdalp.pdf

Land Use Compatibility Plan for the Grand Forks International Airport (2006) Available at:

www.gfkairport.com/authority/pdf/land_use.pdf

McClellan-Palomar Land Use Compatibility Plan (Amended March 4, 2010) Available at: 

www.ci.oceanside.ca.us/.../McClellan-Palomar_ALUCP_03-4-10_amendment.pdf 50 On-demand (air taxi) and commuter operations not covered by Part 121 51 The FAA GAATA is a database collected from surveys of pilots flying aircraft used for general aviation 

and air taxi activity. For more information on the 2008 GAATA, see Appendix A at 

http://www.faa.gov/data_research/aviation_data_statistics/general_aviation/CY2008/
B-13 

percent (34%) are turboprop and turbojet powered which use jet fuel, such as Jet A. The 

LTO data in Table 2.4 in the 2008 GAATA Survey does not distinguish LTOs as GA or 

AT, and thus does not allow us derive separate piston activity fractions for GA and AT. 

We are using the number of hours flown by piston versus turboprop or turbojet 

aircraft (reported in Table 1.4 in the 2008 GAATA Survey) to allow us to make separate 

estimates of the fraction of GA activity conducted by piston aircraft and the fraction of 

AT activity conducted by piston aircraft. We chose to use the fraction of hours flown by 

piston-engine aircraft as a surrogate to calculate the fraction of LTOs flown by piston 

aircraft since the overall (i.e., for GA and AT combined) piston percent of hours flown 

(66.4%) is very close to the percent of LTOs that are piston (65.7%). Table 1.4 of the 

2008 GAATA presents the total hours flown by aircraft type and separates GA from AT. 

Seventy-three percent (73%) of all GA hours flown are by piston-engine aircraft while 

twenty-eight percent (28%) of all GA hours flown are by turboprop and turbojet powered 

aircraft.52 Twenty-three percent (23%) of all AT hours flown are by piston-engine 

aircraft while seventy-seven percent (77%) of all AT hours flown are by turboprop and 

turbojet powered aircraft. Approximately 5,000 of the total 20,000 airport facilities in the 

U.S. are heliports at which only helicopters (rotocraft) operate. Therefore, EPA also 

calculated the percent of rotocraft hours flown that are conducted by piston-engine 

aircraft. Thirty-six percent (36%) of all GA rotocraft hours flown are by piston-engine 

rotocraft while sixty-four percent (64%) of all GA rotocraft hours flown are by turboprop 

and turbojet powered rotocraft. Two percent (2%) of all AT rotocraft hours flown are by 

piston-engine rotocraft while ninety-eight percent (98%) of all AT rotocraft hours flown 

are by turboprop and turbojet powered rotocraft. Table 3 identifies the piston and turbine 

fractions that were used in the absence of airport-specific information to calculate pistonengine operations at airports and heliports in the 2008 NEI. 

Table 3: Piston and Turbine Activity Fractions used in the 2008 NEI

Airports Heliports 

GA AT GA AT 

Piston 

Powered 72.5% 23.1% 36.1% 2% 

Turbine 

Powered 27.5% 76.9% 63.9% 98% 

52 Numbers in the text may not add to 100% due to rounding; the percentages in Table 3 are the values we 

used to calculate the 2008 NEI. 
B-14 

(b) Calculating the Piston-engine Aircraft Emission Factor: Grams of Lead Emitted per 

LTO: 

Piston-engine aircraft can have either one or two engines. EDMS version 5.0.2 

contains information on the amount of avgas used per LTO for some single and twinengine aircraft. The proportion of piston-engine LTOs conducted by single- versus twinengine aircraft was taken from the FAA’s GAATA Survey for 2008 (90% of LTOs are 

conducted by aircraft having one engine and 10% of LTOs by aircraft having two 

engines).53 Since twin-engine aircraft have higher fuel consumption rates than those with 

single engines, a weighted-average LTO fuel usage rate was calculated to apply to the 

population of piston-engine aircraft as a whole. For the single-engine aircraft, the 

average amount of fuel consumed per LTO was determined from the six types of single 

piston-engine aircraft within EDMS.54 This was calculated by averaging the singleengine EDMS outputs for fuel consumed per LTO using the EDMS scenario property of 

ICAO/USEPA Default - Times in Mode (TIM), with a 16 minute taxi-in/taxi-out time 

according to EPA’s Procedures for Emission Inventory Preparation, Volume IV: Mobile 

Sources, 1992.55 This gives a value of 16.96 pounds of fuel per LTO (lbs/LTO). The 

average single-engine fuel consumption rate was divided by the average density of 

100LL avgas, 6 pounds per gallon (lbs/gal), producing an average fuel usage rate for 

single-engine piston aircraft of 2.83 gallons per LTO (gal/LTO). This same calculation 

was performed for the two twin-engine piston aircraft within EDMS, producing an 

average LTO fuel usage rate for twin-engine piston aircraft of 9.12 gal/LTO. 

Using these single- and twin-engine piston aircraft fuel consumption rates, a 

weighted average fuel usage rate per LTO was computed by multiplying the average fuel 

usage rate for single-engine aircraft (2.83 gal/LTO) by the fleet percentage of singleengine aircraft LTOs (90%). Next, the twin-engine piston aircraft average fuel usage rate 

(9.12 gal/LTO) was multiplied by the fleet percentage of twin-engine aircraft LTOs 

(10%). By summing the results of the single- and twin-engine aircraft usage rates, the 

overall weighted-average fuel usage rate per LTO of 3.46 gal/LTO was obtained. 

To calculate the emission factor, the concentration of lead in fuel is multiplied by 

the fuel consumption per LTO. The maximum lead concentration specified by ASTM for 

100LL is 0.56 grams per liter or 2.12 grams per gallon. This amount of lead is normally 

added to assure that the required lean and rich mixture knock values are achieved. 

Multiplying this lead concentration in avgas by the weighted average fuel usage rate 

produces an overall average value of 7.34 grams of lead per LTO (g Pb/LTO) for pistonengines: 3.46 gal/LTO x 2.12 g Pb/gal = 7.34 g Pb/LTO. 

53 The LTOs from the categories of 1-engine fixed wing piston, piston rotocraft, experimental total, and

light sport were summed to determine the total number of single-engine piston aircraft LTOs. 54 EPA understands that EDMS 5.0.2 has a limited list of piston-engines, but these are currently the best

data available.

55 U.S. EPA, Procedures for Emission Inventory Preparation, Volume IV: Mobile Sources, EPA-450/4- 

81026d (Revised), 1992.
B-15 

(c) Retention of Lead in Engine and Oil (1-Pb Retention): 

Data collected from aircraft piston-engines operating on leaded avgas suggests 

that about 5% of the lead from the fuel is retained in the engine and engine oil.56 Thus 

the emitted fraction is 0.95. This information is used in calculating airport-specific lead 

inventories and will be used to develop future national estimates of lead emitted from the 

consumption of leaded avgas. 

Applying these parameters in the equation above yields the following equation: 

Pb(tons) = (piston-engine LTO) (7.34 g Pb/LTO) (0.95) 

907,180 g/ton 

which simplifies to: 

Pb(tons) = (piston-engine LTO) (7.7 X 10-6) 

Where piston-engine LTO57 = (GA LTO x 0.725) + (AT LTO x 0.231) 

(d) Estimating Lead Emissions from Piston-Engine Helicopters: 

The emission factor for helicopters (g Pb/LTO) was determined in the same 

manner as described above for piston-engine fixed-wing aircraft. The concentration of 

lead in avgas (2.12 g/gal) was multiplied by the weighted average fuel usage rate for four 

types of Robinson helicopter engines.58 This produced an overall average emission 

factor of 6.60 grams of lead per LTO (g Pb/LTO) for piston-engine powered helicopters. 

There are no national databases that provide heliport-specific LTO activity data 

for piston-engine powered helicopters separately from turbine-engine powered 

helicopters. The 2008 FAA GA and Part 135 Activity (GAATA) Survey reports that 

approximately 36% of all GA helicopter hours flown are by piston-engine aircraft which 

use avgas, and about 64% are by turbine-engine powered which use jet fuel (which does 

56 The information used to develop this estimate is from the following references: (a) Todd L. Petersen, 

Petersen Aviation, Inc, Aviation Oil Lead Content Analysis, Report # EPA 1-2008, January 2, 2008, 

available at William J. Hughes Technical Center Technical Reference and Research Library at 

http://actlibrary.tc.faa.gov/ and (b) E-mail from Theo Rindlisbacher of Switzerland Federal Office of Civil 

Aviation to Bryan Manning of U.S. EPA, regarding lead retained in engine, September 28, 2007. 57 This equation for piston-engine LTOs only applies to non-heliport facilities. See the text immediately 

below for equations for calculating piston-engine LTOs and Pb emissions at heliports. 58 This was done using the following 4 engine types in EDMS 5.1: Robinson R22 IO-320-D1AD; Robinson 

R22 IO-360-B; Robinson R22 O-320; Robinson R22 TSIO-360C. The fuel consumption rates were: 

Robinson R22 IO-320-D1AD – 5.546 g Pb/LTO; Robinson R22 IO-360-B – 5.973 g Pb/LTO; Robinson 

R22 O-320 – 6.276 g Pb/LTO; Robinson R22 TSIO-360C – 8.604 g Pb/LTO. 
B-16 

not contain lead).59 The 2008 FAA GAATA Survey reports that approximately 2% of all 

AT helicopter hours flown are by piston-engine aircraft which use avgas, and about 98% 

are by turbine-engine powered rotocraft. We expect the fraction of helicopter activity 

conducted by piston-engines to vary by heliport with some facilities having no pistonengine powered helicopter activity and some hosting mainly or only piston-engine 

powered helicopters. However, in the absence of heliport-specific data, the national 

default estimates of 36% for GA and 2% for AT from the GAATA Survey were used. 

Therefore, to calculate piston-engine aircraft LTO as input for this equation, the 

helicopter GA LTOs were multiplied by 0.36 and helicopter AT LTOs were multiplied by 

0.02. 

Lead emitted at the heliport facility was calculated for the 2008 NEI using either 

the LTO data provided in FAA databases or the estimate LTO activity in the following 

equation (i.e., 141 LTOs): 

Pb(tons) = (piston-engine helicopter LTO) (6.60 g Pb/LTO) (0.95)

907,180 g/ton 

which simplifies to: 

Pb(tons) = (piston-engine helicopter LTO) (6.9 X 10-6) 

Where piston-engine helicopter LTO = (Helicopter GA LTO x 0.36) + (Helicopter AT

LTO x 0.02) 

Section 7. Improving Airport­specific Lead Emissions Estimates

There are refinements to the methods described here that would improve airportspecific inventories, most of which involve acquiring airport- and aircraft-specific input 

data. The following information describes data inputs that could be used to generate 

airport lead inventories tailored to specific airports or otherwise improve the estimates 

using currently available data. State and local authorities might have, or be able to 

collect, better information for some of these key data inputs. 

State and local agencies might have access to airport-specific data that would 

improve the national estimates of lead emissions per LTO. These improvements largely 

involve replacing national average or default values with airport-specific data on the 

activity of piston-engine aircraft. Three key data inputs are: 

59 The FAA GAATA is a database collected from surveys of pilots flying aircraft used for general aviation 

and air taxi activity. For more information on the GAATA, see Appendix A at 

http://www.faa.gov/data_statistics/aviation_data_statistics/general_aviation/
B-17 

1) Airport-specific LTO activity for piston-powered aircraft, including the fraction 

of piston-engine activity conducted by single- versus twin-engine aircraft. Some 

airport facilities collect this information and states may use these data to 

calculate airport-specific lead inventories. The activity data should be current 

and updated on a regular schedule so that the data represents the inventory year 

as closely as possible. 

2) The time spent in each mode of the LTO cycle. EPA uses the EDMS scenario 

property of ICAO/USEPA Default - Times in Mode, with a 16 minute taxiin/taxi-out time according to EPA’s Procedures for Emission Inventory 

Preparation, Volume IV: Mobile Sources, 1992. While some local authorities 

have confirmed that these are the relevant times in mode at their airports for 

piston aircraft, the applicability of these times in mode will vary by airport. EPA 

has learned that one of the important factors in piston aircraft operation that is 

currently not included in the time in mode or emissions estimates is the time and 

fuel consumption during the pre-flight run-up checks conducted by piston-engine 

aircraft prior to takeoff. 

3) Other data inputs for the airport-specific lead inventory calculation for which 

states or local authorities may provide airport-specific information include the 

concentration of lead in the avgas supplied at an airport, and the fraction of lead 

in fuel that is retained in the engine and oil, and aircraft-specific fuel 

consumption rates by the piston-engine aircraft in specific modes of operation. 

The accuracy of the based aircraft data on which equation 4 is modeled can be 

improved. FAA recognizes the need to improve the integrity of the 5010 data report 

based-aircraft counts for all of the GA airports and reliever airports in the NPIAS and is 

currently in the process of improving the data collection and submission methods to 

accomplish this task.60

Section 8. Lead emitted in flight (i.e., outside the LTO cycle):

Lead emissions, especially those at altitude, undergo dispersion and eventually 

deposit to surfaces, and lead deposited to soil and water can remain available for uptake 

by plants, animals and humans for long periods of time. Because lead is a persistent 

pollutant, we are including all lead emissions – at airports and in-flight – in the NEI.61

For inventory purposes, lead emitted outside the LTO cycle occurs during aircraft 

cruise mode and portions of the climb-out and approach modes above the mixing height 

(typically 3,000 ft62 ). This part of an aircraft operation emits lead at various altitudes as 

well as close to and away from airports. Because the precise area of lead emission and 

deposition is not known for these flights, EPA is using a simplistic approach to allocate 

60 National Based Aircraft Inventory Program: 

http://www.basedaircraft.com/public/FrequentlyAskedQuestions.aspx, accessed 2/17/2009 61 U.S. EPA, 2006. Air Quality: Criteria for Lead: 2006; EPA/600/R-5/144aF; U.S. Government Printing

Office, Washington, DC, October, 2006.

62 According to EPA’s Procedurees for Emission Inventory Preparation, Volume IV: Mobile Sources, 1992.
B-18 

these emissions for the purposes of the 2008 NEI. A brief explanation of the nature of 

GA flights is provided here for context regarding emissions of lead in-flight. 

FAA categorizes GA flights as either local area or itinerant operations and this 

distinction plays a role in the area over which lead is emitted. Local operations are those 

activities performed by aircraft operating in the local traffic pattern or within sight of the 

airport, aircraft executing simulated instrument approaches or low passes at the airport, 

and/or aircraft operating to or from the airport in a designated practice area located 

within a 20-mile radius of the airport. Local operations are common for GA aircraft. 

This includes applications such as recreational, proficiency and instructional flying as well 

as many common general aerial support tasks. Emissions during local flying are more 

likely to influence air and soil concentrations of lead in the vicinity of the airport because 

they occur near the airport, often at altitudes below the mixing height. 

Itinerant operations are all operations other than those described above as local 

operations. An itinerant aircraft operation usually is one in which the aircraft departs 

from one airport and lands at a different airport. Depending on air time and distance, an 

itinerant flight is much more likely to involve departing the local flying area of the 

originating airport and climbing to altitudes above the mixing height. It is reasonable 

then, to generally expect that lead emitted outside the LTO cycle during itinerant 

operations, in contrast with local operations, will be more widely dispersed and at greater 

distances from the airport. 

The portion of the national avgas lead emitted in flight (i.e., outside the LTO 

cycle) is calculated by subtracting the sum of airport facility lead inventories from the 

national avgas lead inventory. Even though FAA collects and reports information 

regarding the fraction of GA operations that are local and itinerant, there is no practical 

method to assign in-flight lead emissions to small geographic areas such as airports or 

census tracts. And similar data is not available for AT operations, a portion of which are 

conducted by piston-engine aircraft. Since the average duration of a piston-engine 

aircraft flight is approximately an hour, an itinerant flight can traverse county lines. 

Therefore, given the current data available, the best approach is to assign the out-of-LTO 

cycle lead to the state where the flight originated. 

In the 2008 NEI EPA allocated lead emissions that are calculated as being outside 

the LTO cycle to states based on the state-specific fraction of national GA and AT pistonengine LTO activity. The state-specific fractions were calculated by multiplying the 

percent of GA and AT piston-engine LTO activity in each state by 296 tons, which is the 

amount of lead we currently estimate is emitted outside of the LTO cycle nationwide. 

Table 4 presents the total GA and AT piston-engine LTOs by state, the state-specific 

faction of national GA and AT piston-engine LTO activity, and the out-of-LTO lead 

emissions assigned to each state. 
B-19 

Table 4: Out-of-LTO Lead Emissions by State

STATE 

Total GA 

and AT 

Piston 

LTOs 

Percent of 

National GA 

and AT Piston 

LTOs (by state) 

Out of LTO

Pb emissions

(tons) 

AK 660,133 2.0% 5.86

AL 671,026 2.0% 5.96 

AR 638,875 1.9% 5.68

AZ 1,430,302 4.3% 12.71 

CA 3,881,357 11.6% 34.48

CO 780,426 2.3% 6.93 

CT 226,807 0.7% 2.01 

DC 28,833 0.1% 0.26

DE 84,617 0.3% 0.75 

FL 2,751,015 8.3% 24.44

GA 750,876 2.3% 6.67 

HI 138,432 0.4% 1.23

IA 281,961 0.8% 2.50 

ID 430,812 1.3% 3.83 

IL 920,908 2.8% 8.18

IN 566,583 1.7% 5.03 

KS 459,720 1.4% 4.08

KY 280,378 0.8% 2.49 

LA 622,011 1.9% 5.53

MA 714,159 2.1% 6.34 

MD 436,861 1.3% 3.88 

ME 228,302 0.7% 2.03

MI 880,818 2.6% 7.82 

MN 647,876 1.9% 5.76

MO 389,551 1.2% 3.46 

MS 461,383 1.4% 4.10 

MT 270,311 0.8% 2.40

NC 743,004 2.2% 6.60 

ND 214,139 0.6% 1.90

NE 221,681 0.7% 1.97 

NH 173,355 0.5% 1.54

NJ 466,961 1.4% 4.15 

NM 309,657 0.9% 2.75 

NV 298,712 0.9% 2.65

NY 999,738 3.0% 8.88 

OH 1,180,583 3.5% 10.49

OK 575,402 1.7% 5.11 

OR 596,730 1.8% 5.30

PA 954,839 2.9% 8.48 
B-20 

PR 80,728 0.2% 0.72 

RI 45,348 0.1% 0.40 

SC 506,650 1.5% 4.50

SD 228,198 0.7% 2.03 

TN 535,913 1.6% 4.76 

TX 2,422,722 7.3% 21.52

UT 299,471 0.9% 2.66 

VA 502,559 1.5% 4.46

VI 25,763 0.1% 0.23 

VT 88,318 0.3% 0.78

WA 1,189,142 3.6% 10.56 

WI 778,320 2.3% 6.91 

WV 143,393 0.4% 1.27

WY 106,190 0.3% 0.94 

For additional information or if you have questions regarding the methods described in 

this document, please contact Meredith Pedde (pedde.meredith@epa.gov) or Marion 

Hoyer (hoyer.marion@epa.gov). 
B-21

Supplemental Table 1 

Table A-1: Scaling factors 

Year 

U.S. Product Supplied

of Aviation Gasoline 

(Thousand Barrels)63

Ratio of 

2008 to 

Year X 

Before 

198164 0.57 

1981 11,147 0.50 

1982 9,307 0.60 

1983 9,444 0.59 

1984 8,692 0.64 

1985 9,969 0.56 

1986 11,673 0.48 

1987 9,041 0.62 

1988 9,705 0.58 

1989 9,427 0.59 

1990 8,910 0.63 

1991 8,265 0.68 

1992 8,133 0.69 

1993 7,606 0.74 

1994 7,555 0.74 

1995 7,841 0.71 

1996 7,400 0.76 

1997 7,864 0.71 

1998 7,032 0.80 

1999 7,760 0.72 

2000 7,188 0.78 

2001 6,921 0.81 

2002 6,682 0.84 

2003 5,987 0.94 

2004 6,189 0.91 

2005 7,006 0.80 

2006 6,626 0.85 

2007 6,258 0.90 

2008 5,603 1.00 

63 Data from the Energy Information Administration’s (EIA’s) table, “U.S. Product Supplied of Aviation Gasoline 

(Thousand Barrels).” Available at:

http://tonto.eia.doe.gov/dnav/pet/hist/LeafHandler.ashx?n=PET&s=mgaupus1&f=A Accessed August 25, 2010. 64 EIA does not have data for volumes of avgas product supplied for years earlier than 1981. To calculate the scaling 

factor to use for activity data from years before 1981, we used the ratio of 2008 avgas volume product supplied to the 

average avgas volume supplied from 1981 to 1989.
1 of 11 

Appendix A‐4

 List of St. Louis County and St. Louis City Nonroad Emissions by SCC
2 of 11 

Area SCC 

2008 CO Emissions 

(tons/year) 

St. Louis County 2260001010 201.59 

St. Louis County 2260001020 - 

St. Louis County 2260001030 280.60 

St. Louis County 2260001060 45.48 

St. Louis County 2260002006 75.73 

St. Louis County 2260002009 2.77 

St. Louis County 2260002021 3.34 

St. Louis County 2260002027 0.03 

St. Louis County 2260002039 192.25 

St. Louis County 2260002054 0.68 

St. Louis County 2260003030 1.12 

St. Louis County 2260003040 0.09 

St. Louis County 2260004015 11.16 

St. Louis County 2260004016 110.40 

St. Louis County 2260004020 146.27 

St. Louis County 2260004021 2,070.88 

St. Louis County 2260004025 191.31 

St. Louis County 2260004026 1,139.14 

St. Louis County 2260004030 128.59 

St. Louis County 2260004031 1,279.60 

St. Louis County 2260004035 147.00 

St. Louis County 2260004036 747.30 

St. Louis County 2260004071 0.46 

St. Louis County 2260005035 0.07 

St. Louis County 2260006005 29.35 

St. Louis County 2260006010 193.41 

St. Louis County 2260006015 0.08 

St. Louis County 2260006035 1.28 

St. Louis County 2260007005 7.68 

St. Louis County 2265001010 85.85 

St. Louis County 2265001030 885.66 

St. Louis County 2265001050 942.36 

St. Louis County 2265001060 55.59 

St. Louis County 2265002003 43.36 

St. Louis County 2265002006 0.38 

St. Louis County 2265002009 105.79 

St. Louis County 2265002015 76.49 

St. Louis County 2265002021 185.89 

St. Louis County 2265002024 68.91 

St. Louis County 2265002027 3.51 

St. Louis County 2265002030 130.92 

St. Louis County 2265002033 56.94 

St. Louis County 2265002039 299.14 

St. Louis County 2265002042 194.85 

St. Louis County 2265002045 7.18 
3 of 11 

Area SCC 

2008 CO Emissions 

(tons/year) 

St. Louis County 2265002054 19.22 

St. Louis County 2265002057 9.27 

St. Louis County 2265002060 19.45 

St. Louis County 2265002066 100.33 

St. Louis County 2265002072 53.81 

St. Louis County 2265002078 29.74 

St. Louis County 2265002081 8.90 

St. Louis County 2265003010 118.36 

St. Louis County 2265003020 253.53 

St. Louis County 2265003030 77.92 

St. Louis County 2265003040 188.58 

St. Louis County 2265003050 8.50 

St. Louis County 2265003060 4.43 

St. Louis County 2265003070 13.89 

St. Louis County 2265004010 3,203.78 

St. Louis County 2265004011 4,790.28 

St. Louis County 2265004015 269.26 

St. Louis County 2265004016 2,783.47 

St. Louis County 2265004025 17.54 

St. Louis County 2265004026 106.24 

St. Louis County 2265004030 33.52 

St. Louis County 2265004031 3,522.30 

St. Louis County 2265004035 384.09 

St. Louis County 2265004036 1,952.52 

St. Louis County 2265004040 522.88 

St. Louis County 2265004041 448.08 

St. Louis County 2265004046 639.08 

St. Louis County 2265004051 323.11 

St. Louis County 2265004055 6,970.00 

St. Louis County 2265004056 6,088.28 

St. Louis County 2265004066 762.57 

St. Louis County 2265004071 19,082.16 

St. Louis County 2265004075 304.00 

St. Louis County 2265004076 821.05 

St. Louis County 2265005010 0.25 

St. Louis County 2265005015 0.54 

St. Louis County 2265005020 0.00 

St. Louis County 2265005025 0.36 

St. Louis County 2265005030 0.24 

St. Louis County 2265005035 2.48 

St. Louis County 2265005040 7.00 

St. Louis County 2265005045 0.57 

St. Louis County 2265005055 1.08 

St. Louis County 2265005060 0.68 

St. Louis County 2265006005 9,140.97 
4 of 11 

Area SCC 

2008 CO Emissions 

(tons/year) 

St. Louis County 2265006010 1,856.31 

St. Louis County 2265006015 809.73 

St. Louis County 2265006025 2,066.08 

St. Louis County 2265006030 3,894.54 

St. Louis County 2265006035 158.28 

St. Louis County 2265007010 15.73 

St. Louis County 2265007015 0.13 

St. Louis County 2265008005 76.64 

St. Louis County 2265010010 33.50 

St. Louis County 2267001060 0.56 

St. Louis County 2267002003 1.67 

St. Louis County 2267002015 2.52 

St. Louis County 2267002021 0.48 

St. Louis County 2267002024 0.28 

St. Louis County 2267002030 5.19 

St. Louis County 2267002033 1.92 

St. Louis County 2267002039 3.86 

St. Louis County 2267002045 1.97 

St. Louis County 2267002054 0.33 

St. Louis County 2267002057 3.43 

St. Louis County 2267002060 8.06 

St. Louis County 2267002066 0.82 

St. Louis County 2267002072 7.20 

St. Louis County 2267002081 2.99 

St. Louis County 2267003010 39.88 

St. Louis County 2267003020 3,400.08 

St. Louis County 2267003030 22.91 

St. Louis County 2267003040 7.49 

St. Louis County 2267003050 2.14 

St. Louis County 2267003070 12.77 

St. Louis County 2267004066 63.21 

St. Louis County 2267005055 0.00 

St. Louis County 2267005060 0.00 

St. Louis County 2267006005 130.87 

St. Louis County 2267006010 29.26 

St. Louis County 2267006015 34.31 

St. Louis County 2267006025 61.57 

St. Louis County 2267006030 0.84 

St. Louis County 2267006035 0.51 

St. Louis County 2267008005 20.76 

St. Louis County 2268002081 0.12 

St. Louis County 2268003020 242.20 

St. Louis County 2268003030 0.26 

St. Louis County 2268003040 0.18 

St. Louis County 2268003060 0.43 
5 of 11 

Area SCC 

2008 CO Emissions 

(tons/year) 

St. Louis County 2268003070 0.94 

St. Louis County 2268005055 0.00 

St. Louis County 2268005060 0.03 

St. Louis County 2268006005 39.53 

St. Louis County 2268006010 1.96 

St. Louis County 2268006015 2.65 

St. Louis County 2268006020 18.62 

St. Louis County 2268006035 - 

St. Louis County 2268010010 2.04 

St. Louis County 2270001060 1.62 

St. Louis County 2270002003 14.60 

St. Louis County 2270002006 0.05 

St. Louis County 2270002009 0.78 

St. Louis County 2270002015 43.32 

St. Louis County 2270002018 39.51 

St. Louis County 2270002021 2.77 

St. Louis County 2270002024 2.21 

St. Louis County 2270002027 5.68 

St. Louis County 2270002030 27.41 

St. Louis County 2270002033 17.40 

St. Louis County 2270002036 119.52 

St. Louis County 2270002039 2.07 

St. Louis County 2270002042 0.87 

St. Louis County 2270002045 21.91 

St. Louis County 2270002048 26.57 

St. Louis County 2270002051 99.30 

St. Louis County 2270002054 5.27 

St. Louis County 2270002057 69.69 

St. Louis County 2270002060 166.51 

St. Louis County 2270002066 252.07 

St. Louis County 2270002069 140.57 

St. Louis County 2270002072 219.31 

St. Louis County 2270002075 20.22 

St. Louis County 2270002078 0.66 

St. Louis County 2270002081 20.70 

St. Louis County 2270003010 10.87 

St. Louis County 2270003020 67.13 

St. Louis County 2270003030 15.90 

St. Louis County 2270003040 17.36 

St. Louis County 2270003050 1.88 

St. Louis County 2270003060 68.10 

St. Louis County 2270003070 24.84 

St. Louis County 2270004031 0.01 

St. Louis County 2270004036 1.36 

St. Louis County 2270004046 49.81 
6 of 11 

Area SCC 

2008 CO Emissions 

(tons/year) 

St. Louis County 2270004056 10.48 

St. Louis County 2270004066 57.34 

St. Louis County 2270004071 4.94 

St. Louis County 2270004076 0.20 

St. Louis County 2270005010 0.00 

St. Louis County 2270005015 12.01 

St. Louis County 2270005020 0.90 

St. Louis County 2270005025 0.01 

St. Louis County 2270005030 0.00 

St. Louis County 2270005035 0.09 

St. Louis County 2270005040 0.00 

St. Louis County 2270005045 0.10 

St. Louis County 2270005055 0.25 

St. Louis County 2270005060 0.12 

St. Louis County 2270006005 91.88 

St. Louis County 2270006010 21.71 

St. Louis County 2270006015 47.20 

St. Louis County 2270006020 - 

St. Louis County 2270006025 72.41 

St. Louis County 2270006030 2.74 

St. Louis County 2270006035 2.06 

St. Louis County 2270007010 - 

St. Louis County 2270007015 1.56 

St. Louis County 2270008005 85.78 

St. Louis County 2270009010 - 

St. Louis County 2270010010 0.95 

St. Louis County 2282005010 562.87 

St. Louis County 2282005015 241.18 

St. Louis County 2282010005 386.17 

St. Louis County 2282020005 3.66 

St. Louis County 2282020010 0.04 

St. Louis County 2285002015 2.33 

St. Louis County 2285004015 4.47 

St. Louis County 2285006015 0.03 

St. Louis County Total 89,513.99 

St. Louis City 2260001010 - 

St. Louis City 2260001020 - 

St. Louis City 2260001030 - 

St. Louis City 2260001060 - 

St. Louis City 2260002006 - 

St. Louis City 2260002009 - 

St. Louis City 2260002021 - 

St. Louis City 2260002027 - 

St. Louis City 2260002039 - 

St. Louis City 2260002054 - 
7 of 11 

Area SCC 

2008 CO Emissions 

(tons/year) 

St. Louis City 2260003030 0.50 

St. Louis City 2260003040 0.04 

St. Louis City 2260004015 4.55 

St. Louis City 2260004016 5.92 

St. Louis City 2260004020 59.63 

St. Louis City 2260004021 111.05 

St. Louis City 2260004025 78.00 

St. Louis City 2260004026 61.08 

St. Louis City 2260004030 52.43 

St. Louis City 2260004031 68.62 

St. Louis City 2260004035 59.93 

St. Louis City 2260004036 40.07 

St. Louis City 2260004071 0.02 

St. Louis City 2260005035 - 

St. Louis City 2260006005 10.22 

St. Louis City 2260006010 67.33 

St. Louis City 2260006015 0.03 

St. Louis City 2260006035 0.45 

St. Louis City 2260007005 - 

St. Louis City 2265001010 - 

St. Louis City 2265001030 - 

St. Louis City 2265001050 118.00 

St. Louis City 2265001060 - 

St. Louis City 2265002003 - 

St. Louis City 2265002006 - 

St. Louis City 2265002009 - 

St. Louis City 2265002015 - 

St. Louis City 2265002021 - 

St. Louis City 2265002024 - 

St. Louis City 2265002027 - 

St. Louis City 2265002030 - 

St. Louis City 2265002033 - 

St. Louis City 2265002039 - 

St. Louis City 2265002042 - 

St. Louis City 2265002045 - 

St. Louis City 2265002054 - 

St. Louis City 2265002057 - 

St. Louis City 2265002060 - 

St. Louis City 2265002066 - 

St. Louis City 2265002072 - 

St. Louis City 2265002078 - 

St. Louis City 2265002081 - 

St. Louis City 2265003010 52.70 

St. Louis City 2265003020 112.89 

St. Louis City 2265003030 34.70 
8 of 11 

Area SCC 

2008 CO Emissions 

(tons/year) 

St. Louis City 2265003040 83.97 

St. Louis City 2265003050 3.79 

St. Louis City 2265003060 1.52 

St. Louis City 2265003070 6.18 

St. Louis City 2265004010 1,308.59 

St. Louis City 2265004011 257.34 

St. Louis City 2265004015 109.98 

St. Louis City 2265004016 149.53 

St. Louis City 2265004025 7.17 

St. Louis City 2265004026 5.71 

St. Louis City 2265004030 13.69 

St. Louis City 2265004031 189.22 

St. Louis City 2265004035 156.74 

St. Louis City 2265004036 104.80 

St. Louis City 2265004040 213.57 

St. Louis City 2265004041 24.07 

St. Louis City 2265004046 34.33 

St. Louis City 2265004051 17.36 

St. Louis City 2265004055 2,846.91 

St. Louis City 2265004056 327.07 

St. Louis City 2265004066 40.97 

St. Louis City 2265004071 1,025.13 

St. Louis City 2265004075 124.17 

St. Louis City 2265004076 44.11 

St. Louis City 2265005010 - 

St. Louis City 2265005015 - 

St. Louis City 2265005020 - 

St. Louis City 2265005025 - 

St. Louis City 2265005030 - 

St. Louis City 2265005035 - 

St. Louis City 2265005040 - 

St. Louis City 2265005045 - 

St. Louis City 2265005055 - 

St. Louis City 2265005060 - 

St. Louis City 2265006005 3,186.44 

St. Louis City 2265006010 647.09 

St. Louis City 2265006015 282.26 

St. Louis City 2265006025 720.21 

St. Louis City 2265006030 1,357.59 

St. Louis City 2265006035 55.18 

St. Louis City 2265007010 - 

St. Louis City 2265007015 - 

St. Louis City 2265008005 - 

St. Louis City 2265010010 - 

St. Louis City 2267001060 - 
9 of 11 

Area SCC 

2008 CO Emissions 

(tons/year) 

St. Louis City 2267002003 - 

St. Louis City 2267002015 - 

St. Louis City 2267002021 - 

St. Louis City 2267002024 - 

St. Louis City 2267002030 - 

St. Louis City 2267002033 - 

St. Louis City 2267002039 - 

St. Louis City 2267002045 - 

St. Louis City 2267002054 - 

St. Louis City 2267002057 - 

St. Louis City 2267002060 - 

St. Louis City 2267002066 - 

St. Louis City 2267002072 - 

St. Louis City 2267002081 - 

St. Louis City 2267003010 17.73 

St. Louis City 2267003020 1,511.71 

St. Louis City 2267003030 10.19 

St. Louis City 2267003040 3.33 

St. Louis City 2267003050 0.95 

St. Louis City 2267003070 5.68 

St. Louis City 2267004066 3.39 

St. Louis City 2267005055 - 

St. Louis City 2267005060 - 

St. Louis City 2267006005 45.56 

St. Louis City 2267006010 10.19 

St. Louis City 2267006015 11.94 

St. Louis City 2267006025 21.43 

St. Louis City 2267006030 0.29 

St. Louis City 2267006035 0.18 

St. Louis City 2267008005 - 

St. Louis City 2268002081 - 

St. Louis City 2268003020 107.69 

St. Louis City 2268003030 0.12 

St. Louis City 2268003040 0.08 

St. Louis City 2268003060 0.15 

St. Louis City 2268003070 0.42 

St. Louis City 2268005055 - 

St. Louis City 2268005060 - 

St. Louis City 2268006005 13.76 

St. Louis City 2268006010 0.68 

St. Louis City 2268006015 0.92 

St. Louis City 2268006020 6.48 

St. Louis City 2268006035 - 

St. Louis City 2268010010 - 

St. Louis City 2270001060 - 
10 of 11 

Area SCC 

2008 CO Emissions 

(tons/year) 

St. Louis City 2270002003 - 

St. Louis City 2270002006 - 

St. Louis City 2270002009 - 

St. Louis City 2270002015 - 

St. Louis City 2270002018 - 

St. Louis City 2270002021 - 

St. Louis City 2270002024 - 

St. Louis City 2270002027 - 

St. Louis City 2270002030 - 

St. Louis City 2270002033 - 

St. Louis City 2270002036 - 

St. Louis City 2270002039 - 

St. Louis City 2270002042 - 

St. Louis City 2270002045 - 

St. Louis City 2270002048 - 

St. Louis City 2270002051 - 

St. Louis City 2270002054 - 

St. Louis City 2270002057 - 

St. Louis City 2270002060 - 

St. Louis City 2270002066 - 

St. Louis City 2270002069 - 

St. Louis City 2270002072 - 

St. Louis City 2270002075 - 

St. Louis City 2270002078 - 

St. Louis City 2270002081 - 

St. Louis City 2270003010 4.83 

St. Louis City 2270003020 29.84 

St. Louis City 2270003030 7.07 

St. Louis City 2270003040 7.72 

St. Louis City 2270003050 0.83 

St. Louis City 2270003060 23.30 

St. Louis City 2270003070 11.05 

St. Louis City 2270004031 0.00 

St. Louis City 2270004036 0.07 

St. Louis City 2270004046 2.67 

St. Louis City 2270004056 0.56 

St. Louis City 2270004066 3.07 

St. Louis City 2270004071 0.26 

St. Louis City 2270004076 0.01 

St. Louis City 2270005010 - 

St. Louis City 2270005015 - 

St. Louis City 2270005020 - 

St. Louis City 2270005025 - 

St. Louis City 2270005030 - 

St. Louis City 2270005035 - 
11 of 11 

Area SCC 

2008 CO Emissions 

(tons/year) 

St. Louis City 2270005040 - 

St. Louis City 2270005045 - 

St. Louis City 2270005055 - 

St. Louis City 2270005060 - 

St. Louis City 2270006005 31.98 

St. Louis City 2270006010 7.56 

St. Louis City 2270006015 16.43 

St. Louis City 2270006020 - 

St. Louis City 2270006025 25.21 

St. Louis City 2270006030 0.95 

St. Louis City 2270006035 0.72 

St. Louis City 2270007010 - 

St. Louis City 2270007015 - 

St. Louis City 2270008005 - 

St. Louis City 2270009010 - 

St. Louis City 2270010010 - 

St. Louis City 2282005010 151.01 

St. Louis City 2282005015 64.71 

St. Louis City 2282010005 103.83 

St. Louis City 2282020005 0.98 

St. Louis City 2282020010 0.01 

St. Louis City 2285002015 2.12 

St. Louis City 2285004015 4.07 

St. Louis City 2285006015 0.03 

St. Louis City Total 16,556.63 

Combined Total for St. Louis County and St. Louis City 106,070.62 
1 of 53 

Appendix A-5 

Nonpoint Industrial and Commercial/Institutional (ICI) Fuel Combustion Category 

Documentation 
2 of 53 

AREA COMBUSTION SOURCE EMISSIONS INVENTORY 

IMPROVEMENT METHODOLOGY

TECHNICAL MEMORANDUM

Contract No. 07-0901-RPO-036 

March 20, 2009 

Prepared for: 

Kathy Pendleton 

Texas Commission on Environmental Quality 

MC-164 

P.O. Box 13087 

Austin, TX 78711-3087 

Annette Sharp 

Central Regional Air Planning Association 

10005 S. Pennsylvania, Suite C 

Oklahoma City, OK 73159 

Prepared by: 

E.H. Pechan & Associates, Inc. 

3622 Lyckan Parkway, Suite 2005 

Durham, NC 27707 
ii of 53

CONTENTS 

Page 

A. INTRODUCTION ....................................................................................................................... 1 

B. METHODOLOGY ....................................................................................................................... 1 

1. Total ICI Energy Consumption ............................................................................................... 3 

2. Non-Fuel Energy Consumption .............................................................................................. 3 

3. Nonroad Source Energy Consumption .................................................................................... 4 

4. Point Source Energy Consumption ....................................................................................... 11 

5. Emission Factors ................................................................................................................. 23 

6. Coal Sulfur Content ............................................................................................................. 25 

7. County Allocation Data ....................................................................................................... 26 

8. Temporal Allocation Data .................................................................................................... 32 

C. CALCULATION TEMPLATES ................................................................................................. 34 

D. REFERENCES .......................................................................................................................... 35 

ATTACHMENT: PRELIMINARY SUMMARY OF 2002 POINT SOURCE ANNUAL 

THROUGHPUT DATA ................................................................................................................... 37 

TABLES

Table 1. ICI Combustion Area Source Classification Codes ................................................................. 2 

Table 2. Industrial Sector Energy Consumption from Non-Fuel Uses ................................................... 4 

Table 3. Nonroad Sector Subtraction SCCs ........................................................................................ 5 

Table 4. Industrial Fuel Combustion Crosswalk for Point Source Subtractions .................................... 12 

Table 5. Commercial/Institutional Fuel Combustion Crosswalk for Point Source Subtractions ............. 20 

Table 6. Criteria Pollutant Emission Factors for ICI Combustion Area Source Categories ................... 24 

Table 7. Carbon Dioxide Emission Factors for Industrial and Commercial/Institutional Coal Combustion 

(lb/MMBtu) .................................................................................................................................... 25 

Table 8. Additional Greenhouse Gas Emission Factors for ICI Combustion Area Source Categories 

(lb/MMBtu) .................................................................................................................................... 25 

Table 9. Comparison of County Allocation Approaches for Missouri ................................................. 30 

Table 10. EPA Default Commercial Fuel Combustion Sector Allocation ............................................ 33 
1 of 53

A. INTRODUCTION 

The objective of this project is to estimate area source emissions from Industrial and 

Commercial/Institutional (ICI) fuel combustion for the CENRAP region, which encompasses the 

States and tribal areas of Arkansas, Iowa, Kansas, Louisiana, Minnesota, Missouri, Nebraska, 

Oklahoma, and Texas. This project will result in the development of a set of revised 2002 ICI 

area source emission inventories for sulfur dioxide (SO2), nitrogen oxides (NOx), non-methane 

volatile organic compounds (VOCs), particulate matter (specifically, PM10 and primary/direct 

PM2.5), ammonia (NH3), carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O). The 

emission inventories will be developed at the county level and will provide emissions for the 

following time periods: annual; monthly; and average weekly, weekday, and weekend day 

emissions for each month. 

This technical memorandum is one of two components for documenting the methodology that 

E.H. Pechan & Associates, Inc. (Pechan) will follow in preparing CENRAP’s 2002 ICI area 

source emissions inventory. The second component is a set of Microsoft® Excel workbook 

templates that Pechan will use to implement the methodology described in this document. This 

memorandum is organized into four sections: this section (Introduction), Section B 

(Methodology) , which describes the emission estimation methodology, Section C (Calculation 

Templates), which summarizes the content of the calculation templates, and Section D 

(References), which identifies the information sources that were consulted in preparing this 

document. 

B. METHODOLOGY 

This section documents the emission inventory development methodology that Pechan will use 

to prepare an ICI combustion area source emission inventory for the CENRAP States. Table 1 

identifies the source classification codes (SCCs) for which Pechan plans to prepare ICI 

combustion area source emission estimates. It is important to note that some of these SCCs may 

not ultimately appear in each CENRAP State’s inventory. If it is determined that all of an 

individual State’s consumption of a particular fuel is already accounted for in the State’s nonroad 

and/or point source inventory, then the SCC for that fuel will not be included in the area source 

inventory for that State. 

The key data inputs in the emissions estimation methodology are: 

1. Total Industrial and total Commercial/Institutional energy consumption by fuel type and 

CENRAP State for the year 2002; 

2. Industrial energy consumption used for non-fuel purposes by fuel type and State in 2002; 

3. ICI distillate fuel and liquefied petroleum gas (LPG) consumption for nonroad sources by 

State in year 2002; 

4. ICI energy consumption by fuel type for point sources by CENRAP State in year 2002; 

5. Emission factors relating emission rates to volume of energy consumed by fuel type for 

the ICI sectors; 

6. Sulfur content of coal consumed in the ICI sectors by State in year 2002; 
Table 1. ICI Combustion Area Source Classification Codes 

SCC DESCRIPTION 2102001000 Stationary Source Fuel Combustion; Industrial; Anthracite Coal; Total: All Boiler Types 2102002000 Stationary Source Fuel Combustion; Industrial; Bituminous/Subbituminous Coal; Total: All Boiler Types 2102004000 Stationary Source Fuel Combustion; Industrial; Distillate Oil; Total: Boilers and IC Engines 2102005000 Stationary Source Fuel Combustion; Industrial; Residual Oil; Total: All Boiler Types 2102006000 Stationary Source Fuel Combustion; Industrial; Natural Gas; Total: Boilers and IC Engines 2102007000 Stationary Source Fuel Combustion; Industrial; Liquid Petroleum Gas; Total: All Boiler Types 2102008000 Stationary Source Fuel Combustion; Industrial; Wood; Total: All Boiler Types 2102011000 Stationary Source Fuel Combustion; Industrial; Kerosene; Total: All Boiler Types 2103001000 Stationary Source Fuel Combustion; Commercial/Institutional; Anthracite Coal; Total: All Boiler Types 2103002000 Stationary Source Fuel Combustion; Commercial/Institutional; Bituminous/Subbituminous Coal; Total: All Bo2103004000 Stationary Source Fuel Combustion; Commercial/Institutional; Distillate Oil; Total: Boilers and IC Engines 2103005000 Stationary Source Fuel Combustion; Commercial/Institutional; Residual Oil; Total: All Boiler Types 2103006000 Stationary Source Fuel Combustion; Commercial/Institutional; Natural Gas; Total: Boilers and IC Engines 2103007000 Stationary Source Fuel Combustion; Commercial/Institutional; Liquid Petroleum Gas; Total: All Combustor T2103008000 Stationary Source Fuel Combustion; Commercial/Institutional; Wood; Total: All Boiler Types 2103011000 Stationary Source Fuel Combustion; Commercial/Institutional; Kerosene; Total: All Combustor Types 
3 of 53

7. County-level employment in the ICI sectors by State for the year 2002; and 

8. Temporal allocation data for estimating the proportion of annual fuel combusted by 

month, as well as data for estimating the volume of fuel combusted in each month for the 

following time-frames: average week, average week day; and average weekend day. 

The following sections describe the methodology/data source(s) for developing each of these 

data inputs. The following identifies the planned source(s) of information for each of these data 

elements. In selecting the information sources for each of these data elements, Pechan evaluated 

the representativeness and level of confidence criteria identified in the Quality Assurance Project 

Plan (QAPP) for this project. For example, information sources that provide data specific to the 

source category/geography/inventory period were selected over those that are less specific. 

1. Total ICI Energy Consumption 

For total Industrial and total Commercial/Institutional energy consumption by fuel type/State, 

Pechan will use the same source that EPA uses in developing ICI combustion emission estimates 

for the National Emissions Inventory (NEI) – the Energy Information Administration (EIA)’s 

State Energy Data System (SEDS) (EIA, 2009a). The SEDS reports total energy consumption 

estimates by sector, State, fuel type, and year. To facilitate use with the criteria pollutant and 

GHG emission factors, Pechan will compile the SEDS energy consumption data in both sets of 

units provided by the SEDS: physical units and British thermal units (Btus). 

2. Non-Fuel Energy Consumption 

Some Industrial sector energy is consumed for non-fuel purposes. For example, natural gas is 

used as a feedstock in chemical manufacturing plants and to make nitrogenous fertilizer, and 

LPG is used to create intermediate products that are made into plastics. To estimate the volume 

of fuel that is associated with ICI combustion, it is necessary to subtract the volume of fuel 

consumption for non-energy uses from the volume of total fuel consumption. The EPA’s State 

Inventory Tool (SIT) provides national defaults representing the percentage of total Industrial 

fuel consumption from non-energy uses.1

 These default values have an additional limitation 

beyond their lack of geographic detail - they represent the EIA’s definition of the Industrial 

sector, which includes fuel use that is accounted for in other inventory source categories. In 

particular, the EIA Industrial sector includes fuel consumption from Farm, Mining, Construction, 

and Commercial sectors that is accounted for in the nonroad inventory. Because of these 

limitations, Pechan plans to use regional non-fuel use percentages computed from energy 

consumption data from the EIA’s 2002 Manufacturing Energy Consumption Survey (MECS) for 

all fuel types except coal (EIA, 2007). There are two reasons why MECS provides a more 

representative data set for use in this study: (1) MECS provides data specific to the regions of 

interest; and (2) MECS focuses solely on the Manufacturing sector. The latter characteristic is 

particularly important for fuel types which consume significant amounts of non-Manufacturing 

sector energy that is already included elsewhere (e.g., distillate fuel used by the Construction 

sector, which is included in the nonroad inventory). The MECS non-fuel consumption data treat 

 

1

 Although the SIT also develops CO2 emission estimates associated with non-fuel energy use, such estimates are 

not developed here because they are not associated with industrial fuel combustion. 
4 of 53

coal that is used to produce coke as a feedstock. However, available data indicate that none of 

the CENRAP States produce coke (Pechan, 2006). In addition, the 2002 MECS data treat 

“synthetic coal” that is ultimately combusted as regular coal, as a non-fuel (feedstock) use. 

Because of these data limitations, Pechan contacted EIA for assistance in obtaining a reasonable 

estimate of the percentage of non-coking coal that is used for non-fuel purposes (treating 

“synthetic coal” as a fuel use). Based on the EIA’s estimate that 5-10 percent of 2002 non-coke 

coal was used for non-fuel purposes, Pechan plans to assume that 7 percent of CENRAP 

Industrial sector coal consumption is for non-fuel purposes (Lorenz, 2009). 

Table 2 presents the available non-fuel use percentages by type of energy. It was not possible to 

develop percentages by region for each fuel type because some regional MECS data are 

withheld. For this study, Pechan plans to use the most geographic-specific data reported in Table 

2. States are encouraged to provide available State-specific estimates to replace the defaults 

below. 

Table 2. Industrial Sector Energy Consumption from Non-Fuel Uses 

Energy Type 

2002 MECS % Energy Consumption from Non-Fuel Use 

Midwest South Midwest+South National 

Residual not available not available 25% 17% 

Distillate not available not available 9% 7% 

Natural Gas 6% 15% 12% 10% 

LPG/NGL 88% 98% 97% 97% 

Coal not available not available not available 7% 

Sources: EIA, 2007 and Lorenz, 2009. 

 Midwest region includes Iowa, Kansas, Minnesota, Missouri, and Nebraska. 

South region includes Arkansas, Louisiana, Oklahoma, and Texas. 

3. Nonroad Source Energy Consumption 

To avoid double-counting with the nonroad inventory, it is necessary to subtract 2002 year diesel 

and LPG consumption estimates for Industrial, Farm, Logging, Mining, and Construction sector 

nonroad equipment. For the Commercial sector SEDS data, it is necessary to subtract 2002 year 

diesel and LPG consumption for Commercial sector nonroad equipment. Pechan plans to run the 

NONROAD model for 2002 for the CENRAP States to obtain State-level diesel and LPG 

consumption estimates to perform these subtractions. Table 3 identifies the SCCs for which 

Pechan will compile NONROAD fuel consumption estimates. 
Table 3. Nonroad Sector Subtraction SCCs 

SCC Description_2 Description_3 Description_4 

Industrial Sector-Distillate 

2270000000 Off-highway Vehicle Diesel Compression Ignition Equipment except Rail and Marine Total 2270001000 Off-highway Vehicle Diesel Recreational Equipment Total 2270001010 Off-highway Vehicle Diesel Recreational Equipment Motorcycles: Off-road 2270001020 Off-highway Vehicle Diesel Recreational Equipment Snowmobiles 2270001030 Off-highway Vehicle Diesel Recreational Equipment All Terrain Vehicles 2270001040 Off-highway Vehicle Diesel Recreational Equipment Minibikes 2270001050 Off-highway Vehicle Diesel Recreational Equipment Golf Carts 2270001060 Off-highway Vehicle Diesel Recreational Equipment Specialty Vehicles/Carts 2270002000 Off-highway Vehicle Diesel Construction and Mining Equipment Total 2270002003 Off-highway Vehicle Diesel Construction and Mining Equipment Pavers 2270002006 Off-highway Vehicle Diesel Construction and Mining Equipment Tampers/Rammers 2270002009 Off-highway Vehicle Diesel Construction and Mining Equipment Plate Compactors 2270002012 Off-highway Vehicle Diesel Construction and Mining Equipment Concrete Pavers 2270002015 Off-highway Vehicle Diesel Construction and Mining Equipment Rollers 2270002018 Off-highway Vehicle Diesel Construction and Mining Equipment Scrapers 2270002021 Off-highway Vehicle Diesel Construction and Mining Equipment Paving Equipment 2270002024 Off-highway Vehicle Diesel Construction and Mining Equipment Surfacing Equipment 2270002027 Off-highway Vehicle Diesel Construction and Mining Equipment Signal Boards/Light Plants 2270002030 Off-highway Vehicle Diesel Construction and Mining Equipment Trenchers 2270002033 Off-highway Vehicle Diesel Construction and Mining Equipment Bore/Drill Rigs 2270002036 Off-highway Vehicle Diesel Construction and Mining Equipment Excavators 2270002039 Off-highway Vehicle Diesel Construction and Mining Equipment Concrete/Industrial Saws 2270002042 Off-highway Vehicle Diesel Construction and Mining Equipment Cement and Mortar Mixers 2270002045 Off-highway Vehicle Diesel Construction and Mining Equipment Cranes 2270002048 Off-highway Vehicle Diesel Construction and Mining Equipment Graders 
SCC Description_2 Description_3 Description_4 

2270002051 Off-highway Vehicle Diesel Construction and Mining Equipment Off-Highway Trucks 2270002054 Off-highway Vehicle Diesel Construction and Mining Equipment Crushing/Processing Equip2270002057 Off-highway Vehicle Diesel Construction and Mining Equipment Rough Terrain Forklifts 2270002060 Off-highway Vehicle Diesel Construction and Mining Equipment Rubber Tired Loaders 2270002063 Off-highway Vehicle Diesel Construction and Mining Equipment Rubber Tire Tractor/Dozer2270002066 Off-highway Vehicle Diesel Construction and Mining Equipment Tractors/Loaders/Backhoe2270002069 Off-highway Vehicle Diesel Construction and Mining Equipment Crawler Tractor/Dozers 2270002072 Off-highway Vehicle Diesel Construction and Mining Equipment Skid Steer Loaders 2270002075 Off-highway Vehicle Diesel Construction and Mining Equipment Off-Highway Tractors 2270002078 Off-highway Vehicle Diesel Construction and Mining Equipment Dumpers/Tenders 2270002081 Off-highway Vehicle Diesel Construction and Mining Equipment Other Construction Equipm2270003000 Off-highway Vehicle Diesel Industrial Equipment Total 2270003010 Off-highway Vehicle Diesel Industrial Equipment Aerial Lifts 2270003020 Off-highway Vehicle Diesel Industrial Equipment Forklifts 2270003030 Off-highway Vehicle Diesel Industrial Equipment Sweepers/Scrubbers 2270003040 Off-highway Vehicle Diesel Industrial Equipment Other General Industrial E2270003050 Off-highway Vehicle Diesel Industrial Equipment Other Material Handling Eq2270003060 Off-highway Vehicle Diesel Industrial Equipment AC/Refrigeration 2270003070 Off-highway Vehicle Diesel Industrial Equipment Terminal Tractors 2270005000 Off-highway Vehicle Diesel Agricultural Equipment Total 2270005010 Off-highway Vehicle Diesel Agricultural Equipment 2-Wheel Tractors 2270005015 Off-highway Vehicle Diesel Agricultural Equipment Agricultural Tractors 2270005020 Off-highway Vehicle Diesel Agricultural Equipment Combines 2270005025 Off-highway Vehicle Diesel Agricultural Equipment Balers 2270005030 Off-highway Vehicle Diesel Agricultural Equipment Agricultural Mowers 2270005035 Off-highway Vehicle Diesel Agricultural Equipment Sprayers 2270005040 Off-highway Vehicle Diesel Agricultural Equipment Tillers > 6 HP 2270005045 Off-highway Vehicle Diesel Agricultural Equipment Swathers 2270005050 Off-highway Vehicle Diesel Agricultural Equipment Hydro-power Units 
SCC Description_2 Description_3 Description_4 

2270005055 Off-highway Vehicle Diesel Agricultural Equipment Other Agricultural Equipme2270005060 Off-highway Vehicle Diesel Agricultural Equipment Irrigation Sets 2270007000 Off-highway Vehicle Diesel Logging Equipment Total 2270007005 Off-highway Vehicle Diesel Logging Equipment Chain Saws > 6 HP 2270007010 Off-highway Vehicle Diesel Logging Equipment Shredders > 6HP 2270007015 Off-highway Vehicle Diesel Logging Equipment Forest Eqp – Fellers/Bunc2270007020 Off-highway Vehicle Diesel Logging Equipment Fellers/Bunchers ** (see 22270009000 Off-highway Vehicle Diesel Underground Mining Equipment All 2270009010 Off-highway Vehicle Diesel Underground Mining Equipment Other Underground Mining 2270010000 Off-highway Vehicle Diesel Industrial Equipment All 2270010010 Off-highway Vehicle Diesel Industrial Equipment Other Oil Field Equipment 

Industrial Sector-LPG

2267002000 LPG Construction and Mining Equipment All 2267002003 LPG Construction and Mining Equipment Pavers 2267002006 LPG Construction and Mining Equipment Tampers/Rammers 2267002009 LPG Construction and Mining Equipment Plate Compactors 2267002015 LPG Construction and Mining Equipment Rollers 2267002018 LPG Construction and Mining Equipment Scrapers 2267002021 LPG Construction and Mining Equipment Paving Equipment 2267002024 LPG Construction and Mining Equipment Surfacing Equipment 2267002027 LPG Construction and Mining Equipment Signal Boards/Light Plants 2267002030 LPG Construction and Mining Equipment Trenchers 2267002033 LPG Construction and Mining Equipment Bore/Drill Rigs 2267002036 LPG Construction and Mining Equipment Excavators 2267002039 LPG Construction and Mining Equipment Concrete/Industrial Saws 2267002042 LPG Construction and Mining Equipment Cement and Mortar Mixers 2267002045 LPG Construction and Mining Equipment Cranes 2267002048 LPG Construction and Mining Equipment Graders 2267002051 LPG Construction and Mining Equipment Off-highway Trucks 
SCC Description_2 Description_3 Description_4 

2267002054 LPG Construction and Mining Equipment Crushing/Processing Equip2267002057 LPG Construction and Mining Equipment Rough Terrain Forklifts 2267002060 LPG Construction and Mining Equipment Rubber Tire Loaders 2267002063 LPG Construction and Mining Equipment Rubber Tire Tractors/Doze2267002066 LPG Construction and Mining Equipment Tractors/Loaders/Backhoe2267002069 LPG Construction and Mining Equipment Crawler Tractor/Dozers 2267002072 LPG Construction and Mining Equipment Skid Steer Loaders 2267002075 LPG Construction and Mining Equipment Off-Highway Tractors 2267002078 LPG Construction and Mining Equipment Dumpers/Tenders 2267002081 LPG Construction and Mining Equipment Other Construction Equipm2267003000 LPG Industrial Equipment All 2267003010 LPG Industrial Equipment Aerial Lifts 2267003020 LPG Industrial Equipment Forklifts 2267003030 LPG Industrial Equipment Sweepers/Scrubbers 2267003040 LPG Industrial Equipment Other General Industrial E2267003050 LPG Industrial Equipment Other Material Handling Eq2267003060 LPG Industrial Equipment AC\Refrigeration 2267003070 LPG Industrial Equipment Terminal Tractors 2267005000 LPG Agricultural Equipment All 2267005010 LPG Agricultural Equipment 2-Wheel Tractors 2267005015 LPG Agricultural Equipment Agricultural Tractors 2267005020 LPG Agricultural Equipment Combines 2267005025 LPG Agricultural Equipment Balers 2267005030 LPG Agricultural Equipment Agricultural Mowers 2267005035 LPG Agricultural Equipment Sprayers 2267005040 LPG Agricultural Equipment Tillers >6 HP 2267005045 LPG Agricultural Equipment Swathers 2267005050 LPG Agricultural Equipment Hydro-power Units 2267005055 LPG Agricultural Equipment Other Agricultural Equipme
SCC Description_2 Description_3 Description_4 

2267005060 LPG Agricultural Equipment Irrigation Sets 2267007000 LPG Logging Equipment All 2267007005 LPG Logging Equipment Chain Saws > 6 HP 2267007010 LPG Logging Equipment Shredders > 6 HP 2267007015 LPG Logging Equipment Forest Eqp – Feller/Bunch/2267009000 LPG Underground Mining Equipment All 2267009010 LPG Underground Mining Equipment Other Underground Mining 2267010000 LPG Industrial Equipment All 2267010010 LPG Industrial Equipment Other Oil Field Equipment 

Commercial Sector-Distillate 

2270004000 Off-highway Vehicle Diesel Lawn and Garden Equipment All 2270004011 Off-highway Vehicle Diesel Lawn and Garden Equipment Lawn Mowers (Commercia2270004016 Off-highway Vehicle Diesel Lawn and Garden Equipment Rotary Tillers < 6HP (Com2270004021 Off-highway Vehicle Diesel Lawn and Garden Equipment Chain Saws < 6 HP (Comm2270004026 Off-highway Vehicle Diesel Lawn and Garden Equipment Trimmers/Edgers/Brush C2270004031 Off-highway Vehicle Diesel Lawn and Garden Equipment Leafblowers/Vacuums (Co2270004036 Off-highway Vehicle Diesel Lawn and Garden Equipment Snowblowers (Commercia2270004041 Off-highway Vehicle Diesel Lawn and Garden Equipment Rear Engine Riding Mowe2270004046 Off-highway Vehicle Diesel Lawn and Garden Equipment Front Mowers (Commercia2270004051 Off-highway Vehicle Diesel Lawn and Garden Equipment Shredders < 6 HP (Comme2270004056 Off-highway Vehicle Diesel Lawn and Garden Equipment Lawn and Garden Tractors 2270004061 Off-highway Vehicle Diesel Lawn and Garden Equipment Wood Splitters (Commerci2270004066 Off-highway Vehicle Diesel Lawn and Garden Equipment Chippers/Stump Grinders 2270004070 Off-highway Vehicle Diesel Lawn and Garden Equipment Commercial Turf Equipme2270004071 Off-highway Vehicle Diesel Lawn and Garden Equipment Turf Equipment (Commerc2270004076 Off-highway Vehicle Diesel Lawn and Garden Equipment Other Lawn and Garden E2270006000 Off-highway Vehicle Diesel Commercial Equipment Total 2270006005 Off-highway Vehicle Diesel Commercial Equipment Generator Sets 2270006010 Off-highway Vehicle Diesel Commercial Equipment Pumps 
SCC Description_2 Description_3 Description_4 

2270006015 Off-highway Vehicle Diesel Commercial Equipment Air Compressors 2270006020 Off-highway Vehicle Diesel Commercial Equipment Gas Compressors 2270006025 Off-highway Vehicle Diesel Commercial Equipment Welders 2270006030 Off-highway Vehicle Diesel Commercial Equipment Pressure Washers 2270008000 Off-highway Vehicle Diesel Airport Ground Support Equipment Total 2270008005 Off-highway Vehicle Diesel Airport Ground Support Equipment Airport Ground Support Eq2270008010 Off-highway Vehicle Diesel Airport Ground Support Equipment Terminal Tractors 

Commercial Sector-LPG

22670004011 LPG Lawn and Garden Equipment Lawn Mowers (Commercia22670004016 LPG Lawn and Garden Equipment Rotary Tillers < 6 HP (Com22670004021 LPG Lawn and Garden Equipment Chain Saws < 6 HP (Comm22670004026 LPG Lawn and Garden Equipment Trimmers/Edgers/Brush C22670004031 LPG Lawn and Garden Equipment Leafblowers/Vacuums (Co22670004036 LPG Lawn and Garden Equipment Snowblowers (Commercia22670004041 LPG Lawn and Garden Equipment Rear Engine Riding Mowe22670004046 LPG Lawn and Garden Equipment Front Mowers (Commercia22670004051 LPG Lawn and Garden Equipment Shredders < 6 HP (Comme22670004056 LPG Lawn and Garden Equipment Lawn and Garden Tractors 22670004061 LPG Lawn and Garden Equipment Wood Splitters (Commerci22670004066 LPG Lawn and Garden Equipment Chippers/Stump Grinders 22670004071 LPG Lawn and Garden Equipment Turf Equipment (Commerc22670004076 LPG Lawn and Garden Equipment Other Lawn and Garden E22670006000 LPG Commercial Equipment All 22670006005 LPG Commercial Equipment Generator Sets 22670006010 LPG Commercial Equipment Pumps 22670006015 LPG Commercial Equipment Air Compressors 22670006020 LPG Commercial Equipment Gas Compressors 22670006025 LPG Commercial Equipment Welders 22670006030 LPG Commercial Equipment Pressure Washers 
11 of 53

4. Point Source Energy Consumption 

To ensure that energy consumption is not double-counted in the point source inventory, it will 

also be necessary to subtract point source inventory fuel use from the fuel consumption estimates 

developed from the aforementioned data sources. To assist in the point source subtractions, 

Pechan has developed two crosswalks: one between each Industrial fuel combustion area SCC 

and associated point SCCs (Table 4), and an analogous crosswalk for Commercial/Institutional 

fuel combustion (Table 5). Pechan requests CENRAP comments on the point SCCs included in 

these crosswalks. 

In addition, a summary analysis was performed on the throughput data reported in the 2002 point 

source inventory compiled for CENRAP (Pechan/CEP, 2005). The Attachment to this 

memorandum provides a summary of the 2002 annual point source throughput data associated 

with the ICI area source categories (reflecting use of the Table 4 and 5 crosswalks). As indicated 

by this summary, there appear to be numerous potential reporting errors in the CENRAP point 

source inventory throughput information. These errors include throughput reported using 

inappropriate units (e.g., reporting natural gas throughput in tons and distillate fuel throughput in 

million cubic feet), and throughput reported using an inappropriate material code (e.g., reporting 

a distillate fuel combustion category’s throughput as water). There are also records with 

emissions that report throughput as zero and throughput data reported without any unit 

identifiers. Pechan requests guidance from CENRAP States as to revisions to the throughput 

information to ensure the validity of the data that are used in the point source subtractions. For 

States/source categories with suspect values for which revisions are not available, Pechan will 

estimate throughput by dividing point source emissions by the carbon monoxide (CO) emission 

factors listed in the next section. The CO-based approach will also be used for all States that do 

not report any throughput data for ICI point source fuel combustion categories (i.e., Louisiana 

and Texas). 

To ensure that the methodology results in accurate estimates of point source throughput, Pechan 

will supply States with the SEDS energy consumption estimates by fuel type and the point 

source energy consumption by fuel type computed using the throughput or CO emissions-based 

approach. Pechan will wait for State approval of these estimates before final use in the point 

source subtraction procedure. 

 
Table 4. Industrial Fuel Combustion Crosswalk for Point Source Subtractions 

Point SCC SCC1 DESC SCC3 DESC SCC6 DESC SCC8 DESC 

2102001000 & 2102002000 – Industrial; Anthracite Coal; Total: All Boiler Types and Bituminous/Subbituminous Coal; Total: All B

10200101 External Combustion Boilers Industrial Anthracite Coal Pulverized Coal 10200104 External Combustion Boilers Industrial Anthracite Coal Traveling Grate (Overfeed) 10200107 External Combustion Boilers Industrial Anthracite Coal Hand-fired 10200117 External Combustion Boilers Industrial Anthracite Coal Fluidized Bed Boiler Burnin39000189 Industrial Processes In-process Fuel Use Anthracite Coal General 39000199 Industrial Processes In-process Fuel Use Anthracite Coal General 10200201 External Combustion Boilers Industrial Bituminous/Subbituminous Coal Pulverized Coal: Wet Botto10200202 External Combustion Boilers Industrial Bituminous/Subbituminous Coal Pulverized Coal: Dry Botto10200203 External Combustion Boilers Industrial Bituminous/Subbituminous Coal Cyclone Furnace 10200204 External Combustion Boilers Industrial Bituminous/Subbituminous Coal Spreader Stoker 10200205 External Combustion Boilers Industrial Bituminous/Subbituminous Coal Overfeed Stoker 10200206 External Combustion Boilers Industrial Bituminous/Subbituminous Coal Underfeed Stoker 10200210 External Combustion Boilers Industrial Bituminous/Subbituminous Coal Overfeed Stoker ** 10200212 External Combustion Boilers Industrial Bituminous/Subbituminous Coal Pulverized Coal: Dry Botto10200213 External Combustion Boilers Industrial Bituminous/Subbituminous Coal Wet Slurry 10200217 External Combustion Boilers Industrial Bituminous/Subbituminous Coal Atmospheric Fluidized Bed 

Bed (Bituminous Coal) 

10200218 External Combustion Boilers Industrial Bituminous/Subbituminous Coal Atmospheric Fluidized Bed 

Bed (Bitum. Coal) 

10200219 External Combustion Boilers Industrial Bituminous/Subbituminous Coal Cogeneration (Bituminous 10200221 External Combustion Boilers Industrial Bituminous/Subbituminous Coal Pulverized Coal: Wet Botto10200222 External Combustion Boilers Industrial Bituminous/Subbituminous Coal Pulverized Coal: Dry Botto10200223 External Combustion Boilers Industrial Bituminous/Subbituminous Coal Cyclone Furnace (Subbitum10200224 External Combustion Boilers Industrial Bituminous/Subbituminous Coal Spreader Stoker (Subbitum10200225 External Combustion Boilers Industrial Bituminous/Subbituminous Coal Traveling Grate (Overfeed) 

Coal) 

10200226 External Combustion Boilers Industrial Bituminous/Subbituminous Coal Pulverized Coal: Dry Botto

(Subbituminous Coal) 

10200229 External Combustion Boilers Industrial Bituminous/Subbituminous Coal Cogeneration (Subbitumino10500102 External Combustion Boilers Space Heaters Industrial Coal ** 39000201 Industrial Processes In-process Fuel Use Bituminous Coal Cement Kiln/Dryer (Bitumin39000203 Industrial Processes In-process Fuel Use Bituminous Coal Lime Kiln (Bituminous) 39000288 Industrial Processes In-process Fuel Use Bituminous Coal General (Subbituminous) 39000289 Industrial Processes In-process Fuel Use Bituminous Coal General (Bituminous) 39000299 Industrial Processes In-process Fuel Use Bituminous Coal General (Bituminous) 50390002 Waste Disposal Solid Waste Disposal - Industrial Auxiliary Fuel/No Emissions Coal 
Point SCC SCC1 DESC SCC3 DESC SCC6 DESC SCC8 DESC 

2102004000 – Industrial; Distillate Oil; Total: Boilers and IC Engines 

10200501 External Combustion Boilers Industrial Distillate Oil Grades 1 and 2 Oil 10200502 External Combustion Boilers Industrial Distillate Oil 10-100 Million Btu/hr ** 10200503 External Combustion Boilers Industrial Distillate Oil < 10 Million Btu/hr ** 10200504 External Combustion Boilers Industrial Distillate Oil Grade 4 Oil 10200505 External Combustion Boilers Industrial Distillate Oil Cogeneration 10201403 External Combustion Boilers Industrial CO Boiler Distillate Oil 10500105 External Combustion Boilers Space Heaters Industrial Distillate Oil 20200101 Internal Combustion Engines Industrial Distillate Oil (Diesel) Turbine 20200102 Internal Combustion Engines Industrial Distillate Oil (Diesel) Reciprocating 20200103 Internal Combustion Engines Industrial Distillate Oil (Diesel) Turbine: Cogeneration 20200104 Internal Combustion Engines Industrial Distillate Oil (Diesel) Reciprocating: Cogeneratio20200105 Internal Combustion Engines Industrial Distillate Oil (Diesel) Reciprocating: Crankcase 20200106 Internal Combustion Engines Industrial Distillate Oil (Diesel) Reciprocating: Evaporative 

and Delivery System) 

20200107 Internal Combustion Engines Industrial Distillate Oil (Diesel) Reciprocating: Exhaust 20200108 Internal Combustion Engines Industrial Distillate Oil (Diesel) Turbine: Evaporative Loss

Delivery System) 

20200109 Internal Combustion Engines Industrial Distillate Oil (Diesel) Turbine: Exhaust 20200401 Internal Combustion Engines Industrial Large Bore Engine Diesel 20200405 Internal Combustion Engines Industrial Large Bore Engine Crankcase Blowby 20200406 Internal Combustion Engines Industrial Large Bore Engine Evaporative Losses (Fuel S

System) 

20200407 Internal Combustion Engines Industrial Large Bore Engine Exhaust 27000320 Internal Combustion Engines Off-highway Diesel Engines Industrial Equipment Industrial Fork Lift: Diesel 30190001 Industrial Processes Chemical Manufacturing Fuel Fired Equipment Distillate Oil (No. 2): Proce30190011 Industrial Processes Chemical Manufacturing Fuel Fired Equipment Distillate Oil (No. 2): Incine30190021 Industrial Processes Chemical Manufacturing Fuel Fired Equipment Distillate Oil (No. 2): Flares 30290001 Industrial Processes Food and Agriculture Fuel Fired Equipment Distillate Oil (No. 2): Proce30390001 Industrial Processes Primary Metal Production Fuel Fired Equipment Distillate Oil (No. 2): Proce30390011 Industrial Processes Primary Metal Production Fuel Fired Equipment Distillate Oil (No. 2): Incine30390021 Industrial Processes Primary Metal Production Fuel Fired Equipment Distillate Oil (No. 2): Flares 30400406 Industrial Processes Secondary Metal Production Lead Pot Furnace Heater: Distill30490001 Industrial Processes Secondary Metal Production Fuel Fired Equipment Distillate Oil (No. 2): Proce30490011 Industrial Processes Secondary Metal Production Fuel Fired Equipment Distillate Oil (No. 2): Incine30490021 Industrial Processes Secondary Metal Production Fuel Fired Equipment Distillate Oil (No. 2): Flares 30490031 Industrial Processes Secondary Metal Production Fuel Fired Equipment Distillate Oil (No. 2): Furna30500208 Industrial Processes Mineral Products Asphalt Concrete Asphalt Heater: Distillate O30505022 Industrial Processes Mineral Products Asphalt Processing (Blowing) Asphalt Heater: Distillate O30590001 Industrial Processes Mineral Products Fuel Fired Equipment Distillate Oil (No. 2): Proce30590011 Industrial Processes Mineral Products Fuel Fired Equipment Distillate Oil (No. 2): Incine30590021 Industrial Processes Mineral Products Fuel Fired Equipment Distillate Oil (No. 2): Flares 
Point SCC SCC1 DESC SCC3 DESC SCC6 DESC SCC8 DESC 30600901 Industrial Processes Petroleum Industry Flares Distillate Oil 30609901 Industrial Processes Petroleum Industry Incinerators Distillate Oil (No. 2) 30790001 Industrial Processes Pulp and Paper and Wood 

Products 

Fuel Fired Equipment Distillate Oil (No. 2): Proce

30790011 Industrial Processes Pulp and Paper and Wood 

Products 

Fuel Fired Equipment Distillate Oil (No. 2): Incine

30790021 Industrial Processes Pulp and Paper and Wood 

Products 

Fuel Fired Equipment Distillate Oil (No. 2): Flares 

30890001 Industrial Processes Rubber and Miscellaneous 

Plastics Products 

Fuel Fired Equipment Distillate Oil (No. 2): Proce

30890011 Industrial Processes Rubber and Miscellaneous 

Plastics Products 

Fuel Fired Equipment Distillate Oil (No. 2): Incine

30890021 Industrial Processes Rubber and Miscellaneous 

Plastics Products 

Fuel Fired Equipment Distillate Oil (No. 2): Flares 

30990001 Industrial Processes Fabricated Metal Products Fuel Fired Equipment Distillate Oil (No. 2): Proce30990011 Industrial Processes Fabricated Metal Products Fuel Fired Equipment Distillate Oil (No. 2): Incine31000401 Industrial Processes Oil and Gas Production Process Heaters Distillate Oil (No. 2) 31000411 Industrial Processes Oil and Gas Production Process Heaters Distillate Oil (No. 2): Steam 31390001 Industrial Processes Electrical Equipment Process Heaters Distillate Oil (No. 2) 39000501 Industrial Processes In-process Fuel Use Distillate Oil Asphalt Dryer ** 39000502 Industrial Processes In-process Fuel Use Distillate Oil Cement Kiln/Dryer 39000503 Industrial Processes In-process Fuel Use Distillate Oil Lime Kiln 39000589 Industrial Processes In-process Fuel Use Distillate Oil General 39000598 Industrial Processes In-process Fuel Use Distillate Oil Grade 4 Oil: General 39000599 Industrial Processes In-process Fuel Use Distillate Oil General 39900501 Industrial Processes Miscellaneous Manufacturing 

Industries 

Process Heater/Furnace Distillate Oil 

39990001 Industrial Processes Miscellaneous Manufacturing 

Industries 

Miscellaneous Manufacturing Industries 

Distillate Oil (No. 2): Proce

39990011 Industrial Processes Miscellaneous Manufacturing 

Industries 

Miscellaneous Manufacturing Industries 

Distillate Oil (No. 2): Incine

39990021 Industrial Processes Miscellaneous Manufacturing 

Industries 

Miscellaneous Manufacturing Industries 

Distillate Oil (No. 2 Oil): Fla

40201002 Petroleum and Solvent 

Evaporation 

Surface Coating Operations Coating Oven Heater Distillate Oil 

40290011 Petroleum and Solvent 

Evaporation 

Surface Coating Operations Fuel Fired Equipment Distillate Oil: Incinerator/Af

49090011 Petroleum and Solvent 

Evaporation 

Organic Solvent Evaporation Fuel Fired Equipment Distillate Oil (No. 2): Incine

49090021 Petroleum and Solvent 

Evaporation 

Organic Solvent Evaporation Fuel Fired Equipment Distillate Oil (No. 2): Flares 

50390005 Waste Disposal Solid Waste Disposal - Industrial Auxiliary Fuel/No Emissions Distillate Oil 

2102005000 – Industrial; Residual Oil; Total: All Boiler Types 

10200401 External Combustion Boilers Industrial Residual Oil Grade 6 Oil 
Point SCC SCC1 DESC SCC3 DESC SCC6 DESC SCC8 DESC 10200402 External Combustion Boilers Industrial Residual Oil 10-100 Million Btu/hr ** 10200403 External Combustion Boilers Industrial Residual Oil < 10 Million Btu/hr ** 10200404 External Combustion Boilers Industrial Residual Oil Grade 5 Oil 10200405 External Combustion Boilers Industrial Residual Oil Cogeneration 10201404 External Combustion Boilers Industrial CO Boiler Residual Oil 20200501 Internal Combustion Engines Industrial Residual/Crude Oil Reciprocating 20200505 Internal Combustion Engines Industrial Residual/Crude Oil Reciprocating: Crankcase 20200506 Internal Combustion Engines Industrial Residual/Crude Oil Reciprocating: Evaporative 

and Delivery System) 

20200507 Internal Combustion Engines Industrial Residual/Crude Oil Reciprocating: Exhaust 30190002 Industrial Processes Chemical Manufacturing Fuel Fired Equipment Residual Oil: Process Hea30190012 Industrial Processes Chemical Manufacturing Fuel Fired Equipment Residual Oil: Incinerators 30190022 Industrial Processes Chemical Manufacturing Fuel Fired Equipment Residual Oil: Flares 30290002 Industrial Processes Food and Agriculture Fuel Fired Equipment Residual Oil: Process Hea30390002 Industrial Processes Primary Metal Production Fuel Fired Equipment Residual Oil: Process Hea30390012 Industrial Processes Primary Metal Production Fuel Fired Equipment Residual Oil: Incinerators 30390022 Industrial Processes Primary Metal Production Fuel Fired Equipment Residual Oil: Flares 30490002 Industrial Processes Secondary Metal Production Fuel Fired Equipment Residual Oil: Process Hea30490012 Industrial Processes Secondary Metal Production Fuel Fired Equipment Residual Oil: Incinerators 30490022 Industrial Processes Secondary Metal Production Fuel Fired Equipment Residual Oil: Flares 30490032 Industrial Processes Secondary Metal Production Fuel Fired Equipment Residual Oil: Furnaces 30500207 Industrial Processes Mineral Products Asphalt Concrete Asphalt Heater: Residual O30505021 Industrial Processes Mineral Products Asphalt Processing (Blowing) Asphalt Heater: Residual O30590002 Industrial Processes Mineral Products Fuel Fired Equipment Residual Oil: Process Hea30590012 Industrial Processes Mineral Products Fuel Fired Equipment Residual Oil: Incinerators 30600111 Industrial Processes Petroleum Industry Process Heaters Oil-fired (No. 6 Oil) > 100 M30600902 Industrial Processes Petroleum Industry Flares Residual Oil 30609902 Industrial Processes Petroleum Industry Incinerators Residual Oil 30790002 Industrial Processes Pulp and Paper and Wood 

Products 

Fuel Fired Equipment Residual Oil: Process Hea

30790012 Industrial Processes Pulp and Paper and Wood 

Products 

Fuel Fired Equipment Residual Oil: Incinerators 

30790022 Industrial Processes Pulp and Paper and Wood 

Products 

Fuel Fired Equipment Residual Oil: Flares 

30890002 Industrial Processes Rubber and Miscellaneous 

Plastics Products 

Fuel Fired Equipment Residual Oil: Process Hea

30890012 Industrial Processes Rubber and Miscellaneous 

Plastics Products 

Fuel Fired Equipment Residual Oil: Incinerators 

30890022 Industrial Processes Rubber and Miscellaneous 

Plastics Products 

Fuel Fired Equipment Residual Oil: Flares 

30990002 Industrial Processes Fabricated Metal Products Fuel Fired Equipment Residual Oil: Process Hea30990012 Industrial Processes Fabricated Metal Products Fuel Fired Equipment Residual Oil: Incinerators 31000402 Industrial Processes Oil and Gas Production Process Heaters Residual Oil 
Point SCC SCC1 DESC SCC3 DESC SCC6 DESC SCC8 DESC 31000412 Industrial Processes Oil and Gas Production Process Heaters Residual Oil: Steam Gener31390002 Industrial Processes Electrical Equipment Process Heaters Residual Oil 39000402 Industrial Processes In-process Fuel Use Residual Oil Cement Kiln/Dryer 39000403 Industrial Processes In-process Fuel Use Residual Oil Lime Kiln 39000489 Industrial Processes In-process Fuel Use Residual Oil General 39000499 Industrial Processes In-process Fuel Use Residual Oil General 39990002 Industrial Processes Miscellaneous Manufacturing 

Industries 

Miscellaneous Manufacturing Industries 

Residual Oil: Process Hea

39990012 Industrial Processes Miscellaneous Manufacturing 

Industries 

Miscellaneous Manufacturing Industries 

Residual Oil: Incinerators 

39990022 Industrial Processes Miscellaneous Manufacturing 

Industries 

Miscellaneous Manufacturing Industries 

Residual Oil: Flares 

40201003 Petroleum and Solvent 

Evaporation 

Surface Coating Operations Coating Oven Heater Residual Oil 

40290012 Petroleum and Solvent 

Evaporation 

Surface Coating Operations Fuel Fired Equipment Residual Oil: Incinerator/Af

49090012 Petroleum and Solvent 

Evaporation 

Organic Solvent Evaporation Fuel Fired Equipment Residual Oil: Incinerators 

49090022 Petroleum and Solvent 

Evaporation 

Organic Solvent Evaporation Fuel Fired Equipment Residual Oil: Flares 

2102006000 – Industrial; Natural Gas; Total: Boilers and IC Engines 

10200601 External Combustion Boilers Industrial Natural Gas > 100 Million Btu/hr 10200602 External Combustion Boilers Industrial Natural Gas 10-100 Million Btu/hr 10200603 External Combustion Boilers Industrial Natural Gas < 10 Million Btu/hr 10200604 External Combustion Boilers Industrial Natural Gas Cogeneration 10201401 External Combustion Boilers Industrial CO Boiler Natural Gas 10500106 External Combustion Boilers Space Heaters Industrial Natural Gas 20200201 Internal Combustion Engines Industrial Natural Gas Turbine 20200202 Internal Combustion Engines Industrial Natural Gas Reciprocating 20200203 Internal Combustion Engines Industrial Natural Gas Turbine: Cogeneration 20200204 Internal Combustion Engines Industrial Natural Gas Reciprocating: Cogeneratio20200205 Internal Combustion Engines Industrial Natural Gas Reciprocating: Crankcase 20200206 Internal Combustion Engines Industrial Natural Gas Reciprocating: Evaporative 

System) 

20200207 Internal Combustion Engines Industrial Natural Gas Reciprocating: Exhaust 20200208 Internal Combustion Engines Industrial Natural Gas Turbine: Evaporative Loss20200209 Internal Combustion Engines Industrial Natural Gas Turbine: Exhaust 20200252 Internal Combustion Engines Industrial Natural Gas 2-cycle Lean Burn 20200253 Internal Combustion Engines Industrial Natural Gas 4-cycle Rich Burn 20200254 Internal Combustion Engines Industrial Natural Gas 4-cycle Lean Burn 20200255 Internal Combustion Engines Industrial Natural Gas 2-cycle Clean Burn 20200256 Internal Combustion Engines Industrial Natural Gas 4-cycle Clean Burn 30190003 Industrial Processes Chemical Manufacturing Fuel Fired Equipment Natural Gas: Process Heat
Point SCC SCC1 DESC SCC3 DESC SCC6 DESC SCC8 DESC 30190013 Industrial Processes Chemical Manufacturing Fuel Fired Equipment Natural Gas: Incinerators 30190023 Industrial Processes Chemical Manufacturing Fuel Fired Equipment Natural Gas: Flares 30290003 Industrial Processes Food and Agriculture Fuel Fired Equipment Natural Gas: Process Heat30291001 Industrial Processes Food and Agriculture Fuel Fired Equipment Broiling Food: Natural Gas 30390003 Industrial Processes Primary Metal Production Fuel Fired Equipment Natural Gas: Process Heat30390013 Industrial Processes Primary Metal Production Fuel Fired Equipment Natural Gas: Incinerators 30390023 Industrial Processes Primary Metal Production Fuel Fired Equipment Natural Gas: Flares 30400407 Industrial Processes Secondary Metal Production Lead Pot Furnace Heater: Natur30490003 Industrial Processes Secondary Metal Production Fuel Fired Equipment Natural Gas: Process Heat30490013 Industrial Processes Secondary Metal Production Fuel Fired Equipment Natural Gas: Incinerators 30490023 Industrial Processes Secondary Metal Production Fuel Fired Equipment Natural Gas: Flares 30490033 Industrial Processes Secondary Metal Production Fuel Fired Equipment Natural Gas: Furnaces 30500206 Industrial Processes Mineral Products Asphalt Concrete Asphalt Heater: Natural Ga30505020 Industrial Processes Mineral Products Asphalt Processing (Blowing) Asphalt Heater: Natural Ga30590003 Industrial Processes Mineral Products Fuel Fired Equipment Natural Gas: Process Heat30590013 Industrial Processes Mineral Products Fuel Fired Equipment Natural Gas: Incinerators 30590023 Industrial Processes Mineral Products Fuel Fired Equipment Natural Gas: Flares 30790003 Industrial Processes Pulp and Paper and Wood 

Products 

Fuel Fired Equipment Natural Gas: Process Heat

30790013 Industrial Processes Pulp and Paper and Wood 

Products 

Fuel Fired Equipment Natural Gas: Incinerators 

30790023 Industrial Processes Pulp and Paper and Wood 

Products 

Fuel Fired Equipment Natural Gas: Flares 

30890003 Industrial Processes Rubber and Miscellaneous 

Plastics Products 

Fuel Fired Equipment Natural Gas: Process Heat

30890013 Industrial Processes Rubber and Miscellaneous 

Plastics Products 

Fuel Fired Equipment Natural Gas: Incinerators 

30890023 Industrial Processes Rubber and Miscellaneous 

Plastics Products 

Fuel Fired Equipment Natural Gas: Flares 

30990003 Industrial Processes Fabricated Metal Products Fuel Fired Equipment Natural Gas: Process Heat30990013 Industrial Processes Fabricated Metal Products Fuel Fired Equipment Natural Gas: Incinerators 30990023 Industrial Processes Fabricated Metal Products Fuel Fired Equipment Natural Gas: Flares 31000404 Industrial Processes Oil and Gas Production Process Heaters Natural Gas 31000414 Industrial Processes Oil and Gas Production Process Heaters Natural Gas: Steam Gener31390003 Industrial Processes Electrical Equipment Process Heaters Natural Gas 39000602 Industrial Processes In-process Fuel Use Natural Gas Cement Kiln/Dryer 39000603 Industrial Processes In-process Fuel Use Natural Gas Lime Kiln 39000605 Industrial Processes In-process Fuel Use Natural Gas Metal Melting ** 39000689 Industrial Processes In-process Fuel Use Natural Gas General 39000699 Industrial Processes In-process Fuel Use Natural Gas General 39900601 Industrial Processes Miscellaneous Manufacturing 

Industries 

Process Heater/Furnace Natural Gas 

39990003 Industrial Processes Miscellaneous Manufacturing Miscellaneous Manufacturing Natural Gas: Process Heat
Point SCC SCC1 DESC SCC3 DESC SCC6 DESC SCC8 DESC 

Industries Industries 

39990013 Industrial Processes Miscellaneous Manufacturing 

Industries 

Miscellaneous Manufacturing Industries 

Natural Gas: Incinerators 

39990023 Industrial Processes Miscellaneous Manufacturing 

Industries 

Miscellaneous Manufacturing Industries 

Natural Gas: Flares 

40201001 Petroleum and Solvent 

Evaporation 

Surface Coating Operations Coating Oven Heater Natural Gas 

40290013 Petroleum and Solvent 

Evaporation 

Surface Coating Operations Fuel Fired Equipment Natural Gas: Incinerator/Af

40290023 Petroleum and Solvent 

Evaporation 

Surface Coating Operations Fuel Fired Equipment Natural Gas: Flares 

49090013 Petroleum and Solvent 

Evaporation 

Organic Solvent Evaporation Fuel Fired Equipment Natural Gas: Incinerators 

49090023 Petroleum and Solvent 

Evaporation 

Organic Solvent Evaporation Fuel Fired Equipment Natural Gas: Flares 

50390006 Waste Disposal Solid Waste Disposal - Industrial Auxiliary Fuel/No Emissions Natural Gas 

2102007000 – Industrial; Liquified Petroleum Gas (LPG); Total: All Boiler Types 

10201001 External Combustion Boilers Industrial Liquified Petroleum Gas (LPG) Butane 10201002 External Combustion Boilers Industrial Liquified Petroleum Gas (LPG) Propane 10201003 External Combustion Boilers Industrial Liquified Petroleum Gas (LPG) Butane/Propane Mixture: S

Comments 

10500110 External Combustion Boilers Space Heaters Industrial Liquified Petroleum Gas (L20201001 Internal Combustion Engines Industrial Liquified Petroleum Gas (LPG) Propane: Reciprocating 20201002 Internal Combustion Engines Industrial Liquified Petroleum Gas (LPG) Butane: Reciprocating 20201005 Internal Combustion Engines Industrial Liquified Petroleum Gas (LPG) Reciprocating: Crankcase 20201006 Internal Combustion Engines Industrial Liquified Petroleum Gas (LPG) Reciprocating: Evaporative 

and Delivery System) 

20201007 Internal Combustion Engines Industrial Liquified Petroleum Gas (LPG) Reciprocating: Exhaust 20201008 Internal Combustion Engines Industrial Liquified Petroleum Gas (LPG) Turbine: Evaporative Losse

Delivery System) 

20201009 Internal Combustion Engines Industrial Liquified Petroleum Gas (LPG) Turbine: Exhaust 20201011 Internal Combustion Engines Industrial Liquified Petroleum Gas (LPG) Turbine 20201012 Internal Combustion Engines Industrial Liquified Petroleum Gas (LPG) Reciprocating Engine 20201013 Internal Combustion Engines Industrial Liquified Petroleum Gas (LPG) Turbine: Cogeneration 20201014 Internal Combustion Engines Industrial Liquified Petroleum Gas (LPG) Reciprocating Engine: Cog27300320 Internal Combustion Engines Off-highway LPG-fueled Engines Industrial Equipment Industrial Fork Lift: Liquifie30290005 Industrial Processes Food and Agriculture Fuel Fired Equipment Liquified Petroleum Gas (L30490035 Industrial Processes Secondary Metal Production Fuel Fired Equipment Propane: Furnaces 30500209 Industrial Processes Mineral Products Asphalt Concrete Asphalt Heater: LPG 30505023 Industrial Processes Mineral Products Asphalt Processing (Blowing) Asphalt Heater: LP Gas 30590005 Industrial Processes Mineral Products Fuel Fired Equipment Liquified Petroleum Gas (L30600107 Industrial Processes Petroleum Industry Process Heaters LPG-fired 30600905 Industrial Processes Petroleum Industry Flares Liquified Petroleum Gas 
Point SCC SCC1 DESC SCC3 DESC SCC6 DESC SCC8 DESC 30609905 Industrial Processes Petroleum Industry Incinerators Liquified Petroleum Gas 30890004 Industrial Processes Rubber and Miscellaneous 

Plastics Products 

Fuel Fired Equipment Liquified Petroleum Gas (L

31000406 Industrial Processes Oil and Gas Production Process Heaters Propane/Butane 39001089 Industrial Processes In-process Fuel Use Liquified Petroleum Gas General 39001099 Industrial Processes In-process Fuel Use Liquified Petroleum Gas General 39901001 Industrial Processes Miscellaneous Manufacturing 

Industries 

Process Heater/Furnace LPG 

40201004 Petroleum and Solvent 

Evaporation 

Surface Coating Operations Coating Oven Heater Liquified Petroleum Gas (L

50390010 Waste Disposal Solid Waste Disposal - Industrial Auxiliary Fuel/No Emissions Liquified Petroleum Gas (L

2102008000 – Industrial; Wood; Total: All Boiler Types 

10200902 External Combustion Boilers Industrial Wood/Bark Waste Wood/Bark-fired Boiler 10200903 External Combustion Boilers Industrial Wood/Bark Waste Wood-fired Boiler - Wet Wo10200905 External Combustion Boilers Industrial Wood/Bark Waste Wood/Bark-fired Boiler (< 510200906 External Combustion Boilers Industrial Wood/Bark Waste Wood-fired Boiler (< 50,0010200907 External Combustion Boilers Industrial Wood/Bark Waste Wood Cogeneration 10200908 External Combustion Boilers Industrial Wood/Bark Waste Wood-fired Boiler - Dry Wo10200910 External Combustion Boilers Industrial Wood/Bark Waste Fuel cell/Dutch oven boiler10200911 External Combustion Boilers Industrial Wood/Bark Waste Stoker boilers ** 10200912 External Combustion Boilers Industrial Wood/Bark Waste Fluidized bed combustion 39000989 Industrial Processes In-process Fuel Use Wood General 39000999 Industrial Processes In-process Fuel Use Wood General: Wood 

2102011000 – Industrial; Kerosene; Total: All Boiler Types 

20200901 Internal Combustion Engines Industrial Kerosene/Naphtha (Jet Fuel) Turbine 20200902 Internal Combustion Engines Industrial Kerosene/Naphtha (Jet Fuel) Reciprocating 20200905 Internal Combustion Engines Industrial Kerosene/Naphtha (Jet Fuel) Reciprocating: Crankcase 20200906 Internal Combustion Engines Industrial Kerosene/Naphtha (Jet Fuel) Reciprocating: Evaporative 

and Delivery System) 

20200907 Internal Combustion Engines Industrial Kerosene/Naphtha (Jet Fuel) Reciprocating: Exhaust 20200908 Internal Combustion Engines Industrial Kerosene/Naphtha (Jet Fuel) Turbine: Evaporative Losse

Delivery System) 

20200909 Internal Combustion Engines Industrial Kerosene/Naphtha (Jet Fuel) Turbine: Exhaust 
Table 5. Commercial/Institutional Fuel Combustion Crosswalk for Point Source Subt

Point SCC SCC1 DESC SCC3 DESC SCC6 DESC SCC8 DESC 

2103001000 & 2103002000 -- Commercial/Institutional; Anthracite Coal; Total: All Boiler Types and Bituminous/Subbituminous Coal; Tot

10300101 External Combustion Boilers Commercial/Institutional Anthracite Coal Pulverized Coal 10300102 External Combustion Boilers Commercial/Institutional Anthracite Coal Traveling Grate (Overfeed10300103 External Combustion Boilers Commercial/Institutional Anthracite Coal Hand-fired 10300203 External Combustion Boilers Commercial/Institutional Bituminous/Subbituminous Coal Cyclone Furnace (Bitumin10300205 External Combustion Boilers Commercial/Institutional Bituminous/Subbituminous Coal Pulverized Coal: Wet Botto10300206 External Combustion Boilers Commercial/Institutional Bituminous/Subbituminous Coal Pulverized Coal: Dry Botto10300207 External Combustion Boilers Commercial/Institutional Bituminous/Subbituminous Coal Overfeed Stoker (Bitumino10300208 External Combustion Boilers Commercial/Institutional Bituminous/Subbituminous Coal Underfeed Stoker (Bitumin10300209 External Combustion Boilers Commercial/Institutional Bituminous/Subbituminous Coal Spreader Stoker (Bitumino10300211 External Combustion Boilers Commercial/Institutional Bituminous/Subbituminous Coal Overfeed Stoker ** 10300214 External Combustion Boilers Commercial/Institutional Bituminous/Subbituminous Coal Hand-fired (Bituminous Co10300216 External Combustion Boilers Commercial/Institutional Bituminous/Subbituminous Coal 

Pulverized Coal: Dry Botto(Bituminous Coal) 

10300217 External Combustion Boilers Commercial/Institutional Bituminous/Subbituminous Coal 

Atmospheric Fluidized Bed Bed (Bituminous Coal) 

10300218 External Combustion Boilers Commercial/Institutional Bituminous/Subbituminous Coal 

Atmospheric Fluidized Bed 

Bed (Bitum. Coal) 

10300221 External Combustion Boilers Commercial/Institutional Bituminous/Subbituminous Coal Pulverized Coal: Wet Botto10300222 External Combustion Boilers Commercial/Institutional Bituminous/Subbituminous Coal Pulverized Coal: Dry Botto10300223 External Combustion Boilers Commercial/Institutional Bituminous/Subbituminous Coal Cyclone Furnace (Subbitu10300224 External Combustion Boilers Commercial/Institutional Bituminous/Subbituminous Coal Spreader Stoker (Subbitum10300225 External Combustion Boilers Commercial/Institutional Bituminous/Subbituminous Coal 

Traveling Grate (OverfeedCoal) 

10300226 External Combustion Boilers Commercial/Institutional Bituminous/Subbituminous Coal 

Pulverized Coal: Dry Botto(Subbituminous Coal) 

10500202 External Combustion Boilers Space Heaters Commercial/Institutional Coal ** 50190002 Waste Disposal 

Solid Waste Disposal - Government Auxiliary Fuel/No Emissions Coal 

50290002 Waste Disposal 

Solid Waste Disposal - Commercial/Institutional Auxiliary Fuel/No Emissions Coal 

2103004000 -- Commercial/Institutional; Distillate Oil; Total: Boilers and IC Engines 

10300501 External Combustion Boilers Commercial/Institutional Distillate Oil Grades 1 and 2 Oil 10300502 External Combustion Boilers Commercial/Institutional Distillate Oil 10-100 Million Btu/hr ** 10300503 External Combustion Boilers Commercial/Institutional Distillate Oil < 10 Million Btu/hr ** 10300504 External Combustion Boilers Commercial/Institutional Distillate Oil Grade 4 Oil 10500205 External Combustion Boilers Space Heaters Commercial/Institutional Distillate Oil 20300101 Internal Combustion Engines Commercial/Institutional Distillate Oil (Diesel) Reciprocating 20300102 Internal Combustion Engines Commercial/Institutional Distillate Oil (Diesel) Turbine 
Point SCC SCC1 DESC SCC3 DESC SCC6 DESC SCC8 DESC 20300105 Internal Combustion Engines Commercial/Institutional Distillate Oil (Diesel) Reciprocating: Crankcase 20300106 Internal Combustion Engines Commercial/Institutional Distillate Oil (Diesel) 

Reciprocating: Evaporative and Delivery System) 

20300107 Internal Combustion Engines Commercial/Institutional Distillate Oil (Diesel) Reciprocating: Exhaust 20300108 Internal Combustion Engines Commercial/Institutional Distillate Oil (Diesel) 

Turbine: Evaporative LossDelivery System) 

20300109 Internal Combustion Engines Commercial/Institutional Distillate Oil (Diesel) Turbine: Exhaust 50190005 Waste Disposal 

Solid Waste Disposal - Government Auxiliary Fuel/No Emissions Distillate Oil 

50290005 Waste Disposal 

Solid Waste Disposal - Commercial/Institutional Auxiliary Fuel/No Emissions Distillate Oil 

2103005000 -- Commercial/Institutional; Residual Oil; Total: All Boiler Types 

10300401 External Combustion Boilers Commercial/Institutional Residual Oil Grade 6 Oil 10300402 External Combustion Boilers Commercial/Institutional Residual Oil 10-100 Million Btu/hr ** 10300403 External Combustion Boilers Commercial/Institutional Residual Oil < 10 Million Btu/hr ** 10300404 External Combustion Boilers Commercial/Institutional Residual Oil Grade 5 Oil 

2103006000 -- Commercial/Institutional; Natural Gas; Total: Boilers and IC Engines 

10300601 External Combustion Boilers Commercial/Institutional Natural Gas > 100 Million Btu/hr 10300602 External Combustion Boilers Commercial/Institutional Natural Gas 10-100 Million Btu/hr 10300603 External Combustion Boilers Commercial/Institutional Natural Gas < 10 Million Btu/hr 10500206 External Combustion Boilers Space Heaters Commercial/Institutional Natural Gas 20300201 Internal Combustion Engines Commercial/Institutional Natural Gas Reciprocating 20300202 Internal Combustion Engines Commercial/Institutional Natural Gas Turbine 20300203 Internal Combustion Engines Commercial/Institutional Natural Gas Turbine: Cogeneration 20300204 Internal Combustion Engines Commercial/Institutional Natural Gas Cogeneration 20300205 Internal Combustion Engines Commercial/Institutional Natural Gas Reciprocating: Crankcase 20300206 Internal Combustion Engines Commercial/Institutional Natural Gas 

Reciprocating: Evaporative System) 

20300207 Internal Combustion Engines Commercial/Institutional Natural Gas Reciprocating: Exhaust 20300208 Internal Combustion Engines Commercial/Institutional Natural Gas Turbine: Evaporative Loss20300209 Internal Combustion Engines Commercial/Institutional Natural Gas Turbine: Exhaust 50190006 Waste Disposal 

Solid Waste Disposal - Government Auxiliary Fuel/No Emissions Natural Gas 

50290006 Waste Disposal 

Solid Waste Disposal - Commercial/Institutional Auxiliary Fuel/No Emissions Natural Gas 

2103007000 -- Commercial/Institutional; Liquid Petroleum Gas; Total: All Combustor Types 

10301001 External Combustion Boilers Commercial/Institutional Liquified Petroleum Gas (LPG) Butane 10301002 External Combustion Boilers Commercial/Institutional Liquified Petroleum Gas (LPG) Propane 10301003 External Combustion Boilers Commercial/Institutional Liquified Petroleum Gas (LPG) 

Butane/Propane Mixture: SComments 

10500210 External Combustion Boilers Space Heaters Commercial/Institutional Liquified Petroleum Gas (L20301001 Internal Combustion Engines Commercial/Institutional Liquified Petroleum Gas (LPG) Propane: Reciprocating 20301002 Internal Combustion Engines Commercial/Institutional Liquified Petroleum Gas (LPG) Butane: Reciprocating 
Point SCC SCC1 DESC SCC3 DESC SCC6 DESC SCC8 DESC 20301005 Internal Combustion Engines Commercial/Institutional Liquified Petroleum Gas (LPG) Reciprocating: Crankcase 20301006 Internal Combustion Engines Commercial/Institutional Liquified Petroleum Gas (LPG) 

Reciprocating: Evaporative and Delivery System) 

20301007 Internal Combustion Engines Commercial/Institutional Liquified Petroleum Gas (LPG) Reciprocating: Exhaust 50190010 Waste Disposal 

Solid Waste Disposal - Government Auxiliary Fuel/No Emissions Liquified Petroleum Gas (L

50290010 Waste Disposal 

Solid Waste Disposal - Commercial/Institutional Auxiliary Fuel/No Emissions Liquified Petroleum Gas (L

2103008000 -- Commercial/Institutional; Wood; Total: All Boiler Types 

10300902 External Combustion Boilers Commercial/Institutional Wood/Bark Waste Wood/Bark-fired Boiler 10300903 External Combustion Boilers Commercial/Institutional Wood/Bark Waste Wood-fired Boiler - Wet W10300908 External Combustion Boilers Commercial/Institutional Wood/Bark Waste Wood-fired Boiler - Dry Wo10300910 External Combustion Boilers Commercial/Institutional Wood/Bark Waste Fuel cell/Dutch oven boile10300911 External Combustion Boilers Commercial/Institutional Wood/Bark Waste Stoker boilers ** 10300912 External Combustion Boilers Commercial/Institutional Wood/Bark Waste Fluidized bed combustion 10500209 External Combustion Boilers Space Heaters Commercial/Institutional Wood 

2103011000 -- Commercial/Institutional; Kerosene; Total: All Combustor Types 

20300901 Internal Combustion Engines Commercial/Institutional Kerosene/Naphtha (Jet Fuel) Turbine: JP-4 20300908 Internal Combustion Engines Commercial/Institutional Kerosene/Naphtha (Jet Fuel) 

Turbine: Evaporative LossDelivery System) 

20300909 Internal Combustion Engines Commercial/Institutional Kerosene/Naphtha (Jet Fuel) Turbine: Exhaust 50100603 Waste Disposal 

Solid Waste Disposal - Government Fire Fighting Structure: Kerosene 
23 of 53

5. Emission Factors 

Table 6 presents the criteria pollutant emission factors that will be applied to fuel consumption 

estimates to calculate ICI combustion area source emissions. Except as noted below, all criteria 

air pollutant emission factors were from an EPA database of emission factors that will be used in 

preparing the 2008 nonpoint source NEI (Huntley, 2009).2 Wood combustion emission factors 

were compiled from AP-42 (EPA, 2003). Because there are no NH3 emission factors for ICI fuel 

combustion available in the 2008 NEI emission factor database, AP-42, or EPA’s WebFIRE, 

Pechan will use emission factors reported in an NH3 emissions Emission Inventory Improvement 

Program (EIIP) guidance document (Pechan, 2004). Pechan compared the 2008 NEI emission 

factors with those used to develop the last area source NEI (2002), as well as those listed by the 

Eastern Regional Technical Advisory Committee (ERTAC) for potential use by States in 

developing their area source inventories (ERTAC, 2009). With a few notable exceptions, the 

2008 NEI emission factors are the same as those used for the 2002 NEI.3 The PM emission 

factors for natural gas and LPG combustion are the major exceptions. Because the 2002 

emission factors were deemed too high because of artifact formation in the test method (method 

202) during stack testing, EPA developed a set of SCC-specific adjustment factors to apply to the 

2002 NEI to better reflect PM emissions from these fuels.4

 In preparation for the 2008 NEI, EPA 

developed revised natural gas and LPG PM emission factors by applying these adjustment 

factors to the 2002 NEI emission factors. 

Pechan does not plan to use the ERTAC emission factors that differ from the 2008 NEI factors 

because of the lack of documentation as to the source of the ERTAC factors. For PM emissions 

from ICI bituminous coal combustion, ERTAC specifically notes that their proposed emission 

factors reflect combustion in an uncontrolled overfeed stoker. The EPA PM emission factors for 

these categories, which were obtained from AP-42, reflect coal-fired boilers with controls 

(specifically, multiple cyclones with or without fly ash reinjection). Because an analysis of an 

EPA boiler database indicates that most small coal-fired boilers have PM controls (with cyclones 

as the most common type of control), EPA’s PM emission factors will be used in preparing the 

CENRAP emission inventory (ERG, 2002). 

For greenhouse gases (GHGs), Pechan will use the emission factors from EPA’s State 

Greenhouse Gas Inventory Tool, which incorporates the EIIP’s GHG emissions inventory 

guidelines for States (EPA, 2009). Table 7 displays the State-specific CO2 emission factors for 

each ICI combustion area source category, and Table 8 presents the N2O and CH4 emission 

factors by source category. Because SIT assumes that CO2 emissions from U.S. biomass 

combustion need not be inventoried, the SIT does not provide CO2 emission factors for ICI wood 

combustion.5 Therefore, Pechan will use the wood combustion CO2 emission factors reported in 

AP-42 (EPA, 2003).

 

2

 All criteria pollutant emission factors were rounded to two decimal places. 

3

 The 2002 NEI documentation provides citations to the AP-42 source for each emission factor (Pechan, 2006). 

4

 These factors reduce PM emissions by more than 90 percent. 

5

 As stated in the EIIP fossil fuel combustion CO2 emissions guidance: “...biomass fuels are generally grown on a 

sustainable basis. ... In cases where biomass fuels are not grown sustainably, GHG emissions are captured as a land 

use change.” 
Table 6. Criteria Pollutant Emission Factors for ICI Combustion Area Source Categ

SCC Description 

Emission 

Factor Units VOC NOx CO SO2 PM2.5-FIL PM10-

2102001000 Industrial Anthracite Coal lb/ton 0.3 9 0.6 39 * S% 0.48 * A% 1.1 * 2102002000 Industrial Bitum/Subbitum Coal lb/ton 0.05 11 5 38 * S% 1.4 2102004000 Industrial Distillate Oil lb/1000 gal 0.2 20 5 142 * S% 0.25 2102005000 Industrial Residual Oil lb/1000 gal 0.28 55 5 157 * S% 4.67 * (1.12 * S% + 0.37) 7.17 * (1

S% + 0

2102006000 Industrial Natural Gas lb/MMcf 5.5 100 84 0.6 0.11 2102007000 Industrial LPG 1 lb/1000 bbl 20.09 365.32 306.87 2.19 0.39 2102008000 Industrial Wood 2 lb/MMBtu 0.017 0.22 0.6 0.025 0.43 2102011000 Industrial Kerosene lb/1000 gal 0.19 19.29 4.82 142 * S% 0.24 2103001000 Comm/Inst Anthracite Coal lb/ton 0.3 9 0.6 39 * S% 0.48 * A% 1.1 * 2103002000 Comm/Inst Bitum/Subbitum Coal lb/ton 0.05 11 5 38 * S% 1.4 2103004000 Comm/Inst Distillate Oil lb/1000 gal 0.34 20 5 142 * S% 0.83 2103005000 Comm/Inst Residual Oil lb/1000 gal 1.13 55 5 157 * S% 1.92 * (1.12 * S% + 0.37) 5.17 * (1

S% + 0

2103006000 Comm/Inst Natural Gas lb/MMcf 5.5 100 84 0.6 0.11 2103007000 Comm/Inst LPG lb/1000 bbl 20.09 365.32 306.87 2.19 0.39 2103008000 Comm/Inst Wood 1 lb/MMBtu 0.017 0.22 0.6 0.025 0.43 2103011000 Comm/Inst Kerosene lb/1000 gal 0.33 19.29 4.82 142 * S% 0.8 Source: Unless otherwise noted, 2008 nonpoint source NEI (Huntley, 2009). Notes: 1 Emission factors from Commercial/Institutional LPG. 

2 Emission factors from AP-42, Section 1.6 (Wood Residue Combustion in Boilers). 3 Emission factor from Pechan, 2004; reported in lb/tons. 

In addition to above, PM2.5-PRI and PM10-PRI will be computed as the sum of condensable PM emissions and PM25-FIL/PM1

 lb = ton  gal = gallon  MMcf = million cubic feet  MMBtu = million British thermal units  bbl = barrels  S = sulfur content  A = ash content 
25 of 53

Table 7. Carbon Dioxide Emission Factors for Industrial and 

Commercial/Institutional Coal Combustion (lb/MMBtu) 

State Industrial CO2 Commercial/Institutional CO2

Arkansas 205.70 227.41 

Iowa 207.72 204.42 

Kansas 203.02 204.89 

Louisiana 204.78 227.41 

Minnesota 209.70 208.27 

Missouri 203.98 204.53 

Nebraska 209.66 212.70 

Oklahoma 205.99 205.92 

Texas 210.39 206.25 

 Source: EPA State Greenhouse Gas Inventory Tool (EPA, 2009). 

Table 8. Additional Greenhouse Gas Emission Factors for ICI Combustion Area 

Source Categories (lb/MMBtu) 

SCC Description CO2 CH4 N2O 

2102001000 Industrial Anthracite Coal see above 0.02210 0.00331 

2102002000 Industrial Bitum/Subbitum Coal see above 0.02210 0.00331 

2102004000 Industrial Distillate Oil 161.11 0.00663 0.00133 

2102005000 Industrial Residual Oil 173.54 0.00663 0.00133 

2102006000 Industrial Natural Gas 116.86 0.00209 0.00021 

2103007000 Industrial LPG 137.32 0.00663 0.00133 

2102008000 Industrial Wood 1 195 0.06280 0.00837 

2102011000 Industrial Kerosene 159.28 0.00663 0.00133 

2103001000 Comm/Inst Anthracite Coal see above 0.02210 0.00331 

2103002000 Comm/Inst Bitum/Subbitum Coal see above 0.02210 0.00331 

2103004000 Comm/Inst Distillate Oil 161.11 0.02210 0.00133 

2103005000 Comm/Inst Residual Oil 173.54 0.02210 0.00133 

2103006000 Comm/Inst Natural Gas 116.86 0.01047 0.00021 

2103007000 Comm/Inst LPG 139.00 0.02210 0.00133 

2103008000 Comm/Inst Wood 1 195 0.62802 0.00837 

2103011000 Comm/Inst Kerosene 159.28 0.02210 0.00133 

Source: Unless otherwise noted, EPA State Greenhouse Gas Inventory Tool (EPA, 2009). 1

 CO2 emission factors from AP-42, Section 1.6 - Wood Residue Combustion in Boilers. 

6. Coal Sulfur Content 

Under a forthcoming task (Task 4), Pechan will evaluate the reliability of various data sources 

for coal sulfur content before identifying the source(s) that will be used to estimate emissions in 

this project. Pechan will review potential coal sulfur content data sources, including: 
26 of 53

(1) information reported in the point source inventories of each State;6

 (2) the USGS’ U.S. Coal 

Quality Database (this is the ICI coal sulfur content source used in the 2002 NEI); (3) plant-level 

data from the Federal Energy Regulatory Commission’s (FERC) Form 423;7

 and (4) State-level 

data reported in EIA’s “Monthly Report of Cost and Quality of Fuels for Electric Plants.” 

Pechan will evaluate these and any other identified alternative data sources for use in this project 

to ensure that the data are as representative as possible with respect to consuming sector, 

geography, and time-frame. Any data sets that are deemed equally representative will next be 

evaluated with respect to level of confidence (i.e., a data source for which estimated coal content 

is based on more data points than other data sources will be deemed to have higher confidence, 

and therefore, the preferred data source). Pechan will prepare a memorandum identifying the 

coal content data sources that were reviewed and a priority ranking of preferred sources based on 

an evaluation of the aforementioned criteria. The memorandum will identify the preferred 

approach for characterizing the sulfur content of coal consumption for each ICI area source 

combustion source category, which will be incorporated into the Excel calculation templates. 

7. County Allocation Data 

After computing State-level emissions using the data described above, the project requires 

allocating these emissions to individual counties. There are two allocation approaches that 

CENRAP is evaluating for this step. The first, which has been used in past inventory efforts 

including the 2002 NEI, is based on each county’s proportion of total State employment for the 

energy-consuming sectors for each source category. The second is based on estimates of total 

energy consumption for each sector. For both approaches, the initial step is to identify the 

economic sectors associated with Industrial fuel combustion, and the economic sectors 

associated with Commercial/Institutional fuel combustion. 

Commercial/Institutional 

For area source Commercial/Institutional fuel combustion, the 2002 NEI used employment data 

in North American Industrial Classification System (NAICS) codes 42, 44-45, 51-54, 56, 61-62, 

71-72, and 81 to allocate EIA State Commercial sector energy consumption data to counties.8

 

These NAICS codes suggest that fuel combustion emissions for the following sectors are 

covered elsewhere in the NEI: Agriculture, Forestry, Fishing and Hunting; Mining; 

Construction; Manufacturing; Transportation and Warehousing; Management of Companies and 

Enterprises; and Public Administration. Meanwhile the EIIP area source method abstracts for 

Commercial/Institutional fuel combustion categories identify Standard Industrial Classification 

(SIC) codes 50-99 as representing the Commercial/Institutional sector. These SIC codes indicate 

that the following is the comprehensive list of non-Commercial sectors: Agriculture, Forestry, 

Fishing and Hunting; Mining; Construction; Manufacturing; and Transportation, 

Communications, Electric, Gas, and Sanitary Services. 

 

6

 Iowa has stated that they did not report coal sulfur content information in their 2002 point source inventory. 

7

 Note that these data include Commercial and Industrial combined heat and power producers whose total fossilfueled nameplate generating capacity is 50 or more megawatts. 

8

 These NAICS codes are also listed in ERTAC’s area source methodology worksheet (ERTAC, 2009). 
27 of 53

Documentation for the SEDS is not entirely clear on the NAICS codes associated with the 

Commercial sector, defining the Commercial sector as “an energy-consuming sector that consists 

of service-providing facilities and equipment of: businesses; Federal, State, and local 

governments; and other private and public organizations, such as religious, social, or fraternal 

groups. The Commercial sector includes institutional living quarters. It also includes sewage 

treatment facilities.” In an attempt to further clarify the NAICS codes associated with this 

sector, Pechan performed additional research into the original data sources that are used to create 

the SEDS. 

Because data for the SEDS originates with data collected from EIA fuel sector-specific surveys 

of energy suppliers,9

 Pechan reviewed these survey forms/instructions for further details on what 

SEDS considers Commercial sector use of each fuel. This review found that the 

surveys/guidance do not always provide further clarity. In addition, the EIA has admitted that 

energy suppliers may use their own account classifications as well as EIA guidance in 

determining whether a particular account belongs in the Residential, Commercial, Industrial, or 

Transportation sector. The only source of NAICS-code based EIA definitions of the Commercial 

energy sector is a “rough crosswalk” between Commercial building types and NAICS codes 

developed for EIA’s Commercial Building Energy Consumption Survey (CBECS). With the 

exception of NAICS code 814 (Private Households), this crosswalk links all NAICS codes 

between 42 and 92 with Commercial building energy consumption, suggesting that both the EIIP 

guidance and NEI definitions of the Commercial fuel combustion source category are missing 

some sectors, while also including one sector that should not be included (Private Households). 

In lieu of additional information, data for the CBECS-identified NAICS codes (42 though 92 

with exception of 814) will be used to allocate SEDS energy consumption data to individual 

counties. 

Industrial 

Although there are no EIIP guidance documents for area source Industrial fuel combustion, the 

2002 NEI used the Manufacturing sector NAICS codes (31-33) to represent this category. 

Unlike the Commercial sector, the SEDS documentation provides a clear listing of the NAICS 

codes associated with SEDS Industrial energy consumption data: “the industrial sector 

encompasses the following types of activity: Manufacturing (NAICS codes 31–33); Agriculture, 

Forestry, Fishing and Hunting (NAICS code 11); Mining, including Oil and Gas Extraction 

(NAICS code 21); and Construction (NAICS code 23).” As noted earlier, this indicates that a 

portion of Industrial sector consumption is already accounted for in other emission inventory 

sectors. It is expected that non-Manufacturing sector Industrial fuel consumption will largely be 

eliminated via the nonroad subtractions described earlier. Therefore, Pechan will not expand the 

list of NAICS codes used to represent the area source Industrial fuel combustion category 

beyond the Manufacturing sector NAICS codes (31-33). 

Standard Employment-Based Approach 

 

9

 For natural gas, for example – EIA-176 “Annual Report of Natural and Supplemental Gas Supply and 

Disposition.” 
28 of 53

In keeping with EIIP guidance and past EPA practice, employment data can be used to allocate 

State-level emission estimates to counties. Each year the Census Bureau releases County 

Business Patterns (CBP), a county level data set of employment by NAICS code (Census, 2009). 

The CBP county-level employment estimates for 2002 can be compiled for the appropriate 

NAICS codes noted above. Due to concerns with releasing confidential business information, 

the CBP withholds values for a given county/NAICS code if it would be possible to identify 

individual businesses from these values. In such cases, the CBP reports a letter code, 

representing a particular employment size range. To estimate data for withheld counties/NAICS 

codes, Pechan used the following procedure. 

1. County-level employment for counties with reported values are totaled by State for the 

applicable NAICS code. 

2. Value from step 1 is subtracted from the State employment value for the NAICS code. 

3. Each of the withheld counties is assigned an initial employment estimate reflecting the 

midpoint of the CBP range code (e.g., code A, which reflects 1-19 employees, is assigned an 

estimate of 10 employees). 

4. The initial employment estimates from step 3 are then summed to the State level. 

5. The value from step 2 is divided by the value from step 4 to yield an adjustment factor to 

apply to the initial employment estimates to yield employment values that will sum to the 

State employment total for the applicable NAICS code. 

6. The final county-level employment values are estimated by multiplying the initial 

employment estimates from step 3 by the step 5 adjustment factors. 

Example: NAICS 31-33 (Manufacturing) 

fipsstate fipscty naics empflag emp 

23 001 31---- 6,774 

23 003 31---- 3,124 

23 005 31---- 10,333 

23 007 31---- 1,786 

23 009 31---- 1,954 

23 011 31---- 2,535 

23 013 31---- 1,418 

23 015 31---- F 0 

23 017 31---- 2,888 

23 019 31---- 4,522 

23 021 31---- 948 

23 023 31---- I 0 

23 025 31---- 4,322 

23 027 31---- 1,434 

23 029 31---- 1,014 

23 031 31---- 9,749 

1. The total of employees not including counties 015 and 023 is 52,801. 

2. The State-level CBP reports 59,322 employees in NAICS 31----the difference is 6,521. 

3. County 015 is given a midpoint of 1,750 (since range code F is 1,000-2,499) and County 023 

is given a midpoint of 17,500. 
29 of 53

4. State total for these two counties is 19,250. 

5. 6,521/19,250 = 0.33875. 

6. The final employment estimate for county 015 is 1,750 * 0.33875 = 593. The county 023 

final employment estimate is computed as 17,500 * 0.33875 = 5,928. 

Energy Intensity-Adjusted Approach 

Employment-based county allocation methods lead to overrepresentation of energy consumption 

in counties with sectors that have high employment but low energy intensities (measured on a 

Btu per employee basis), and vice-versa. Therefore, Pechan recommended that CENRAP 

consider utilizing energy use per employee values by NAICS code to refine the employmentbased county allocation approach. Because State/NAICS code-level energy use data are not 

available, this approach relies on 2002 national energy consumption data by NAICS code as 

reported by EIA in Annual Energy Outlook (EIA, 2005). Energy intensity values are computed 

by dividing these Btu-based energy consumption estimates by 2002 national employment data by 

NAICS code. The resulting intensity values are then multiplied by county/NAICS code-level 

employment estimates to estimate total county energy consumption by NAICS code. These 

values are then summed for the appropriate Industrial and Commercial/Institutional fuel 

combustion NAICS codes. The resulting county-level total Industrial and total 

Commercial/Institutional energy consumption estimates can then be used to apportion State-level 

Industrial fuel combustion emissions and State-level Commercial/Institutional fuel combustion 

emissions to each county. 

Table 9 displays a comparison of the county-level allocation percentages computed for Missouri 

from the two methods. This table is sorted in descending order based on each county’s Industrial 

fuel combustion employment-based allocation percentage. The cells shaded in green indicate 

that the energy intensity-adjusted approach reflects a greater than 50 percent higher allocation of 

activity/emissions to the given county versus the employment-based approach. Similarly, cells 

shaded in tan indicate that the energy-based approach reflects an allocation that is more than 50 

percent lower than that resulting from the employment-based approach. The table shows that the 

Industrial sector allocations differ more substantially between the two methods in Missouri. 

Focusing on the Industrial sector allocation percentages for Jackson county, for example, overall 

Manufacturing sector employment is approximately 10 percent of the Missouri total. However, a 

much higher percentage of Missouri total Industrial sector energy consumption is estimated for 

this county (~17 percent). A closer look at the underlying data indicates that this county has a 

relatively high proportion of total State employment in the Chemicals and Paper industries that 

are the third and fifth highest energy-intensive manufacturing sector industries. Pechan will 

provide the information in Table 9 for all CENRAP States when it submits the Task 3 State-level 

fuel consumption estimates, which are due by April 17. 
30 of 53

Table 9. Comparison of County Allocation Approaches for Missouri 

County

Industrial Commercial/Institutional 

Employment Energy Ratio Employment Energy Ratio 

St. Louis 17.3% 14.9% 0.9 25.2% 21.8% 0.9

Jackson 10.3% 16.5% 1.6 16.2% 15.2% 0.9

City of St. Louis 8.3% 8.9% 1.1 11.9% 11.4% 1.0

Greene 5.2% 4.5% 0.9 6.0% 6.1% 1.0

St. Charles 4.6% 2.3% 0.5 4.0% 4.1% 1.0

Clay 4.6% 3.4% 0.7 3.3% 3.6% 1.1

Jasper 3.4% 2.5% 0.7 2.0% 2.0% 1.0

Franklin 3.2% 2.5% 0.8 1.0% 1.1% 1.1

Buchanan 2.3% 5.1% 2.2 1.5% 1.5% 1.0

Barry 2.0% 1.3% 0.6 0.4% 0.4% 1.0

Boone 1.7% 0.7% 0.4 2.8% 2.7% 0.9

Pettis 1.6% 1.6% 1.0 0.6% 0.7% 1.2

Cape Girardeau 1.6% 5.5% 3.4 1.6% 1.5% 1.0

Laclede 1.6% 0.4% 0.3 0.3% 0.4% 1.1

Jefferson 1.4% 2.4% 1.7 1.5% 1.8% 1.2

Newton 1.4% 1.2% 0.9 0.5% 0.6% 1.2

Howell 1.2% 0.3% 0.3 0.5% 0.6% 1.2

Cole 1.1% 0.5% 0.4 1.6% 1.5% 0.9

Butler 1.1% 0.4% 0.4 0.6% 0.6% 1.1

Perry 0.9% 0.5% 0.5 0.2% 0.2% 1.0

McDonald 0.9% 0.7% 0.7 0.1% 0.1% 1.3

Marion 0.8% 1.5% 1.8 0.4% 0.5% 1.1

St. Francois 0.8% 1.0% 1.3 0.7% 0.8% 1.0

New Madrid 0.8% 1.7% 2.1 0.1% 0.2% 1.6

Scott 0.8% 0.5% 0.6 0.6% 0.7% 1.1

Stoddard 0.8% 0.4% 0.5 0.3% 0.4% 1.3

Christian 0.7% 0.3% 0.4 0.4% 0.5% 1.2

Nodaway 0.6% 0.6% 1.0 0.3% 0.3% 1.1

Platte 0.6% 0.3% 0.5 1.8% 1.6% 0.9

Audrain 0.6% 0.3% 0.5 0.3% 0.3% 1.1

Phelps 0.6% 0.3% 0.4 0.6% 0.7% 1.3

Linn 0.6% 0.2% 0.4 0.1% 0.2% 1.1

Henry 0.5% 0.3% 0.5 0.2% 0.3% 1.3

Johnson 0.5% 0.3% 0.5 0.4% 0.5% 1.3

Crawford 0.5% 0.2% 0.4 0.2% 0.2% 1.3

Warren 0.5% 0.5% 0.9 0.2% 0.2% 1.1

Ste. Genevieve 0.5% 0.4% 0.8 0.1% 0.2% 1.2

Sullivan 0.5% 0.6% 1.2 0.0% 0.1% 1.4

Barton 0.5% 0.3% 0.6 0.1% 0.2% 1.4

Cass 0.5% 0.5% 1.1 0.7% 0.8% 1.2

Gasconade 0.5% 0.2% 0.5 0.1% 0.2% 1.3

Saline 0.5% 0.4% 0.8 0.3% 0.3% 1.2
31 of 53

County

Industrial Commercial/Institutional 

Employment Energy Ratio Employment Energy Ratio 

Lawrence 0.5% 0.2% 0.5 0.2% 0.4% 1.5

Randolph 0.5% 0.2% 0.5 0.3% 0.4% 1.1

Grundy 0.4% 0.3% 0.7 0.1% 0.2% 1.5

Adair 0.4% 0.2% 0.6 0.3% 0.4% 1.1

Lincoln 0.3% 0.1% 0.4 0.3% 0.4% 1.3

Vernon 0.3% 0.2% 0.4 0.2% 0.3% 1.4

Camden 0.3% 0.1% 0.4 0.6% 0.6% 1.1

Dunklin 0.3% 0.3% 0.8 0.3% 0.4% 1.2

Lafayette 0.3% 0.3% 0.9 0.3% 0.4% 1.2

Osage 0.3% 0.1% 0.4 0.1% 0.1% 1.4

Texas 0.3% 0.2% 0.5 0.2% 0.2% 1.5

Monroe 0.3% 0.1% 0.4 0.1% 0.1% 1.9

Miller 0.3% 0.1% 0.2 0.2% 0.3% 1.2

Webster 0.3% 0.6% 2.2 0.2% 0.2% 1.3

Moniteau 0.3% 0.2% 0.8 0.1% 0.1% 1.3

Callaway 0.3% 0.1% 0.4 0.4% 0.5% 1.2

Pemiscot 0.3% 0.3% 1.2 0.2% 0.2% 1.3

Polk 0.3% 0.1% 0.4 0.3% 0.4% 1.3

Dent 0.2% 0.6% 2.6 0.1% 0.2% 1.2

Livingston 0.2% 0.2% 0.9 0.2% 0.2% 1.2

Washington 0.2% 0.3% 1.3 0.1% 0.2% 1.6

Montgomery 0.2% 0.2% 0.9 0.1% 0.1% 1.4

Pike 0.2% 2.3% 10.5 0.2% 0.2% 1.4

Ripley 0.2% 0.1% 0.6 0.1% 0.1% 1.4

Wright 0.2% 0.1% 0.3 0.1% 0.2% 1.3

Morgan 0.2% 0.1% 0.3 0.1% 0.1% 1.3

Douglas 0.2% 0.1% 0.3 0.1% 0.1% 1.6

Ray 0.2% 0.4% 2.3 0.1% 0.2% 1.4

Cooper 0.2% 0.1% 0.5 0.2% 0.2% 1.3

Taney 0.2% 0.3% 1.5 0.9% 0.9% 1.0

Shannon 0.2% 0.1% 0.5 0.0% 0.0% 1.4

Macon 0.2% 0.3% 1.8 0.1% 0.2% 1.9

Ralls 0.2% 1.6% 10.4 0.1% 0.1% 1.6

Madison 0.2% 0.1% 0.6 0.1% 0.1% 1.3

Wayne 0.1% 0.1% 0.6 0.1% 0.1% 1.3

Dallas 0.1% 0.1% 0.8 0.1% 0.1% 1.0

Carroll 0.1% 0.1% 0.4 0.1% 0.1% 1.4

Bates 0.1% 0.1% 1.3 0.1% 0.2% 1.4

Lewis 0.1% 0.1% 0.5 0.1% 0.1% 1.5

Shelby 0.1% 0.1% 0.7 0.0% 0.1% 2.0

Benton 0.1% 0.1% 1.2 0.1% 0.1% 1.4

Reynolds 0.1% 0.1% 0.8 0.0% 0.1% 1.6

Oregon 0.1% 0.1% 0.8 0.1% 0.1% 1.4

Iron 0.1% 0.0% 0.4 0.1% 0.1% 1.4
32 of 53

County

Industrial Commercial/Institutional 

Employment Energy Ratio Employment Energy Ratio 

Mississippi 0.1% 0.0% 0.3 0.1% 0.1% 1.2

Gentry 0.1% 0.0% 0.3 0.1% 0.1% 1.3

Howard 0.1% 0.2% 2.1 0.1% 0.1% 1.4

Stone 0.1% 0.0% 0.3 0.2% 0.2% 1.2

Carter 0.1% 0.2% 2.7 0.0% 0.0% 1.4

Dade 0.1% 0.0% 0.5 0.1% 0.1% 1.6

Clinton 0.1% 0.0% 0.5 0.2% 0.2% 1.1

Pulaski 0.1% 0.0% 0.2 0.3% 0.4% 1.2

Cedar 0.1% 0.0% 0.5 0.1% 0.1% 1.4

Maries 0.1% 0.5% 8.7 0.1% 0.1% 1.4

Ozark 0.1% 0.0% 0.6 0.0% 0.1% 1.7

Daviess 0.0% 0.0% 0.2 0.0% 0.1% 1.6

Bollinger 0.0% 0.1% 2.3 0.1% 0.1% 1.5

Scotland 0.0% 0.0% 0.5 0.0% 0.1% 2.5

Holt 0.0% 0.2% 4.8 0.0% 0.1% 1.7

Clark 0.0% 0.0% 0.4 0.0% 0.1% 1.8

DeKalb 0.0% 0.2% 4.6 0.1% 0.1% 1.3

Putnam 0.0% 0.0% 1.7 0.0% 0.1% 2.0

Harrison 0.0% 0.0% 0.5 0.1% 0.1% 1.4

Chariton 0.0% 0.0% 0.5 0.1% 0.1% 1.5

Andrew 0.0% 0.0% 0.5 0.1% 0.1% 1.7

Atchison 0.0% 0.0% 0.5 0.1% 0.1% 1.3

Knox 0.0% 0.0% 0.5 0.0% 0.1% 1.8

Hickory 0.0% 0.0% 0.4 0.0% 0.1% 1.7

Worth 0.0% 0.0% 0.4 0.0% 0.0% 2.0

Caldwell 0.0% 0.0% 0.4 0.0% 0.1% 2.1

St. Clair 0.0% 0.0% 0.3 0.1% 0.1% 1.5

Mercer 0.0% 0.0% 0.5 0.0% 0.0% 1.5

Schuyler 0.0% 0.0% 0.2 0.0% 0.0% 2.1

8. Temporal Allocation Data 

The EPA provides national default temporal allocation data via the “temporal allocation” section 

of their Emissions Modeling Clearinghouse (EMCH). For all Industrial sector fuel types, the 

EPA default is for an equal distribution of annual activity across months. For the Commercial 

sector, the EPA default is for an equal distribution of annual activity across months for LPG and 

kerosene, but the EPA default distribution for all other fuel types is as displayed in Table 10. 
33 of 53

Table 10. EPA Default Commercial Fuel Combustion Sector Allocation 

Month % Allocation 

January 11.7 

February 11.7 

March 8.3 

April 8.3 

May 8.3 

June 5 

July 5 

August 5 

September 8.3 

October 8.3 

November 8.3 

December 11.7 

 Note: Excludes LPG and kerosene (equal 

distribution assumed throughout year). 

Pechan researched the availability of more representative (sector, geographic, and/or timespecific) energy consumption data than that used to develop the EMCH’s temporal allocation 

factors. The following summarizes the available information: 

 Natural Gas – State-level volume delivered data are available by month and sector 

(Industrial versus Commercial) for 2002; 

 Coal – national consumption data are available by month and sector (Industrial versus 

Commercial) for 2002; and 

 Petroleum products (i.e., distillate, residual, LPG, kerosene) – regional level product 

supplied data are available by month for 2002. 

Pechan was unable to identify a source reporting sub-annual consumption estimates for wood. 

Pechan plans to use EIA’s State-level natural gas deliveries data for 2002 to allocate the annual 

SEDS data to each month (EIA, 2009b). Given the limitations of the available coal and 

petroleum product data, and the lack of data for wood, Pechan plans to apply EPA’s monthly 

default profiles to allocate annual activity/emissions for these fuel types. Because Pechan was 

unable to identify any source of sub-monthly estimates of ICI energy consumption, the EPA 

default allocation profiles will be used to develop average weekday, average weekend day, and 

average weekly emission estimates for each month. 
34 of 53

C. CALCULATION TEMPLATES 

This section summarizes the draft templates that Pechan has produced to develop the ICI 

combustion area source emission estimates for CENRAP. CENRAP should not review the 

actual data in these draft templates at this time because some entries are currently missing or 

represent “dummy” placeholder values. Pechan will provide completed templates for CENRAP 

review by April 17 as required under Task 5. 

Template 1 – Adjust SEDS Fuel Consumption – this workbook, which reflects the discussion in 

sections B.1 through B.4, performs the following tasks: 

 Computes Industrial sector State-level non-fuel energy consumption estimates by fuel 

type by applying MECS-based non-fuel percentages to the SEDS total Industrial sector 

energy consumption estimates; 

 Subtracts Industrial and Commercial sector State-level distillate and LPG consumption 

estimates from a (forthcoming) NONROAD model run for 2002. 

 Converts the result of the steps above from their original units to the emission factor 

units; 

 Performs the point source subtractions using 2002 CENRAP point source inventory data 

and the ICI area source combustion SCC to point source SCC crosswalk; 

Template 2 – Apply Emission Factors – this workbook accompanies the discussion in Sections 

B.5 and B.6 of criteria pollutant and GHG emission factors and associated coal sulfur content 

assumptions. Reflecting the fact that some emission factors differ by type of coal, this template 

also estimates the proportion of Industrial and Commercial/Institutional coal that is anthracite 

versus bituminous/subbituminous in each State. This template will ultimately report the 

estimated sulfur content of coal consumed in each State. 

Template 3 – County Allocations – this workbook, which reflects the Section B.7 discussion, 

contains the data used to compute both sets of county allocation data (i.e., the county 

employment data and the total county energy consumption data). This template currently 

develops actual allocation data for Missouri counties. Ultimately, this template will only include 

county data for the allocation method that CENRAP chooses to implement in this project. This 

template also calculates county-level emissions from the Template 2 State-level emission 

estimates. 

Template 4 – Temporal Allocation – this workbook, which reflects the discussion in Section 

B.8, provides the data that will be used to allocate annual county emissions to monthly, average 

weekly, average weekday, and average weekend day time periods. It will ultimately perform the 

necessary calculations to estimate emissions in each period. 
35 of 53

D. REFERENCES 

Census, 2009: U.S. Census Bureau, County Business Patterns, accessed from 

http://www.census.gov/epcd/cbp/index.html, U.S. Department of Commerce, March 

2009. 

EIA, 2009a: Energy Information Administration, “State Energy Data System (SEDS): 

Consumption, Price, and Expenditure Estimates,” U.S. Department of Energy, accessed 

from http://www.eia.doe.gov/emeu/states/_seds.html, March 2009. 

EIA, 2009b: Energy Information Administration, “Natural Gas Navigator – Natural Gas 

Consumption by End Use,” U.S. Department of Energy, accessed from 

http://tonto.eia.doe.gov/dnav/ng/ng_cons_sum_dcu_nus_m.htm, March 2009. 

EIA, 2007: Energy Information Administration, “2002 Energy Consumption by Manufacturers

Data Tables,” 2002 Manufacturing Energy Consumption Survey, U.S. Department of 

Energy, accessed from 

http://www.eia.doe.gov/emeu/mecs/mecs2002/data02/shelltables.html, issued 

January 2007. 

EIA, 2005: Energy Information Administration, Annual Energy Outlook 2005 with Projections 

to 2025, U.S. Department of Energy, accessed from 

http://www.eia.doe.gov/oiaf/archive/aeo05/index.html, issued January 2005. 

EPA, 2009: U.S. Environmental Protection Agency, “Emission Inventory Improvement 

Program, Technical Report Series Volume 8, Estimating Greenhouse Gas Emissions,” 

accessed from http://www.epa.gov/ttn/chief/eiip/techreport/volume08/index.html, 

March 2009. 

EPA, 2003: U.S. Environmental Protection Agency, AP 42, Compilation of Air Pollutant 

Emission Factors, Fifth Edition, “Volume I, Chapter 1: External Combustion Sources, 

Section 1.6-Wood Residue in Combustion Boilers,” accessed from 

http://www.epa.gov/ttn/chief/ap42/ch01/final/c01s06.pdf, September 2003. 

ERG, Inc., 2002: Eastern Research Group, “Development of Model Units for the Industrial/

Commercial/Institutional Boilers and Process Heaters National Emission Standards for 

Hazardous Air Pollutants,” prepared for U.S. Environmental Protection Agency, Office 

of Air Quality Planning and Standards, October 2002. 

ERTAC, 2009: Eastern Regional Technical Advisory Committee, “Area Source Comparability, 

Comparability Spreadsheet with Week 1 Modifications,” accessed from 

http://www.ertac.us/, March 2009. 

Huntley, 2009: Huntley, Roy, U.S. Environmental Protection Agency, “SCCs & emission 

factors to be used in 2008 NEI to Bollman March 13 2009.mdb [electronic file],” 

March 13, 2009. 
36 of 53

Lorenz, 2009: Lorenz, Thomas, Energy Information Administration, personal communication 

with Andy Bollman, E.H. Pechan & Associates, Inc., March 19, 2009. 

Pechan/CEP, 2005: E.H. Pechan & Associates, Inc. and Carolina Environmental Program, 

“Consolidation of Emissions Inventories (Schedule 9; Work Item 3), Final,” prepared for 

the Central Regional Air Planning Association, April 28, 2005. 

Pechan, 2006: E.H. Pechan & Associates, Inc., “Documentation for the Final 2002 Nonpoint 

Sector (Feb 06 version) National Emission Inventory for Criteria and Hazardous Air 

Pollutants,” prepared for U.S. Environmental Protection Agency, Office of Air Quality 

Planning and Standards, July 2006. 

Pechan, 2004: E.H. Pechan & Associates, Inc. “Estimating Ammonia Emissions from 

Anthropogenic Nonagricultural Sources - Draft Final Report,” prepared for the Emission 

Inventory Improvement Program, April 2004. 
37 of 53

ATTACHMENT: PRELIMINARY SUMMARY OF 

2002 POINT SOURCE ANNUAL THROUGHPUT DATA 

The following table reports 2002 annual point source throughput data associated with the ICI 

area source categories. The table is sorted in descending order by CENRAP State and area SCC. 

Cells that are shaded in light blue indicate potentially suspect entries.
Area_SCC SCC_2 Area SCC_3 StateName Throughput ThroughputUnits

Material

Code Mate

2102001000 Industrial Anthracite Coal ARKANSAS 1,167,890 TON 640 Anthra2102002000 Industrial Bituminous/Subbituminous Coal ARKANSAS 3,153,027 TON 663 Bitum2102004000 Industrial Distillate Oil ARKANSAS 8,255,280 E3GAL 44 Diesel 2102004000 Industrial Distillate Oil ARKANSAS 0 E3GAL 57 Distilla2102004000 Industrial Distillate Oil ARKANSAS E3GAL 58 Distilla2102004000 Industrial Distillate Oil ARKANSAS 2,136,217 E3GAL 823 Distilla2102004000 Industrial Distillate Oil ARKANSAS 6,408,642 E3GAL 825 Distilla2102005000 Industrial Residual Oil ARKANSAS 224,941 E3GAL 279 Resid2102005000 Industrial Residual Oil ARKANSAS 13,587,658 E3GAL 923 Resid2102005000 Industrial Residual Oil ARKANSAS E3GAL 924 Residu2102006000 Industrial Natural Gas ARKANSAS 184,838,095 E6FT3 209 Natura2102006000 Industrial Natural Gas ARKANSAS 2102007000 Industrial Liquified Petroleum Gas (LPG) ARKANSAS E3GAL 178 Liquifi2102008000 Industrial Wood ARKANSAS 56,092,213 TON 15 Wood 2102008000 Industrial Wood ARKANSAS 21,798,710 TON 943 Wood/2103004000 Commercial/Institutional Distillate Oil ARKANSAS E3GAL 57 Distilla2103006000 Commercial/Institutional Natural Gas ARKANSAS 23,912,086 E6FT3 209 Natura2103008000 Commercial/Institutional Wood ARKANSAS 7,655,765 TON 15 Wood 2102001000 Industrial Anthracite Coal IOWA 24 E3GAL 255 Propa2102001000 Industrial Anthracite Coal IOWA 98,368 TON 645 Ash 2102002000 Industrial Bituminous/Subbituminous Coal IOWA 30,950,000 LB 561 Sludge 2102002000 Industrial Bituminous/Subbituminous Coal IOWA 87,110 TON 323 Subbit2102002000 Industrial Bituminous/Subbituminous Coal IOWA 3,741,706 TON 717 Coal 2102004000 Industrial Distillate Oil IOWA 1,039 E3GAL 44 Diesel 2102004000 Industrial Distillate Oil IOWA 0 E3GAL 56 Distilla2102004000 Industrial Distillate Oil IOWA 926 E3GAL 58 Distilla2102004000 Industrial Distillate Oil IOWA 2 E3GAL 255 Propa2102004000 Industrial Distillate Oil IOWA 42 E3GAL 823 Distilla2102004000 Industrial Distillate Oil IOWA 0 E3LB 44 Diesel 2102004000 Industrial Distillate Oil IOWA 5,599 E6BTU 44 Diesel 2102004000 Industrial Distillate Oil IOWA 0 E6BTU 56 Distilla2102004000 Industrial Distillate Oil IOWA 0 E6BTU 209 Natura2102004000 Industrial Distillate Oil IOWA 42 E6BTU 823 Distilla2102004000 Industrial Distillate Oil IOWA 90 E6FT3 209 Natura
Area_SCC SCC_2 Area SCC_3 StateName Throughput ThroughputUnits

Material

Code Mate

2102004000 Industrial Distillate Oil IOWA 8 E6GAL 58 Distilla2102004000 Industrial Distillate Oil IOWA 2 E6GAL 823 Distilla2102004000 Industrial Distillate Oil IOWA 341,800,000 FT3 209 Natura2102004000 Industrial Distillate Oil IOWA 4,758 GAL 5 Water 2102004000 Industrial Distillate Oil IOWA 35,967 GAL 44 Diesel 2102004000 Industrial Distillate Oil IOWA 613 GAL 56 Distilla2102004000 Industrial Distillate Oil IOWA 459 GAL 58 Distilla2102004000 Industrial Distillate Oil IOWA 330 GAL 209 Natura2102004000 Industrial Distillate Oil IOWA 10,262 GAL 255 Propa2102004000 Industrial Distillate Oil IOWA 339 GAL 823 Distilla2102004000 Industrial Distillate Oil IOWA 14,123 HP-HR 58 Distilla2102004000 Industrial Distillate Oil IOWA 2,681 HR 44 Diesel 2102004000 Industrial Distillate Oil IOWA 29 HR 209 Natura2102004000 Industrial Distillate Oil IOWA 138 HR 268 Raw M2102004000 Industrial Distillate Oil IOWA 0 KL 44 Diesel 2102004000 Industrial Distillate Oil IOWA 0 TON 44 Diesel 2102004000 Industrial Distillate Oil IOWA 0 TON 58 Distilla2102004000 Industrial Distillate Oil IOWA 1,628 TON 268 Raw M2102004000 Industrial Distillate Oil IOWA 2102005000 Industrial Residual Oil IOWA 14 E3GAL 44 Diesel 2102005000 Industrial Residual Oil IOWA 0 E3GAL 923 Residu2102005000 Industrial Residual Oil IOWA 438 E3GAL 2102005000 Industrial Residual Oil IOWA 0 GAL 127 Gasol2102005000 Industrial Residual Oil IOWA 978,215 GAL 279 Resid2102005000 Industrial Residual Oil IOWA 6,000 GAL 823 Distilla2102005000 Industrial Residual Oil IOWA 188,565 GAL 923 Residu2102005000 Industrial Residual Oil IOWA 2102006000 Industrial Natural Gas IOWA 6,690 E3FT3 209 Natura2102006000 Industrial Natural Gas IOWA 11 E3GAL 58 Distilla2102006000 Industrial Natural Gas IOWA 18,353,512 E6BTU 209 Natura2102006000 Industrial Natural Gas IOWA 248,378 E6BTU 268 Raw M2102006000 Industrial Natural Gas IOWA 69,899 E6FT3 127 Gasol2102006000 Industrial Natural Gas IOWA 2,851,074 E6FT3 209 Natura2102006000 Industrial Natural Gas IOWA 0 E6FT3 225 Paint 2102006000 Industrial Natural Gas IOWA 21 E6FT3 268 Raw M
Area_SCC SCC_2 Area SCC_3 StateName Throughput ThroughputUnits

Material

Code Mate

2102006000 Industrial Natural Gas IOWA 119 E6FT3 315 Starch 2102006000 Industrial Natural Gas IOWA 0 E6LB 268 Raw M2102006000 Industrial Natural Gas IOWA 0 E6LB 281 Resin 2102006000 Industrial Natural Gas IOWA 1,818,653,437 FT3 209 Natura2102006000 Industrial Natural Gas IOWA 1,335,666,448 FT3S 209 Natura2102006000 Industrial Natural Gas IOWA 1,320 GAL 189 Materi2102006000 Industrial Natural Gas IOWA 73,408 GAL 225 Paint 2102006000 Industrial Natural Gas IOWA 46 GAL 255 Propa2102006000 Industrial Natural Gas IOWA 0 GAL 268 Raw M2102006000 Industrial Natural Gas IOWA 4 GAL 952 Solven2102006000 Industrial Natural Gas IOWA 0 GAL 973 ABS P2102006000 Industrial Natural Gas IOWA 30,621 HR 516 Metal 2102006000 Industrial Natural Gas IOWA 7,000 LB 189 Materi2102006000 Industrial Natural Gas IOWA 0 LB 225 Paint 2102006000 Industrial Natural Gas IOWA 13,848 LB 268 Raw M2102006000 Industrial Natural Gas IOWA 0 LB 281 Resin 2102006000 Industrial Natural Gas IOWA 317 LB 516 Metal 2102006000 Industrial Natural Gas IOWA 344,238 TON 209 Natura2102006000 Industrial Natural Gas IOWA 14 TON 225 Paint 2102006000 Industrial Natural Gas IOWA 40,230 TON 268 Raw M2102006000 Industrial Natural Gas IOWA 0 TON 289 Sand 2102006000 Industrial Natural Gas IOWA 54 TON 303 Soil 2102006000 Industrial Natural Gas IOWA 162 TON 315 Starch 2102006000 Industrial Natural Gas IOWA 0 TON 561 Sludge 2102006000 Industrial Natural Gas IOWA 0 TON 580 Sulfur 2102006000 Industrial Natural Gas IOWA 209 Natura2102006000 Industrial Natural Gas IOWA 2102007000 Industrial Liquified Petroleum Gas (LPG) IOWA 0 E3GAL 178 Liquifi2102007000 Industrial Liquified Petroleum Gas (LPG) IOWA 0 E3GAL 255 Propa2102007000 Industrial Liquified Petroleum Gas (LPG) IOWA 2,977 E6BTU 209 Natura2102007000 Industrial Liquified Petroleum Gas (LPG) IOWA 0 E6BTU 255 Propa2102007000 Industrial Liquified Petroleum Gas (LPG) IOWA 0 E6FT3 209 Natura2102007000 Industrial Liquified Petroleum Gas (LPG) IOWA 0 E6LB 268 Raw M2102007000 Industrial Liquified Petroleum Gas (LPG) IOWA 3 E6LB 281 Resin 2102007000 Industrial Liquified Petroleum Gas (LPG) IOWA 7,399 GAL 255 Propa
Area_SCC SCC_2 Area SCC_3 StateName Throughput ThroughputUnits

Material

Code Mate

2102007000 Industrial Liquified Petroleum Gas (LPG) IOWA 2102008000 Industrial Wood IOWA 13,154 HR 124 Fuel 2102008000 Industrial Wood IOWA 6,497 TON 268 Raw M2102008000 Industrial Wood IOWA 0 TON-YR 717 Coal 2102011000 Industrial Kerosene IOWA 0 E3GAL 162 Keros2102011000 Industrial Kerosene IOWA 13,717 TON 189 Mater2103002000 Commercial/Institutional Bituminous/Subbituminous Coal IOWA 142,485 TON 717 Coal 2103004000 Commercial/Institutional Distillate Oil IOWA 26 E3GAL 44 Diesel 2103004000 Commercial/Institutional Distillate Oil IOWA 0 E3GAL 56 Distilla2103004000 Commercial/Institutional Distillate Oil IOWA 0 E3GAL 58 Distilla2103004000 Commercial/Institutional Distillate Oil IOWA 18 E3GAL 268 Raw M2103004000 Commercial/Institutional Distillate Oil IOWA 162 E3GAL 823 Distilla2103004000 Commercial/Institutional Distillate Oil IOWA 1,033 GAL 44 Diesel 2103004000 Commercial/Institutional Distillate Oil IOWA 34,758 GAL 58 Distilla2103004000 Commercial/Institutional Distillate Oil IOWA 0 TON 44 Diesel 2103004000 Commercial/Institutional Distillate Oil IOWA 2103005000 Commercial/Institutional Residual Oil IOWA 1 E3GAL 58 Distilla2103005000 Commercial/Institutional Residual Oil IOWA 21 E3GAL 2103005000 Commercial/Institutional Residual Oil IOWA 332,184 GAL 279 Resid2103005000 Commercial/Institutional Residual Oil IOWA 4,340 GAL 923 Resid2103006000 Commercial/Institutional Natural Gas IOWA 51,606 BTU 209 Natura2103006000 Commercial/Institutional Natural Gas IOWA 719,333 E3FT3 209 Natura2103006000 Commercial/Institutional Natural Gas IOWA 1 E3GAL 58 Distilla2103006000 Commercial/Institutional Natural Gas IOWA 6 E3GAL 209 Natura2103006000 Commercial/Institutional Natural Gas IOWA 0 E6BTU 209 Natura2103006000 Commercial/Institutional Natural Gas IOWA 28 E6FT3 127 Gasol2103006000 Commercial/Institutional Natural Gas IOWA 28 E6FT3 189 Materi2103006000 Commercial/Institutional Natural Gas IOWA 465,334 E6FT3 209 Natura2103006000 Commercial/Institutional Natural Gas IOWA 16 E6FT3 268 Raw M2103006000 Commercial/Institutional Natural Gas IOWA 0 E6GAL 823 Distilla2103006000 Commercial/Institutional Natural Gas IOWA 8,169,622 FT3 209 Natura2103006000 Commercial/Institutional Natural Gas IOWA 576 GAL 58 Distilla2103006000 Commercial/Institutional Natural Gas IOWA 0 GAL 209 Natura2103006000 Commercial/Institutional Natural Gas IOWA 831 GAL 255 Propa2103006000 Commercial/Institutional Natural Gas IOWA 24 HR 44 Diesel 
Area_SCC SCC_2 Area SCC_3 StateName Throughput ThroughputUnits

Material

Code Mate

2103006000 Commercial/Institutional Natural Gas IOWA 13,632 TON 209 Natura2103006000 Commercial/Institutional Natural Gas IOWA 0 TON 225 Paint 2103006000 Commercial/Institutional Natural Gas IOWA 16,178 TON 724 Coke 2103006000 Commercial/Institutional Natural Gas IOWA 2103007000 Commercial/Institutional Liquified Petroleum Gas (LPG) IOWA 0 E3GAL 178 Liquifi2103007000 Commercial/Institutional Liquified Petroleum Gas (LPG) IOWA 0 E3GAL 255 Propa2103007000 Commercial/Institutional Liquified Petroleum Gas (LPG) IOWA 0 E3GAL 268 Raw M2103007000 Commercial/Institutional Liquified Petroleum Gas (LPG) IOWA 15 E6FT3 209 Natura2103007000 Commercial/Institutional Liquified Petroleum Gas (LPG) IOWA 0 E6GAL 268 Raw M2103007000 Commercial/Institutional Liquified Petroleum Gas (LPG) IOWA 88,575 GAL 255 Propa2103008000 Commercial/Institutional Wood IOWA 7,142 TON 15 Wood 2102004000 Industrial Distillate Oil KANSAS 1,148 E3GAL 44 Diese2102004000 Industrial Distillate Oil KANSAS 92,275 E3GAL 56 Distilla2102004000 Industrial Distillate Oil KANSAS 83 E3GAL 823 Distilla2102004000 Industrial Distillate Oil KANSAS 2,437 E3HP-HR 945 Work 2102004000 Industrial Distillate Oil KANSAS 22,979 E6BTU 44 Diese2102004000 Industrial Distillate Oil KANSAS 488 E6BTU 58 Distilla2102004000 Industrial Distillate Oil KANSAS 1,082,040 HP-HR 945 Work 2102004000 Industrial Distillate Oil KANSAS 233 HR 209 Natura2102004000 Industrial Distillate Oil KANSAS 716 HR 945 Work 2102004000 Industrial Distillate Oil KANSAS 10,248,064 KW-HR 828 Electr2102004000 Industrial Distillate Oil KANSAS 0 2102005000 Industrial Residual Oil KANSAS 380 E3GAL 922 Residu2102005000 Industrial Residual Oil KANSAS 3,402 E3GAL 923 Residu2102005000 Industrial Residual Oil KANSAS 48 E6BTU 923 Residu2102006000 Industrial Natural Gas KANSAS 287 E3FT3 209 Natura2102006000 Industrial Natural Gas KANSAS 19 E3GAL 189 Materi2102006000 Industrial Natural Gas KANSAS 2,594,753 E3HP-HR 945 Work 2102006000 Industrial Natural Gas KANSAS 17,010,214 E6BTU 209 Natura2102006000 Industrial Natural Gas KANSAS 282,631 E6FT3 209 Natura2102006000 Industrial Natural Gas KANSAS 39 EACH 189 Materi2102006000 Industrial Natural Gas KANSAS 288,425,458 HP-HR 945 Work 2102006000 Industrial Natural Gas KANSAS 100 HR 127 Gasol2102006000 Industrial Natural Gas KANSAS 856,039 HR 209 Natura2102006000 Industrial Natural Gas KANSAS 100,217 HR 945 Work 
Area_SCC SCC_2 Area SCC_3 StateName Throughput ThroughputUnits

Material

Code Mate

2102006000 Industrial Natural Gas KANSAS 269 LB 209 Natura2102006000 Industrial Natural Gas KANSAS 10,000 LB 635 Ammo2102006000 Industrial Natural Gas KANSAS 7 TON 209 Natura2102006000 Industrial Natural Gas KANSAS 25 TON 305 Solven2102006000 Industrial Natural Gas KANSAS 0 2102007000 Industrial Liquified Petroleum Gas (LPG) KANSAS 5 E3GAL 178 Liquifi2102007000 Industrial Liquified Petroleum Gas (LPG) KANSAS 54 E3GAL 178 Liquifi2102007000 Industrial Liquified Petroleum Gas (LPG) KANSAS 0 E3GAL 189 Materi2102007000 Industrial Liquified Petroleum Gas (LPG) KANSAS 99 E3GAL 255 Propa2103004000 Commercial/Institutional Distillate Oil KANSAS 22 E3GAL 44 Diesel 2103004000 Commercial/Institutional Distillate Oil KANSAS 29 E3GAL 823 Distilla2103004000 Commercial/Institutional Distillate Oil KANSAS 0 2103006000 Commercial/Institutional Natural Gas KANSAS 3,150 E6FT3 209 Natura2103006000 Commercial/Institutional Natural Gas KANSAS 0 EACH 189 Materi2103006000 Commercial/Institutional Natural Gas KANSAS 107,768 HR 209 Natura2103006000 Commercial/Institutional Natural Gas KANSAS 7,200 HR 945 Work 2103006000 Commercial/Institutional Natural Gas KANSAS 0 2102002000 Industrial Bituminous/Subbituminous Coal LOUISIANA 2102004000 Industrial Distillate Oil LOUISIANA 2102005000 Industrial Residual Oil LOUISIANA 2102006000 Industrial Natural Gas LOUISIANA 2102007000 Industrial Liquified Petroleum Gas (LPG) LOUISIANA 2102008000 Industrial Wood LOUISIANA 2103004000 Commercial/Institutional Distillate Oil LOUISIANA 2103005000 Commercial/Institutional Residual Oil LOUISIANA 2103006000 Commercial/Institutional Natural Gas LOUISIANA 2103007000 Commercial/Institutional Liquified Petroleum Gas (LPG) LOUISIANA 2102002000 Industrial Bituminous/Subbituminous Coal MINNESOTA 6,138,274 E6BTU 142 Heat 2102002000 Industrial Bituminous/Subbituminous Coal MINNESOTA 10,584 HR 830 Equipm2102002000 Industrial Bituminous/Subbituminous Coal MINNESOTA 582,249 TON 323 Subbit2102002000 Industrial Bituminous/Subbituminous Coal MINNESOTA 81,870 TON 663 Bitum2102004000 Industrial Distillate Oil MINNESOTA 232 E3GAL 44 Diesel 2102004000 Industrial Distillate Oil MINNESOTA 4,003 E3GAL 57 Distilla2102004000 Industrial Distillate Oil MINNESOTA 1,071 E3GAL 823 Distilla2102004000 Industrial Distillate Oil MINNESOTA 535 E3GAL 825 Distilla
Area_SCC SCC_2 Area SCC_3 StateName Throughput ThroughputUnits

Material

Code Mate

2102004000 Industrial Distillate Oil MINNESOTA 586 E6BTU 142 Heat 2102004000 Industrial Distillate Oil MINNESOTA 1,353,017 GAL 57 Distilla2102004000 Industrial Distillate Oil MINNESOTA 342,565 GAL 823 Distilla2102004000 Industrial Distillate Oil MINNESOTA 2102005000 Industrial Residual Oil MINNESOTA 362 E3GAL 279 Residu2102005000 Industrial Residual Oil MINNESOTA 370 E3GAL 922 Residu2102005000 Industrial Residual Oil MINNESOTA 21,526 E3GAL 923 Residu2102005000 Industrial Residual Oil MINNESOTA 34,637 E6BTU 142 Heat 2102006000 Industrial Natural Gas MINNESOTA 6,400,498 E6BTU 142 Heat 2102006000 Industrial Natural Gas MINNESOTA 39,046 E6FT3 209 Natura2102006000 Industrial Natural Gas MINNESOTA 7,395,200 FT3 209 Natura2102006000 Industrial Natural Gas MINNESOTA 19,936,121,225 GAL 209 Natura2102006000 Industrial Natural Gas MINNESOTA 155,328 HR 830 Equipm2102007000 Industrial Liquified Petroleum Gas (LPG) MINNESOTA 94,000 BTU 142 Heat 2102007000 Industrial Liquified Petroleum Gas (LPG) MINNESOTA 1,212 E3GAL 255 Propa2102007000 Industrial Liquified Petroleum Gas (LPG) MINNESOTA 209 E3GAL 675 Butan2102007000 Industrial Liquified Petroleum Gas (LPG) MINNESOTA 274 E6BTU 142 Heat 2102007000 Industrial Liquified Petroleum Gas (LPG) MINNESOTA 266,584 GAL 255 Propa2102007000 Industrial Liquified Petroleum Gas (LPG) MINNESOTA 626 HR 830 Equipm2102008000 Industrial Wood MINNESOTA 4,675,962 E6BTU 142 Heat 2102008000 Industrial Wood MINNESOTA 16,467 HR 830 Equipm2102008000 Industrial Wood MINNESOTA 120,057 TON 15 Wood 2102008000 Industrial Wood MINNESOTA 89,216 TON 943 Wood/2102011000 Industrial Kerosene MINNESOTA 12 E3GAL 159 Jet Fu2103001000 Commercial/Institutional Anthracite Coal MINNESOTA 2103002000 Commercial/Institutional Bituminous/Subbituminous Coal MINNESOTA 2,648 E6BTU 142 Heat 2103002000 Commercial/Institutional Bituminous/Subbituminous Coal MINNESOTA 184,324 TON 323 Subbit2103002000 Commercial/Institutional Bituminous/Subbituminous Coal MINNESOTA 51,658 TON 663 Bitum2103004000 Commercial/Institutional Distillate Oil MINNESOTA 1,197 E3GAL 57 Distilla2103004000 Commercial/Institutional Distillate Oil MINNESOTA 1,334 E3GAL 823 Distilla2103004000 Commercial/Institutional Distillate Oil MINNESOTA 29 E3GAL 825 Distilla2103005000 Commercial/Institutional Residual Oil MINNESOTA 1,695 E3GAL 922 Residu2103005000 Commercial/Institutional Residual Oil MINNESOTA 3,303 E3GAL 923 Residu2103006000 Commercial/Institutional Natural Gas MINNESOTA 8,623,850 E6BTU 142 Heat 2103006000 Commercial/Institutional Natural Gas MINNESOTA 19,921 E6FT3 209 Natura
Area_SCC SCC_2 Area SCC_3 StateName Throughput ThroughputUnits

Material

Code Mate

2103006000 Commercial/Institutional Natural Gas MINNESOTA 174,979 HR 830 Equipm2103006000 Commercial/Institutional Natural Gas MINNESOTA 2103007000 Commercial/Institutional Liquified Petroleum Gas (LPG) MINNESOTA 3,033 E3GAL 255 Propa2103007000 Commercial/Institutional Liquified Petroleum Gas (LPG) MINNESOTA 4,614 E6BTU 142 Heat 2103008000 Commercial/Institutional Wood MINNESOTA 1,096 TON 15 Wood 2103008000 Commercial/Institutional Wood MINNESOTA 246,551 TON 943 Wood/2102002000 Industrial Bituminous/Subbituminous Coal MISSOURI 20,843 TON 174 Lime 2102002000 Industrial Bituminous/Subbituminous Coal MISSOURI 0 TON 189 Materi2102002000 Industrial Bituminous/Subbituminous Coal MISSOURI 271,022 TON 663 Bitum2102002000 Industrial Bituminous/Subbituminous Coal MISSOURI 2102004000 Industrial Distillate Oil MISSOURI 0 E2LB 253 Produ2102004000 Industrial Distillate Oil MISSOURI 77,335 E3GAL 44 Diesel 2102004000 Industrial Distillate Oil MISSOURI 1,146 E3GAL 56 Distilla2102004000 Industrial Distillate Oil MISSOURI 3,922 E3GAL 57 Distilla2102004000 Industrial Distillate Oil MISSOURI 1,462,931 E3GAL 58 Distilla2102004000 Industrial Distillate Oil MISSOURI 0 E3GAL 352 Toluen2102004000 Industrial Distillate Oil MISSOURI 641 E3GAL 823 Distilla2102004000 Industrial Distillate Oil MISSOURI 0 E3GAL 825 Distilla2102004000 Industrial Distillate Oil MISSOURI 0 E3GAL 868 Liquid 2102004000 Industrial Distillate Oil MISSOURI 0 E3GAL 908 Petrol2102004000 Industrial Distillate Oil MISSOURI 27 E3GAL-YR 58 Distilla2102004000 Industrial Distillate Oil MISSOURI 0 E3GAL-YR 127 Gasol2102004000 Industrial Distillate Oil MISSOURI 10 E3GAL-YR 192 Metha2102004000 Industrial Distillate Oil MISSOURI 20 E6FT3 209 Natura2102004000 Industrial Distillate Oil MISSOURI 1 E6GAL 4 Waste2102004000 Industrial Distillate Oil MISSOURI 0 EACH 364 Unit 2102004000 Industrial Distillate Oil MISSOURI 235 MILE 368 Vehicl2102004000 Industrial Distillate Oil MISSOURI 24 TON 133 Grain 2102004000 Industrial Distillate Oil MISSOURI 0 TON 174 Lime 2102004000 Industrial Distillate Oil MISSOURI 1,462,933 TON 189 Materi2102004000 Industrial Distillate Oil MISSOURI 1 TON 189 Materi2102004000 Industrial Distillate Oil MISSOURI 13 TON 253 Produ2102004000 Industrial Distillate Oil MISSOURI 226 TON 268 Raw M2102004000 Industrial Distillate Oil MISSOURI 0 TON 311 Soybe2102004000 Industrial Distillate Oil MISSOURI 5 TON 849 Hot M
Area_SCC SCC_2 Area SCC_3 StateName Throughput ThroughputUnits

Material

Code Mate

2102004000 Industrial Distillate Oil MISSOURI 2102005000 Industrial Residual Oil MISSOURI 345 E3GAL 279 Resid2102005000 Industrial Residual Oil MISSOURI 9 E3GAL 922 Residu2102005000 Industrial Residual Oil MISSOURI 1,512 E3GAL 923 Residu2102005000 Industrial Residual Oil MISSOURI 2 E3GAL 924 Residu2102005000 Industrial Residual Oil MISSOURI 30 TON 174 Lime 2102005000 Industrial Residual Oil MISSOURI 0 TON 189 Materi2102005000 Industrial Residual Oil MISSOURI 0 TON 849 Hot M2102005000 Industrial Residual Oil MISSOURI 2102006000 Industrial Natural Gas MISSOURI 84 ACRE-YR 320 Storag2102006000 Industrial Natural Gas MISSOURI 0 BALE 740 Cotton 2102006000 Industrial Natural Gas MISSOURI 25 E2LB 253 Produ2102006000 Industrial Natural Gas MISSOURI 16 E3EACH 654 Batter2102006000 Industrial Natural Gas MISSOURI 0 E3FT3 189 Materi2102006000 Industrial Natural Gas MISSOURI 15 E3GAL 44 Diesel 2102006000 Industrial Natural Gas MISSOURI 63 E3GAL 56 Distilla2102006000 Industrial Natural Gas MISSOURI 233 E3GAL 57 Distilla2102006000 Industrial Natural Gas MISSOURI 56 E3GAL 58 Distilla2102006000 Industrial Natural Gas MISSOURI 21 E3GAL 178 Liquifi2102006000 Industrial Natural Gas MISSOURI 24 E3GAL 189 Materi2102006000 Industrial Natural Gas MISSOURI 133 E3GAL 255 Propa2102006000 Industrial Natural Gas MISSOURI 123 E3GAL 823 Distilla2102006000 Industrial Natural Gas MISSOURI 0 E3GAL-YR 58 Distilla2102006000 Industrial Natural Gas MISSOURI 79 E3GAL-YR 127 Gasol2102006000 Industrial Natural Gas MISSOURI 2 E3GAL-YR 374 Crude 2102006000 Industrial Natural Gas MISSOURI 11 E3GAL-YR 865 Jet Ke2102006000 Industrial Natural Gas MISSOURI 190 E3GAL-YR 868 Liquid 2102006000 Industrial Natural Gas MISSOURI 5,202 E3GAL-YR 908 Petrol2102006000 Industrial Natural Gas MISSOURI 254,692 E6FT3 209 Natura2102006000 Industrial Natural Gas MISSOURI 0 EACH 364 Unit 2102006000 Industrial Natural Gas MISSOURI 206 EACH 368 Vehicl2102006000 Industrial Natural Gas MISSOURI 97 EACH 712 Circuit 2102006000 Industrial Natural Gas MISSOURI 26 GAL 151 Ink 2102006000 Industrial Natural Gas MISSOURI 12 GAL 189 Mater2102006000 Industrial Natural Gas MISSOURI 9 GAL 305 Solven
Area_SCC SCC_2 Area SCC_3 StateName Throughput ThroughputUnits

Material

Code Mate

2102006000 Industrial Natural Gas MISSOURI 375 GAL 720 Coatin2102006000 Industrial Natural Gas MISSOURI 5 MILE 368 Vehicl2102006000 Industrial Natural Gas MISSOURI 32 TON 93 Ethyle2102006000 Industrial Natural Gas MISSOURI 59 TON 133 Grain 2102006000 Industrial Natural Gas MISSOURI 153 TON 174 Lime 2102006000 Industrial Natural Gas MISSOURI 1,780 TON 189 Materi2102006000 Industrial Natural Gas MISSOURI 456 TON 189 Materi2102006000 Industrial Natural Gas MISSOURI 15 TON 224 P2O5 2102006000 Industrial Natural Gas MISSOURI 121 TON 253 Produ2102006000 Industrial Natural Gas MISSOURI 73 TON 268 Raw M2102006000 Industrial Natural Gas MISSOURI 2 TON 289 Sand 2102006000 Industrial Natural Gas MISSOURI 293 TON 305 Solven2102006000 Industrial Natural Gas MISSOURI 348 TON 306 Solven2102006000 Industrial Natural Gas MISSOURI 65 TON 311 Soybe2102006000 Industrial Natural Gas MISSOURI 0 TON 315 Starch 2102006000 Industrial Natural Gas MISSOURI 6 TON 516 Metal 2102006000 Industrial Natural Gas MISSOURI 116 TON 516 Metal 2102006000 Industrial Natural Gas MISSOURI 0 TON 673 Brick 2102006000 Industrial Natural Gas MISSOURI 1 TON 699 Charg2102006000 Industrial Natural Gas MISSOURI 13 TON 723 Coatin2102006000 Industrial Natural Gas MISSOURI 2102007000 Industrial Liquified Petroleum Gas (LPG) MISSOURI 4,610 E3GAL 178 Liquifi2102007000 Industrial Liquified Petroleum Gas (LPG) MISSOURI 12,560 E3GAL 255 Propa2102007000 Industrial Liquified Petroleum Gas (LPG) MISSOURI 9 E3GAL-YR 374 Crude 2102007000 Industrial Liquified Petroleum Gas (LPG) MISSOURI 122 E3GAL-YR 908 Petrol2102007000 Industrial Liquified Petroleum Gas (LPG) MISSOURI 2 E3LB 77 Electro2102007000 Industrial Liquified Petroleum Gas (LPG) MISSOURI 9 GAL 305 Solven2102007000 Industrial Liquified Petroleum Gas (LPG) MISSOURI 39 GAL 720 Coatin2102007000 Industrial Liquified Petroleum Gas (LPG) MISSOURI 186 MILE 368 Vehicl2102007000 Industrial Liquified Petroleum Gas (LPG) MISSOURI 0 TON 15 Wood 2102007000 Industrial Liquified Petroleum Gas (LPG) MISSOURI 0 TON 133 Grain 2102007000 Industrial Liquified Petroleum Gas (LPG) MISSOURI 37 TON 189 Materi2102007000 Industrial Liquified Petroleum Gas (LPG) MISSOURI 29 TON 268 Raw M2102007000 Industrial Liquified Petroleum Gas (LPG) MISSOURI 10 TON 291 Sawdu2102007000 Industrial Liquified Petroleum Gas (LPG) MISSOURI 0 TON 306 Solven
Area_SCC SCC_2 Area SCC_3 StateName Throughput ThroughputUnits

Material

Code Mate

2102007000 Industrial Liquified Petroleum Gas (LPG) MISSOURI 0 TON 723 Coatin2102007000 Industrial Liquified Petroleum Gas (LPG) MISSOURI 0 TON 849 Hot M2102007000 Industrial Liquified Petroleum Gas (LPG) MISSOURI 2102008000 Industrial Wood MISSOURI 13,640 MILE 368 Vehicl2102008000 Industrial Wood MISSOURI 435,597 TON 15 Wood 2102008000 Industrial Wood MISSOURI 366 TON 18 Wood 2102008000 Industrial Wood MISSOURI 133,848 TON 943 Wood/2102011000 Industrial Kerosene MISSOURI 115 E3GAL 159 Jet Fu2102011000 Industrial Kerosene MISSOURI 0 GAL 305 Solven2102011000 Industrial Kerosene MISSOURI 0 MILE 368 Vehicl2102011000 Industrial Kerosene MISSOURI 2103002000 Commercial/Institutional Bituminous/Subbituminous Coal MISSOURI 20,339 TON 663 Bitum2103002000 Commercial/Institutional Bituminous/Subbituminous Coal MISSOURI 2103004000 Commercial/Institutional Distillate Oil MISSOURI 0 E3GAL 44 Diesel 2103004000 Commercial/Institutional Distillate Oil MISSOURI 423 E3GAL 56 Distilla2103004000 Commercial/Institutional Distillate Oil MISSOURI 1,295 E3GAL 57 Distilla2103004000 Commercial/Institutional Distillate Oil MISSOURI 8 E3GAL 127 Gasol2103004000 Commercial/Institutional Distillate Oil MISSOURI 26,744 E3GAL 823 Distilla2103004000 Commercial/Institutional Distillate Oil MISSOURI 6 E3GAL 825 Distilla2103004000 Commercial/Institutional Distillate Oil MISSOURI 12 E6FT3 209 Natura2103004000 Commercial/Institutional Distillate Oil MISSOURI 0 MILE 368 Vehicl2103004000 Commercial/Institutional Distillate Oil MISSOURI 1 TON 180 Logs 2103004000 Commercial/Institutional Distillate Oil MISSOURI 0 TON 253 Produ2103004000 Commercial/Institutional Distillate Oil MISSOURI 1 TON 291 Sawdu2103004000 Commercial/Institutional Distillate Oil MISSOURI 0 TON 306 Solven2103004000 Commercial/Institutional Distillate Oil MISSOURI 2103005000 Commercial/Institutional Residual Oil MISSOURI 719 E3GAL 279 Resid2103005000 Commercial/Institutional Residual Oil MISSOURI 11 E3GAL 922 Resid2103005000 Commercial/Institutional Residual Oil MISSOURI 32 E3GAL 923 Resid2103005000 Commercial/Institutional Residual Oil MISSOURI 4 E3GAL-YR 58 Distilla2103005000 Commercial/Institutional Residual Oil MISSOURI 2 E6FT3 209 Natura2103005000 Commercial/Institutional Residual Oil MISSOURI 2103006000 Commercial/Institutional Natural Gas MISSOURI 8 ACRE-YR 320 Storag2103006000 Commercial/Institutional Natural Gas MISSOURI 125 E3GAL 57 Distilla2103006000 Commercial/Institutional Natural Gas MISSOURI 60 E3GAL 58 Distilla
Area_SCC SCC_2 Area SCC_3 StateName Throughput ThroughputUnits

Material

Code Mate

2103006000 Commercial/Institutional Natural Gas MISSOURI 1 E3GAL 127 Gasol2103006000 Commercial/Institutional Natural Gas MISSOURI 1 E3GAL 305 Solven2103006000 Commercial/Institutional Natural Gas MISSOURI 282 E3GAL-YR 58 Distilla2103006000 Commercial/Institutional Natural Gas MISSOURI 69 E3GAL-YR 127 Gasol2103006000 Commercial/Institutional Natural Gas MISSOURI 40,033 E6FT3 209 Natura2103006000 Commercial/Institutional Natural Gas MISSOURI 62 GAL 189 Materi2103006000 Commercial/Institutional Natural Gas MISSOURI 141 GAL 720 Coatin2103006000 Commercial/Institutional Natural Gas MISSOURI 95 MILE 368 Vehicl2103006000 Commercial/Institutional Natural Gas MISSOURI 30 TON 65 Dried 2103006000 Commercial/Institutional Natural Gas MISSOURI 5 TON 129 Glaze 2103006000 Commercial/Institutional Natural Gas MISSOURI 29 TON 133 Grain 2103006000 Commercial/Institutional Natural Gas MISSOURI 17 TON 151 Ink 2103006000 Commercial/Institutional Natural Gas MISSOURI 0 TON 180 Logs 2103006000 Commercial/Institutional Natural Gas MISSOURI 41 TON 189 Materi2103006000 Commercial/Institutional Natural Gas MISSOURI 6 TON 224 P2O5 2103006000 Commercial/Institutional Natural Gas MISSOURI 16 TON 253 Produ2103006000 Commercial/Institutional Natural Gas MISSOURI 355 TON 306 Solven2103006000 Commercial/Institutional Natural Gas MISSOURI 39 TON 308 Solven2103006000 Commercial/Institutional Natural Gas MISSOURI 8 TON 874 Medic2103006000 Commercial/Institutional Natural Gas MISSOURI 2103007000 Commercial/Institutional Liquified Petroleum Gas (LPG) MISSOURI 25 E3GAL 178 Liquifi2103007000 Commercial/Institutional Liquified Petroleum Gas (LPG) MISSOURI 24,781 E3GAL 255 Propa2103007000 Commercial/Institutional Liquified Petroleum Gas (LPG) MISSOURI 9 E6FT3 209 Natura2103007000 Commercial/Institutional Liquified Petroleum Gas (LPG) MISSOURI 1 TON 253 Produ2103007000 Commercial/Institutional Liquified Petroleum Gas (LPG) MISSOURI 2103008000 Commercial/Institutional Wood MISSOURI 25,448 TON 15 Wood 2103008000 Commercial/Institutional Wood MISSOURI 128 TON 943 Wood/2102002000 Industrial Bituminous/Subbituminous Coal NEBRASKA 45,820 TON 2102004000 Industrial Distillate Oil NEBRASKA 137,269 E3GAL 2102004000 Industrial Distillate Oil NEBRASKA 2102005000 Industrial Residual Oil NEBRASKA 268 E3GAL 2102006000 Industrial Natural Gas NEBRASKA 319,058 E3FT3 2102006000 Industrial Natural Gas NEBRASKA 7,733,748 E6FT3 2102006000 Industrial Natural Gas NEBRASKA 232 MASS 1 Waste 2102006000 Industrial Natural Gas NEBRASKA 
Area_SCC SCC_2 Area SCC_3 StateName Throughput ThroughputUnits

Material

Code Mate

2102007000 Industrial Liquified Petroleum Gas (LPG) NEBRASKA 48 E3GAL 2102008000 Industrial Wood NEBRASKA 1,141 TON 2103004000 Commercial/Institutional Distillate Oil NEBRASKA 0 E3GAL 2103006000 Commercial/Institutional Natural Gas NEBRASKA 168,142 E6FT3 2103006000 Commercial/Institutional Natural Gas NEBRASKA 22 MASS 1 Waste 2103006000 Commercial/Institutional Natural Gas NEBRASKA 2103007000 Commercial/Institutional Liquified Petroleum Gas (LPG) NEBRASKA 4,866 E3GAL 2103008000 Commercial/Institutional Wood NEBRASKA 9,398 TON 2102001000 Industrial Anthracite Coal OKLAHOMA 645 2102002000 Industrial Bituminous/Subbituminous Coal OKLAHOMA 2,181,492 2102004000 Industrial Distillate Oil OKLAHOMA 25,021 2102005000 Industrial Residual Oil OKLAHOMA 1,463 2102006000 Industrial Natural Gas OKLAHOMA 10,908,513 2102007000 Industrial Liquified Petroleum Gas (LPG) OKLAHOMA 0 2102008000 Industrial Wood OKLAHOMA 114,619 2103004000 Commercial/Institutional Distillate Oil OKLAHOMA 21 2103006000 Commercial/Institutional Natural Gas OKLAHOMA 228,899 2102002000 Industrial Bituminous/Subbituminous Coal TEXAS 2102004000 Industrial Distillate Oil TEXAS 2102005000 Industrial Residual Oil TEXAS 2102006000 Industrial Natural Gas TEXAS 2102007000 Industrial Liquified Petroleum Gas (LPG) TEXAS 2102008000 Industrial Wood TEXAS 2102011000 Industrial Kerosene TEXAS 2103004000 Commercial/Institutional Distillate Oil TEXAS 2103006000 Commercial/Institutional Natural Gas TEXAS 2103007000 Commercial/Institutional Liquified Petroleum Gas (LPG) TEXAS 2103008000 Commercial/Institutional Wood TEXAS 2103011000 Commercial/Institutional Kerosene TEXAS 
Appendix A-6 

Inspection/Maintenance Input Table Development Protocol for MOVES for Counties in the 

St. Louis Ozone Nonattainment Area 

EPA has technical guidance on appropriate input assumptions and sources of data for the use of 

MOVES 2010 in State Implementation Plan 

(http://www.epa.gov/otaq/models/moves/420b10023.pdf). Section 3.10 of this guidance 

document explains the appropriate assumptions and methods to be used when developing the I/M 

input table for MOVES 2010. This guidance has been followed in the development of I/M input 

Tables 2 – 6 at the end of this document. This document outlines the approach used to develop 

each parameter of these I/M input tables in MOVES. The goal in developing these I/M input 

tables is to accurately reflect the actual I/M program being implemented in the St. Louis 

nonattainment area. 

Pollutant Process ID 

To begin development of the I/M input table, the default data for the I/M input table for St. Louis 

County was exported from the MOVES county database manager. The default data included 

four different I/M test types. However, the actual St. Louis area only had two different test types 

(On-board diagnostics) OBD tests for the exhaust and evaporative systems. In the default I/M 

input table, these were the only two types of tests that were “turned on” along with the 

appropriate pollutant process IDs that would be impacted by each test. Therefore, the pollutant 

process IDs that were included in the default table for the two OBD tests were the same pollutant 

process IDs used in the I/M input table for the St. Louis nonattainment area. The other two tests 

included in the default data along with their associated pollutant process IDs were still included 

in the I/M input table, but they were “turned off”. 

Source Type ID 

The St. Louis I/M program includes passenger cars and also trucks with a gross vehicle weight 

rating of 8,500 lbs. or less. Therefore, the three source type IDs included in the I/M input table 

for the St. Louis nonattainment area are passenger cars, passenger trucks, and light commercial 

trucks (IDs = 21, 31, and 32). 

Fuel Type ID 

The St. Louis I/M program is applicable to both gasoline and diesel vehicles; however, MOVES 

only calculates an I/M benefit for gasoline vehicles. Therefore, the fuel type ID for gasoline was 

the only uel type ID used in the I/M input table for the St. Louis nonattainment area. 

Inspection Frequency 
The St. Louis I/M program requires that emission be tested every two years, so the inspection 

frequency ID that represents biennial tests (ID = 2) was used in the I/M input table for the OBD 

tests applicable to the St. Louis nonattainment area. 

Test Standards 

The St. Louis I/M program is a centralized program with OBD tests for exhaust and evaporative 

systems on the vehicles. Therefore, the test standard IDs for exhaust OBD check and the 

evaporative system OBD check (IDs = 43 and 51) were used in the I/M input table for the St. 

Louis nonattainment area. 

I/M Program ID 

This is an arbitrary number developed by the MOVES user to define a unique test given for 

vehicles within a range of model years. Therefore, I/M program IDs were arbitrarily assigned to 

the various unique tests within the St. Louis I/M program. 

Beginning and Ending Model Years 

The St. Louis I/M program applies to gasoline vehicles with a model year of 1996 or later and it 

also applies to diesel vehicles with a model year of 1997 or later. Since the emissions inspection 

is required biennially, the ending model year would always be two years less than the emissions 

inventory year that is being developed. Therefore, for the tests for gasoline vehicles, the 

beginning model year is 1996 and the ending model year is two years earlier than the year for 

which MOVES is being run, and the for diesel vehicles the beginning model year is 1997 and 

the ending model year is two years earlier than the year for which MOVES is being run. 

Compliance Factor 

According to page 39 of the MOVES guidance document the compliance factor is calculated 

with the following equation: 

Compliance Factor = percent compliance rate x (100 – percent waiver rate) x regulatory 

class coverage adjustment. 

Therefore, in order to calculate the compliance factor for each source type included in the I/M 

program, the compliance rate, waiver rate, and regulatory class coverage adjustment needed to be 

determined. These three values were determined by the processes described below and then the 

compliance factors for each source type were calculated with the equation written above. 

Compliance Rate 

The compliance rate was calculated with the following equation: 

Compliance Rate = Number of vehicles that were tested over a two year period (2008 – 2009) / 

Population of vehicles that is theoretically subject to I/M during the same period. 
In order to determine the compliance rate, as it compares to the source type population by model 

year, the population of vehicles that is theoretically subject to I/M first needed to be determined. 

In May 2009, the Missouri Department of Revenue (DOR) Vehicle Registration database was 

queried and a VIN decoder was used to separate the vehicle counts into Mobile 6.2 vehicle 

classes by model year. In the St. Louis nonattainment area, the Mobile 6.2 vehicle classes that 

are subject to I/M include 1996 and newer light duty gasoline vehicles, light duty gasoline trucks 

Class 1, light duty gasoline trucks Class 2, light duty gasoline trucks Class 3, light duty gasoline 

trucks Class 4, as well as 1997 and newer light duty diesel vehicles, light duty diesel trucks Class 

1, light duty diesel trucks Class 2, light duty diesel trucks Class 3, and light duty diesel trucks 

Class 4. Table 1 below shows the total combined population of these 10 vehicle classes within 

the appropriate model years by county in the St. Louis nonattainment area according the May 

2009 DOR data. 

Table 1. Vehicles Theoretically Subject to the I/M Program in the St. Louis Nonattainment Area

 1996 and later 1997 and later 

County Light Duty Gas (1996 and newer) Light Duty Diesel (1997 and newer) 

Franklin 73,300 328

Jefferson 150,998 484

St Charles 238,672 589

St Louis City 144,871 345

St Louis County 756,978 1,653

Total 1,364,819 3,399

Total Count 1,368,218 

The Air Program also queried the I/M report generator to determine the total number of vehicles, 

which had their emissions tested at least once from January 1, 2008 through December 31, 2009. 

The query also included the total number of vehicles that received waivers during the same time 

period. Table 2 below, was generated with data from this query. 

Table 2. Initially Tested Vehicles that Received a Waiver in the St. Louis I/M Program 

from January 1, 2008 through December 31, 2009 
Using the data from Tables 1 and 2 above the compliance rate is calculated for the St. Louis I/M 

Program with the following equation: 

 Compliance Rate: (1,344,747 / 1,368,218) x 100% = 98.28% 

Waiver Rate 

The waiver rate is the percentage of vehicles that fail an initial I/M test and do not pass a retest, 

but do receive a certificate of compliance. The waiver rate was determined by dividing the 

number of vehicles that received waivers from January 1, 2008 through December 31, 2009 by 

the total number of vehicles that were tested at least once during the same time period. 

Therefore, the waiver rate was calculated for the St. Louis I/M Program with the following 

equation: 

 Waiver Rate: (4,761 / 1,344,747) X 100% = 0.35% 

Regulatory Class Coverage Adjustment 

The regulatory class coverage adjustment is an adjustment that accounts for the fraction of 

vehicles within a source type that are covered by the I/M program. Since the I/M program in St. 

Louis exempts vehicles with a gross vehicle weight rating above 8,500 lbs., the compliance 

factor needs to reflect the percentage of vehicles in the source types subject to I/M that are 

exempt because of their GVWR. Table A.3 in the Appendix of the MOVES Technical Guidance 

Document was used to develop adjustments to the compliance factor to account for this 

discrepancy. The adjustments are percentages of vehicle miles traveled by the various regulatory 

weight classes within a source type. The corresponding adjustment factors used for the three 

source categories are as follow: 

 Passenger cars: 100% 

 Passenger Trucks: 94% 

 Light Commercial Trucks: 88% 
Calculating the Compliance Factor 

Based on the calculations listed above the compliance factor for each source category impacted 

by the I/M program in St. Louis is listed below. 

Passenger cars: 98.28% x (100% - 0.35%) x 100% = 97.94%

Passenger Trucks: 98.28% x (100% - 0.35%) x 94% = 92.06%

Light Commercial Trucks: 98.28% x (100% - 0.35%) x 88% = 86.18%