Annual Air Emissions Inventory
2011 Air Emissions Inventory
Question and Answers
- Who must report?
- What do I have to report?
- When do I have to report my emissions?
- Are there forms or software to use to report my annual air emissions inventory?
- How should I calculate my emission estimates?
- Where can I find emission factors?
- How did DEP develop the default emission factors?
- I believe we made a calculation error in a previous year. What should I do?
- Should actual sulfur content of fuel be reported or the Chapter 106 allowable fuel sulfur content?
- What other facilities are subject to greenhouse gas reporting?
- When calculating greenhouse gas emissions, do I use dry or wet weight of wood?
An annual air emissions inventory is required by every facility that is licensed by the Department to emit criteria pollutants at or above the limits established in DEP Rules, Chapter 137, "Emission Statements." Stationary sources must report air emissions when emissions of one or more of those pollutants exceed the minimum reporting threshold listed below.
|Carbon Monoxide (CO)||75 tons per year|
|Sulfur Dioxide (SO 2 )||40 tons per year|
|Volatile Organic Compounds (VOCs)||25 tons per year|
|Nitrogen Oxides (NOx)||25 tons per year|
|Fine Particulate Matter (PM 2.5 )||15 tons per year|
|Fine Particulate Matter (PM 10 )||15 tons per year|
|Lead (Pb)||0.1 tons per year|
|Ammonia (NH 3 )||50 tons per year|
Annually, facilities must report emissions of all the criteria air pollutants listed above and greenhouse gases.
DEP Rules, Chapter 137 lists four specific greenhouse gases and two broad classes for which emissions must be reported. The four specific greenhouse gases are carbon dioxide, methane, nitrous oxide, and sulfur hexafluoride. The two broad classes of greenhouse gases are hydrofluorocarbons, such as those used as refrigerants, and perfluorocarbons, such as those used in the semiconductor manufacturing industry.
- emitted at or above the minimum reporting threshold described in DEP Rules, Chapter 137, "Emission Statements;" or
- where actual emissions are not known, either used, processed, or manufactured at or above that same minimum reporting threshold. For the purposes of this reporting, "manufacture" includes any hazardous air pollutant coincidentally manufactured, such as byproducts of a process or compounds resulting from combustion.
And, since the 2008 annual air emissions inventory, in addition to the requirements above, a facility must also report emissions of the following thirteen hazardous air pollutants for all fuel burning or combustion equipment only , regardless of the minimum reporting threshold.
- Arsenic and arsenic compounds;
- Cadmium and cadmium compounds;
- Chromium and chromium compounds;
- Cobalt and cobalt compounds;
- Manganese and manganese compounds;
- Mercury and mercury compounds;
- Nickel and nickel compounds; and
- Polycyclic organic matter.
Facilities subject to reporting must file their annual air emissions inventory with the DEP by May15th of the year following the inventory year. For example, a facility would file a report detailing emissions from calendar year 2010 by May 15, 2011.
Hazardous air pollutants emissions are collected every third year and must be included again in the 2011 emissions inventory which must be reported by May 15, 2012.
Facilities in Maine use a web-based software program called the Maine Air Emissions Inventory Reporting System or MAIRIS. Users are required to register on paper prior to their first use. Please visit the MAIRIS page for registration forms, user manuals and information on upcoming training programs.
Chapter 137, Section 5 provides a seven-step hierarchy for emission estimation methods.
- For sources with specification CEMs/PEMs monitoring systems that are required by statute, regulation, or license condition, emission data generated by these systems shall serve as the basis for emissions reported in the Chapter 137 inventory;
- For sources not subject to #1 above and for which reference method emission testing that has been deemed by the Department to be representative of current and normal operating conditions, emission data from such testing shall serve as the basis for estimating emissions reported in the Chapter 137 inventory;
- For sources not subject to either #1 or #2, emissions reported pursuant to this Chapter shall be estimated and reported on the basis of a facility-specific emission factor approved by the Department;
- For sources not subject to either #1, #2 or #3, emissions reported pursuant to this Chapter shall be estimated and reported on the basis of EPA-published emission factors, where available;
- For sources not subject to either #1, #2, #3 or #4, emissions reported pursuant to this Chapter shall be estimated and reported based on emissions factors from other industry and trade groups based on sound science, where available;
- For sources not subject to either #1, #2, #3, #4 or #5, emissions reported pursuant to this Chapter shall be estimated and reported based on default emission factors published by the Department, where available; or
- For sources not subject to any of the above sections, emissions reported pursuant to this Chapter shall be estimated and reported based on best engineering judgement.
When determining how to estimate your emissions, you should consider the method in #1 before #2, #2 before #3, and so on.
Emission factors come from many sources. U.S. EPA's Factor Information Retrieval System (FIRE) database of emission factors is now available online at http://cfpub.epa.gov/oarweb/index.cfm?action=fire.main . The FIRE Data System contains more than 17,000 AP-42-rated factors, as well as approximately 4,400 unrated emissions factors that EPA recommends for use. U.S. EPA has converted the existing database program (version 6.25) to a web-based application (WebFIRE) to allow easier public access and for FIRE to be updated more frequently. You can search for available emission factors by SCC or by simple phrase.
Facilities can also contact their Air Licensing Engineer for assistance with emission factors.
Maine DEP has also published default emission factors which facilities may use to report emissions of hazardous air pollutants. These factors were used to pre-populate the thirteen required HAPs for select fuel-burning and combustion-related process units in the data sets created for the 2008 emissions inventory. Facility owners and operators may choose to use the default emission factors and to accept the HAP pollutant estimates, or provide their own estimate (using an alternative emission factor or other estimation method), when completing their Satellite i-Steps submittal. We will not require that the default factors be used - we are simply providing them as a way to pre-populate the pollutant records and as tool to help facilities meet the new requirements of Chapter 137.
Greenhouse gas inventories are still evolving and the Department will accept any emission factor with proper documentation. The three primary sources of emission factors are:
- World Resources Institute (WRI)/World Business Council for Sustainable Development (WBSCD) - These groups have published the most widely-used greenhouse gas emission factors. These factors are included in NCASI's Pulp and Paper workbook, the Wood Products workbook (Note: the NCASI website is not compatible with the Firefox browser);
- U.S. Environmental Protection Agency, AP-42 - AP-42, the primary source of emission factors for criteria pollutants, also has greenhouse gas emission factors for selected processes; and
- U.S. Dept. of Energy, Energy Information Administration - The DOE publishes primarily CO2 emission factors for an exhaustive list of fuels.
Stack test data and other industry-specific documents can be submitted with calculations to document emission factors.
When developing the default emission factors for the thirteen HAPs, DEP reviewed already available factors from EPA, trade groups and source testing in Maine. The DEP identified equipment and processes described by numerous source classification codes (SCCs) for which no published emission factors were available. We understand that many facilities have equipment and processes described by these SCCs for which HAP emission reporting is required. To aid facility owners and operators in meeting the Chapter 137 requirements, the Department identified emission factors for other related SCCs that we would be willing to accept when used to estimate emissions for equipment and processes for which no other, better emission factor is available. We recognize that they may be low quality factors when applied in this manner, and we strongly encourage owners and operators to conduct source testing or otherwise determine more accurate emission factors for their facilities.
If you believe that a calculation error was made in a previous reporting year, you should submit a corrected emissions inventory and new certification statement. There is no fee or penalty for providing more accurate information.
Weighted, annual average sulfur content, as calculated from records of fuel deliveries, should be reported under Chapter 137, rather than the Chapter 106 allowable fuel sulfur content.
Greenhouse gas emissions reporting is also required of:
- All electrical power transmission and distribution plants that emit any amount of sulfur hexafluoride (SF 6 ), and
- All greenhouse gas manufacturing facilities.
That depends. The WRI/WBSCD emission factors assume dry weight with approximately 12% moisture content for wood or 8,000 Btu/lb of wood. The U.S. EPA, AP-42 emission factors assume a 50% moisture content or 4,500 Btu/lb of wood. Facilities should use the factor most applicable to their needs or perform appropriate conversions.