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Criteria Pollutants: Reporting Requirements
Questions and Answers
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2008 Air Emissions Inventory Information


Who must report?

DEP Rules, Chapter 137, "Emission Statements," requires annual emissions reports from stationary sources which are licensed by the Department to emit criteria pollutants into the air. 

Stationary sources must report emissions of all criteria pollutants when emissions of one or more of those pollutants exceed the minimum reporting threshold listed below.

Criteria Pollutant Minimum Reporting Threshold
Carbon Monoxide (CO) 75 tons per year
Sulfur Dioxide (SO2) 40 tons per year
Volatile Organic Compounds (VOCs) 25 tons per year
Nitrogen Oxides (NOx) 25 tons per year
Fine Particulate Matter (PM2.5) 15 tons per year
Fine Particulate Matter (PM10) 15 tons per year
Lead (Pb) 0.1 tons per year
Ammonia (NH3) 50 tons per year

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When do I have to report my emissions?

Facilities subject to criteria pollutant emission reporting must file their emission statement with the DEP by July 1 of the year following the inventory year.

For example, a facility would file an report detailing emissions from calendar year 2008 by July 1, 2009.

Beginning with reporting year 2009, the reporting deadline moves from July 1 to May 15.  The 2009 air emissions inventory will be due on May 15, 2010.

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How should I calculate my emission estimates?

Chapter 137, Section 5 provides a seven-step hierarchy for emission estimation methods.

  1. 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;
  2. 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;
  3. 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;
  4. 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;
  5. 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;
  6. 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
  7. 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.

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Where can I find emission factors?

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.

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What information must be included on the emission statement?

The data required on an emission statement is extensive, in part, because emissions must be calculated at the process level.  The DEP encourages facilities that must report emissions to use Satellite i-STEPS , a version if i-STEPS INFINITY, the software used by DEP to track criteria pollutant emissions.  Facilities using Satellite i-STEPS or i-STEPS INIFINITY to report their emission data will meet all the minimum submission requirements. Further information about downloading and using Satellite i-STEPS is available here.

De minimis emissions need not be reported. For criteria pollutants, the de minimis level is one percent (1%) of the minimum reporting threshold for a criteria pollutant, calculated on a per facility basis. 

All submissions, where electronic or paper, must include a certification statement attesting that the emission statement is accurate and complete to the best knowledge of the individual responsible for operating the facility.  The certification statement should be on company letterhead and include the full name, title, signature, date of signature, and telephone number of the responsible official.

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What is an acceptable certification statement?

Pursuant to DEP Rules, Chapter 137, Section 4(A), a certification statement must accompany all data submissions. The certification statement must attest that the information contained in the submission is accurate and complete and include the full name, title, signature, date of signature, and telephone number of the responsible official.

In recent inventories, Maine DEP has accepted the Satellite i-STEPS Summary Report as the certification statement, even though two pollutants -- PM2.5 and Ammonia -- were noticeably absent.  The Satellite i-STEPS Summary Report is no longer considered an adequate certification statement.  In its place, we advise facilities to print the last page of the Facility Detail Report (instructions) and to attach that page to a certification statement printed on company letterhead and signed by the responsible official.  A sample certification statement would be:

"I, (responsible official's name), certify that the information contained in the 2005 Air Emissions Inventory Statement for (facility name) is accurate and complete to the best of my knowledge."

(Responsible Official Name and Title, Telephone Number, Signature and Date)

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I believe we made a calculation error in a previous year.  What should I do?

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.

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Is the reported annual fuel use based upon the amount of fuel consumed in a calendar year?

Yes, all pollutant emission reports are based upon calendar year activity and that includes fuel consumption.

Past confusion with this issue has come from calculating the Percent Quarterly Throughputs.  The quarters, for reporting purposes, are not your typical calendar or business quarters. 

  • Dec-Feb Throughput = % Throughput for January, February and December of the reporting calendar year;
  • Mar-May Throughput = % Throughput for March, April and May of the reporting calendar year;
  • Jun-Aug Throughput = % Throughput for June, July and August for the reporting calendar year; and
  • Sep-Nov Throughput = % Throughput for September, October and November for the reporting calendar year.

Also, remember that the sum of the percent quarterly throughputs must equal 100%.

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Should actual sulfur content of fuel be reported or the Chapter 106 allowable fuel sulfur content?

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.

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In the revised Chapter 137, I'm asked to provide an equipment's design capacity and/or nameplate capacity.  For my air emissions license and in past inventories, I've reported capacity in million BTU per hour input.  Is that still acceptable?

Yes, in fact, reporting design capacity in million BTU per hour input is the preferred method.  The revised version of Chapter 137, "Emission Statements," included examples which inappropriately indicated other method of reporting capacity.  The examples will be removed during our next rulemaking cycle.

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Where can I find my latitude and longitude or UTM coordinates?

The coordinates can be found on United States Geological Survey maps.  These maps are available for a small fee from the Maine Geological Survey (http://www.maine.gov/doc/nrimc/pubedinf/pubs/pltopo.htm).  You can also contact Tammy Gould with the Emissions Inventory Program and we can look up your coordinate data for you.

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Who do I contact for more information?

If you have questions about your annual emissions submission, please e-mail your questions to the Emissions Inventory Program at emissionsinventory@maine.gov or contact Tammy Gould (287-7036).

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