Hazardous
Air Pollutants: Reporting Requirements Questions and Answers
Who must report?
Any facility which is required to report criteria air pollutants must also report emissions of hazardous air pollutants every three years.
What must be reported?
Emissions of hazardous air pollutants must be reported when those pollutants are:
- 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, new to the 2008 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.
- Acetaldehyde
- Acrolein
- Arsenic and arsenic compounds;
- Benzene;
- Cadmium and cadmium compounds;
- Chromium and chromium compounds;
- Cobalt and cobalt compounds;
- Dioxins;
- Formaldehyde;
- Manganese and manganese compounds;
- Mercury and mercury compounds;
- Nickel and nickel compounds; and
- Polycyclic organic matter.
A list of hazardous air pollutants and their
reporting thresholds from Appendix A is available here.
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When do I have to report?
Hazardous air pollutant emissions are inventoried every three (3) years. The
current reporting year is 2008, with all reports
due by July 1 , 2009. The next reporting year
will be 2011, with all reports due by May 15, 2012 .
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How should I calculate my emission estimates?
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.
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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 pollutant.
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.
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How did DEP develop the default emission factors?
When developing the default emission factors for the thirteen HAPs listed above, 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.
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Are there special reporting forms for hazardous air pollutants?
No. All emissions - criteria and hazardous air pollutants and greenhouse gases - should be reported using the Satellite i-STEPS software. Please see the i-STEPS page for more information about the program and training materials.
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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
and are available for a small fee from the Maine Geological Survey (http://www.maine.gov/doc/nrimc/pubedinf/pubs/pltopo.htm).
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Who do I contact for more
information?
If you still need further assistance, please feel free to Richard Greves at
(207) 287-7030 or by e-mail at rich.greves@Maine.gov.
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