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DEP > Air Bureau > EIP > Air-Inventory List Server > May 2006

 

-----Original Message-----
From: owner-air-inventory@lists.maine.gov [mailto:owner-air-inventory@lists.maine.gov] On Behalf Of Gould, Tammy
Sent: Tuesday, May 02, 2006 1:03 PM
To: air-inventory@informe.org
Cc: Severance, Ronald W; Wright, David W; Higgins, Lisa; Hodsdon, Becky S; Saball, Doug; Greves, Rich; Cone, Marc A
Subject: air-inventory Additional HAP Guidance

Following the HAP Inventory Training Programs in Bangor and Portland, there were many questions regarding the reporting of HAPs in the 2005 Emissions Inventory. Past guidance from the Department and assumptions made by the facilities seemed at odds with current interpretions. Add to that mix, language within the rule that was somewhat unclear, a desire to leverage i-STEPS to more easily calculate combustion HAPs for this and future inventories, and a need to have facilities prepared for the July 1 reporting deadline, and we found ourselves having to 're-think' the 2005 HAP inventory and to write inventory guidance much later within the inventory cycle that we would have liked.

HAPs are an extremely important inventory. The results of a "bad" HAP inventory linger because we collect HAP data only every three years.
However, we could also not ignore the genuine concerns expressed by our reporting facilities.

Therefore, we are issuing additional HAP inventory guidance today to clarify our position regarding the "in-for-one, in-for-all" concept; incidental HAP uses; and establish a path for our facilities to follow to meet their 2005 inventory obligations. The full policy document may be found on our ftp site at:
ftp://ftp.state.me.us/pub/dep/Air-Inventory/FAQ_Inventory_2005_v7.doc. The document will be posted to the 2005 Inventory website later this week.

Of particular note to facilities will be Question 3.

>3. If my facility emits one HAP above the applicability threshold in
Chapter 137, should I report all HAPs, even if the rest are below the threshold?

Answer:

>Maine DEP's intent when crafting Chapter 137 was to have each facility,
once a determination was made that one HAP exceeded its applicability threshold, to then report on all HAPs at their facility. This is similar to how criteria air pollutants and greenhouse gases are reported. However, there has been a great deal of confusion on which HAPS and what amounts are required to be reported. This confusion has arisen from both the way Chapter
137 is written and to the way it has been interpreted by facilities and DEP over the years.

>Recognizing that we are a few weeks away from the July 1 reporting
deadline, we have decided to issue guidance specific to this inventory cycle. Therefore, for the 2005 Inventory only, the Department is requiring sources to report:

>a) Non-Combustion HAPs: Only those HAPs that exceed the applicability
thresholds established in Chapter 137. This policy is consistent with how the rule had been interpreted and implemented in prior inventory years. If in previous years you reported certain HAPs in amounts below the applicability thresholds, we would encourage you to continue that practice.

>b) Combustion HAPs: All HAPs for which a generally available emission
factors exist, whether those emissions exceed applicability thresholds or not. DEP is facilitating this process by offering both lists of acceptable emission factors and staff assistance to enter those factors into Satellite i-STEPS. Facilities are encouraged to use site-specific testing or emission factors, where available.

If you have questions or need assistance with your HAP inventory, please contact one of our Emissions Inventory staff.

David Wright - 287-6104
Tammy Gould - 287-7036
Rich Greves - 287-7030

-----Original Message-----
From: owner-air-inventory@lists.maine.gov [mailto:owner-air-inventory@lists.maine.gov] On Behalf Of Gould, Tammy
Sent: Thursday, May 25, 2006 3:09 PM
To: air-inventory@informe.org
Cc: Hodsdon, Becky S; Greves, Rich; Higgins, Lisa; Wright, David W
Subject: air-inventory Notes and Minor Corrections to Wood Emission Factors

Please note the following minor corrections to "Default Emission Factors for Calculating Hazardous Air Pollutants from Combusion of Wood Fuels" (DEPAQ21 A2006).

(1) There are two emission factors for 2,4-Dinitrophenol. The first factor, 4.23E-06, is a controlled emission factor and the second factor, 1.62E-06, is an uncontrolled factor. Please place a line through whichever factor you are NOT using.

(2) Some of you may find that Satellite i-STEPS does not accept the Pollutant Code for Cadmium, 7440439. For this pollutant, pleas use the Help pick list by pressing F1 or the ? button on the button bar. You will see an entry for "Cadmium; 7440439" on the list.

(3) The correct Benzo(b+k)fluoranthene is 102, NOT 56832736.

(4) There are two listings for Methylanthracene, mixed isomers, 26914181.
This is simply a duplicate and the second should be ignored.

Thank you for your understanding. If anyone else finds errors on the HAP emission factor forms, please send an e-mail to me.

- Tammy Gould, DEP

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