1. Operations at my facility have been shutdown. Do I still need to report?
A: It depends on which of the following situations fits the circumstances of the shutdown:
Permanent closure of facility
If your facility is permanently closed and the air permit is no longer active with DEQ; you do not need to report.
Temporary closure of facility
If operations at a facility are shutdown and the air permit is still active with DEQ, you will need to report. In this case, please report emissions data from the year before the facility ceased operations and the projected maximum the facility could operate if it went back into operation.
2. Who should report if my business has been sold?
A: Whoever is currently on the air permit is responsible for reporting.
3. How do I know what type of permit (i.e. Basic, General, Simple, Standard ACDP or Title V) my facility was issued?
A: Please contact the regional office for which your facility is located to determine what type of permit you have. See Who to contact with questions section on website for the phone number of the regional office for the county in which the facility is located.
4. Who has the permit review report the company or DEQ?
A: The permit review report is an attachment to the permit. The current permit is supposed to be retained onsite at the facility.
5. My permit number does not tell me much at this time, is there a website with that permit number I can get information from?
A: There is no website to look up permit information. You will need to contact the regional office that manages your permit. See Who to contact with questions section on website for the phone number of the regional office for the county in which the facility is located.
6. I have more than one General ACD permit but only one permit number was listed in the letter. Do I only report on the listed one or all permits?
A: You will need to report on all of them except if they are permits for gasoline dispensing facilities or drycleaners.
7. I received a letter from DEQ and I am a gasoline dispensing facility. Do I need to report?
A: As long as you do not have other air permits for your facility you do not need to report.
8. Do general permit holders only answer the questions from the ‘reporting matrix’ or do they have to also include what’s on the 633 toxics list?
A: DEQ is asking facilities to report production information for emission units (equipment) and activities that emit any of the approximately 630 air toxic pollutants. This should not be limited to what is listed in the permit or in the reporting matrix but should include all potential sources of air toxic emissions that cannot otherwise be eliminated as a categorically insignificant activity. Facilities can check AP-42 and other resources using the links in the section Resources for Emission Factors and Estimation Methodologies on the website to help identify emission units and activities that emit air toxics for their industry.
9. Can DEQ provide examples on the website to help see how to fill out the forms?
A: Examples are now posted on the website.
10. If I have a General permit (AQGP-018) for emergency engines do I have to report?
A: If the emergency engines are part of the PGE Dispatchable Standby Generator Program and the facility has a General Permit (AQGP-018) then you will need to report. This is because the engines have the potential to operate for more hours than a normal emergency generator.
11. Can we request an extension? Are the March/May/September deadlines a hard date? What if I can’t get it done by then?
A: Interim deadlines may be possible but DEQ must be contacted before the initial deadline dates to request an extension. Please contact Brandy Albertson
or call 503-229-6459 to propose a different compliance date.
After each deadline expires, you will be contacted by DEQ to explain why you were unable to report. Failure to provide the requested information is a violation of OAR 340-214-0110, for which DEQ may impose a civil penalty and may issue an order to comply.12. If a General or Basic Permit holder desires to calculate their own emissions, what should they do? Does the reporting deadline change?
A: Facilities who wish to estimate their own emissions will need to contact DEQ in writing by March 17, 2017. DEQ will evaluate the request and issue an approval back in writing. If approved, the deadline will change from March 31, 2017 to May 1, 2017 for information on the 187 federal hazardous air pollutants and the remaining approximately 450 air toxics are due September 1, 2017. Facilities will need to fill out and submit the reporting form, Facilities with Title V, or Standard and Simple Air Contaminant Discharge Permits
, and provide all the data requested for that form.
13. What if I have emission factors and material balance information for the same emission unit or activity? Do I fill out both worksheets in reporting form? Are there situations when we might only use one of those worksheets?
A: Use the information (i.e. emission factor or material balance information) that best represents the emissions coming from the emission unit or activity. If you use emission factors to estimate emissions then use the Emission Units & Activities worksheet of the reporting form. If you use material balance information to estimate emissions use the Material Balance worksheet of the reporting forms. Do not fill out both worksheets for it will double count the emissions.
14. Within the reporting forms there are multiple cases where it requests information regarding compounds of toxic pollutants. For example, Antimony has a column next to it that says “Antimony compounds including but not limited to”, then only lists Antimony trioxide.
Is the facility supposed to add pollutant columns and identify each individual compound that is not listed? Or, is the facility supposed to add a column to report all pollutant compounds combined, as a whole?
A: The facility should list out all individual pollutants in the worksheets. At the end of the list of pollutants in the worksheets are a set of columns for adding pollutants. Copy and paste the columns to the left and fill out the necessary information (i.e. CAS number, pollutant compound name, etc.).
15. Can I hide the pollutant columns while filling out the worksheet, and submit it that way (with the columns still hidden) or do I have to unhide everything?
A: Yes, you can hide the pollutant columns while working in the form and you do not have to unhide the columns to submit the form.
16. Can I delete the pollutant columns that do not apply to my facility?
A: No, you can hide pollutant columns to work in the form but please do not delete the pollutant columns not used.
17. What if a pollutant in the material balance worksheet, has a different “CAS” code?
A: At the end of the list of pollutants in the worksheet are a set of columns for adding pollutants. Copy and paste the columns to the left and fill out the necessary information including the CAS number you believe it to be.
18. What if a chemical (pollutant) is on the list but not on the reporting form?
A: Please add the chemical to the end of the worksheet. At the end of the list of pollutants in the worksheets are a set of columns for adding pollutants. Copy and paste the columns to the left and fill out the necessary information (i.e. CAS number, pollutant compound name, etc.).
19. Do I have to submit my information on the reporting forms DEQ has provided?
A: Yes, the forms were designed to help transition the emissions data into DEQ databases to develop the statewide inventory.
20. What if I know a pollutant is emitted from an emission unit or activity but have no information (i.e. emission factors or percent weight of air toxic in material) to include in the reporting form. Do you use “0” or leave blank on those we don’t have information for?
A: Please use “0” in emission factor or percent weight of air toxic pollutant columns of worksheets if no information is available.
21. Any rules about who has to submit the reporting form?
A: The designated ‘responsible official’ for the facility must submit the reporting forms.
22. Since a facility has to certify data when submitting a form, will DEQ take enforcement action if there is a mistake?
A: DEQ will not take enforcement action if a mistake is made; however, please notify DEQ immediately about any mistakes to get your emissions information corrected.
23. Is there a way to ensure that the spreadsheet has been submitted? Is there any other confirmation than the thank you prompt on the web page that the report form was received?
A: Answer pending.
24. What will happen if I don’t submit anything?
A: Failure to provide the requested information is a violation of OAR 340-214-0110, for which DEQ may impose a civil penalty and may issue an order to comply.
25. I forgot to add something and I already submitted the reporting form. How do I get this information to DEQ?
A: You can revise your reporting form and resubmit by the appropriate deadline date as indicated on the website. Please rename the excel file as follows:
[source number]_[facility name]_revised.xlsx
Source number = first six numbers of permit number
If a facility needs to revise their reporting form after the deadline date(s), please contact Brandy Albertson.
26. Is the new website actually accepting form submittals? (There was an error message during the presentation after the example form was submitted)
A: The submittal feature on the website is currently working. The example form submitted during the presentation on Feb. 8, 2017 did in fact get submitted. The error had nothing to do with the submittal itself but about refreshing that section after something has been submitted.
27. Will the public be involved in the emissions inventory review process?
A: DEQ will present the final results of the statewide emission inventory to the public by the end of the year.
28. How will public records request be handled?
A: Answer pending
29. Can DEQ put a link on the website to submit questions?
A: Answer pending
30. DEQ is now developing air toxic rules. How can DEQ do air toxic rulemaking without first getting this inventory information?
A: The emission inventory is not necessarily needed to develop the air toxic rules. We already have Oregon specific data from the National Air Toxics Assessment (NATA) database, as well as the experience and best practices from other states with health risk based air toxics regulations that provide DEQ and OHA with the information the agencies need to begin drafting the rules.
The inventory will be used as a screening tool to prioritize the implementation of the air toxic program after rules are adopted. It will help us determine pollutants and areas of concern and which air permitted facilities will be subject to the program. For more information please go to the Cleaner Air Oregon program website to access their Frequently Asked Questions.
31. What are the default emission factors that DEQ will use for the in-house emissions inventory for ASR, Basic and General Permits? Will the public and regulated community have a chance to review the default emission factors?
A: DEQ is currently developing emission estimation protocols for 21 different permit types/source categories (i.e. asphalt plants, surface coaters, boilers, etc.) for ASR, Basic and General ACDP facilities. Various resources such as AP-42 Compilation of Emission Factors and California Air Toxic Emission Factor database will be evaluated for the best representative emission factors for the 21 source categories. The emission protocols will only go through an internal review by DEQ staff.
32. Will DEQ provide a list of categorically insignificant activities that were removed from the list?
A: The following activities were removed from the list and therefore still need to be reported:
(a) Constituents of a chemical mixture present at less than 1 percent by weight of any chemical or compound regulated under divisions 200 through 268 excluding divisions 248 and 262 of this chapter, or less than 0.1 percent by weight of any carcinogen listed in the U.S. Department of Health and Human Service's Annual Report on Carcinogens when usage of the chemical mixture is less than 100,000 pounds/year;
c) Distillate oil, kerosene, gasoline, natural gas or propane burning equipment, provided the aggregate expected actual emissions of the equipment identified as categorically insignificant do not exceed the de minimis level for any regulated pollutant, based on the expected maximum annual operation of the equipment. If a source’s expected emissions from all such equipment exceed the de minimis levels, then the source may identify a subgroup of such equipment as categorically insignificant with the remainder not categorically insignificant. The following equipment may never be included as categorically insignificant:
- (A) Any individual distillate oil, kerosene or gasoline burning equipment with a rating greater than 0.4 million Btu/hour;
- (B) Any individual natural gas or propane burning equipment with a rating greater than 2.0 million Btu/hour
(n) Automotive repair shops or storage garages33. If two kilns are rated under the threshold based on natural gas throughput (2mmbtu/hr) individually but together they are above the threshold do I include the production and fuel use for these?
A: Basically, if it is in the permit report it. If it is not in the permit then check to see if the emission unit or activity is considered a Categorically Insignificant Activity to determine if it needs to be reported. There are no thresholds for aggregating devices for air toxics reporting. Thus the answer to this specific question is yes.
34. Please define emission factor, material balance and throughput.
A: The definitions are:
A representative value that relates a quantity of pollutant released to the atmosphere per unit of production, fuel, or material being used or output by an emissions unit or activity. The factor is usually expressed as pounds per unit weight, volume, length, distance, time, etc. An example is a PM10 emission factor for a boiler expressed as pounds per unit of natural gas burned such as 2.5 lb of PM10/million cubic feet of natural gas.
340-200-0020 (92),"Material balance" means a procedure for determining emissions based on the difference in the amount of material added to a process and the amount consumed and/or recovered from a process.
Throughput is the amount of material used, fuel burned, or products produced by an emission unit or activity for a given time period (i.e. hourly, annually, etc.).
35. What is capture and control efficiency?
The amount of a pollutant collected and routed to an air pollution control device divided by the amount of total emissions generated by the process being controlled.
340-200-0020 (35), “Control efficiency” means the product of the capture and removal efficiencies.
“Removal efficiency” is the performance of an air pollution control device in terms of the ratio of the amount of a pollutant removed from the airstream to the total amount of pollutant that enters the air pollution control device.
36. Additional definitions:
Annual Production is defined as “process rates” such as material used, fuel burned, or products produced by an emission unit or activity in a given year.
2016 Annual Production
Actual annual process rates for an emission unit or activity for the 2016 calendar year.
Projected Maximum Production
This is the projected normal (also referred to as anticipated) annual process rates for emissions units and activities that are used to calculate emissions and establish Plant Site Emission Limits (PSEL) for the permit. Projected normal annual process rates are set taking into consideration the highest level that the emissions unit or activities would be expected to achieve in any one year during the permit term. Normal annual process rates should not reflect round-the-clock operation (i.e., 8,760 hours per year) unless that is the norm for the emission unit or activity.
DEQ is looking for a more realistic representation of a facility operating at projected normal annual production levels that essentially would not exceed current criteria pollutant (i.e. CO, NOx, PM, SO2, VOC, etc.) permit limits for a given year.
Emissions Units and Activities
Devices or processes at a facility that emit or has the potential to emit air toxic pollutants. This includes any machine, equipment, raw materials, products, or byproduct that produces air toxic pollutants. An activity is any process, operation, action, or reaction, e.g., chemical, at a stationary source that emits air toxic pollutants.
37. Do we include information regarding pumps and valves for bulk gasoline permits?
A: If it is in the permit then it needs to be included in air toxics reporting. 38. Do emissions from accidental releases need to be reported?
A: No.39. How are product additives such as ammonia refrigeration systems to be recorded? There are typically no losses but potential for accidental release.
A: If the refrigeration system is a permitted activity than report it. If it is not in the permit and the system is considered a Categorically Insignificant activity than you do not need to report the additives for the refrigeration system. 40. Many fruits have trace levels of arsenic; do you want fruit processors to report that?
A: If the arsenic is released to air from the fruit during processing then include it in the reporting. Refer to your permit and other resources (i.e. AP-42 or other resources) for what emission units and activities that release the arsenic during processing. You can check AP-42 and other resources using the links in the section Resources for Emission Factors and Estimation Methodologies
on the website. 41. How do you identify which air toxics are emitted from co-generation engine exhaust from wastewater treatment anaerobic digester gas?
A: You can check AP-42 and other resources on the website under the Resources for Emission Factors and Estimation Methodologies section. 42. Where is the end point to count emissions? Do you calculate for off-gassing after the product has been produced and finished?
A: The end point for counting emissions is isolated to what is emitted onsite. If it is an activity identified in the permit you need to report it. If the activity is not in the permit and emissions are released to air onsite and not considered categorically insignificant it still needs to be reported. Even off-gassing (fugitive emissions) onsite still needs to be considered in air toxics reporting. 43. Do wastes that are shipped off-site to other companies need to be counted on the spreadsheet?
A: Yes. DEQ is asking for the quantity of waste shipped off-site for material balance activities. 44. For emission factors that already include the control device efficiency, do I list the control % under the control device column?
A: Please provide the control device type and put “0” in the overall control efficiency column in the reporting form. This will indicate to DEQ that the emission factor is controlled. 45. For unit or source (tank) that can handle different products throughout the year- do you calculate emissions per product? Product in tank at any point in the year may be different than the following month. Maximum projections will be higher than reality if multiple products are accounted for with 8760 hours, how should the max projection be reported?
A: Answer pending46. What if there is no additional emissions/production information than what is requested from the annual report? (Boiler related)
A: The information requested is not limited to emission units and activities found in the existing permit(s). As long as you have checked and eliminated all potential unpermitted emission units and activities at your facility than that is all you need to report.47. As with Categorically Insignificant Activities, is there a list of activities that are significant and should be reported?
A: DEQ does not have a list of activities considered significant that should be reported. It is the responsibility of facilities to identify emission units and activities that may emit air toxic pollutants. Refer to your permit and other resources (i.e. AP-42 or other resources) for what emission units and activities may emit air toxics. See Where to begin
and Resources for Emission Factors and Estimation Methodologies
sections of the website to help identify emission units and activities that emit air toxics. 48. For sending off hog fuel material or wood chips (from wood processing facility). Do we report this as waste? Do we calculate emissions from this? Is it waste?
A: Answer pending49. If it’s not being emitted to the air, we do not include it on the spreadsheet, correct? (Example- shipping some waste off site?)
A: DEQ is asking for the quantity of waste shipped off-site for material balance activities. 50. Water bought and brought on site that contains 5ppm- to include with reporting?
A: Answer pending51. For natural gas combustion, will DEQ come up with a list to tell what emission factors can be used for fuel use?
A: DEQ will not provide emission factors that can be used for fuel use. It is the responsibility of facilities to find emission factors that best represent the air toxics emitted from emission units or activities. However, DEQ has provided resources on the website for facilities to find emission factors. See the Resources for Emission Factors and Estimation Methodologie
s section of the website. 52. Which do I convert the emission factor or the annual production to get the units of measure the same?
A: DEQ leaves this up to the facility. 53. Are you comparing emission factors for similar equipment between different facilities?
A: No.54. Do you only include stationary source emissions or mobile emissions such as forklifts?
A: If mobile emissions (i.e. vehicular traffic, forklifts, onsite mobile equipment, etc) are already included in your permit than you will need to report them. Otherwise, mobile emissions are excluded because it is considered a Categorically Insignificant Activity. 55. For 2016 fuel used to manufacture products? Does this include fuel used in trucks used to deliver product (concrete)?
A: If mobile emissions (i.e. truck deliveries, etc) are already included in your permit than you will need to report them. Otherwise, mobile emissions are excluded because it is considered a Categorically Insignificant Activity. 56. A sewage treatment plant is permitted for an engine, boiler, and a flare. However, there are air toxic emissions (i.e. Carbon disulfide, Carbonyl sulfide, and Hydrogen sulfide) from the sewage treatment process that are not included in the permit. Do I report also on the unpermitted activities?
A: Yes, you will need to report air toxic emissions from the unpermitted activities as well as the engine, boiler, flare.57. What should I report for a rock crusher?
A: Please refer to the reporting matrix on the website under the Facility Information section for Area Source Registrants and Basic and General ACD permits. 58. I have a sawmill on a General Permit and:
What am I supposed to report?
- only cut dry wood, and collect sawdust,
- don’t have a boiler or kiln or veneer dryer,
- emissions are just particulate matter (sawdust)
A: Report sawdust collected in the emission unit and activities worksheet of the reporting form. And, if you use any paints or inks for marking or stenciling, check the MSDS / SDS sheets for pollutants in the paint or ink against the Air Toxic Contaminant List. Record those products in the Material Balance worksheet of the reporting form that contain toxics. Include the types and quantity of paints and inks used in 2016/Projected Maximum year; product density, and percent weight of air toxic contaminants found in the materials and quantity of waste shipped offsite for each product.
59. Do you want Safety Data Sheets (formerly MSDS) submitted with reporting forms?
A: No, DEQ does not need copies of the Safety Data Sheets included with reporting forms.
60. Will you accept both MSDS and SDS for information gathering?
A: A Facility may use either MSDS or SDS for information gathering. The MSDS and SDS do not need to be submitted along with the reporting form.
61. Is there a de minimis level for reporting purposes?
A: There is no de minimis level currently for air toxics reporting.
62. Is there a de minimis level? If you use only 2 gallons of a product do you need to include that? For instance, defect marking paint is part of the production process (not categorically insignificant). But may only use very small amounts of that product. Does that need to be included?
A: There is no de minimis level so you do have to report the defect marking paint.
63. For custom paint shops that may have over 300-400 different SDS sheets, i.e. multiple lacquers, thinners; can they aggregate groups to make reporting easier?
A: If paint products or other similar materials have the same air toxic content (i.e. product density, percent weight of air toxic pollutant, etc.) then you can group them. However, if it differs from one product to the next then it needs to be listed individually.
64. Products like adhesive or epoxy, used for trescent and beam mfg, the list of compounds in MSDS are bound to product and not emitted to air during production, including the information from MSDS would not represent the actual emissions. Should they use engineering estimates for this?
A: Yes, use engineering estimates.
65. For devices/processes in a completely closed system do they need to be reported? There is no transfer point; there are no emissions from this product process. The example: transfer to a truck off-site in an enclosed loop.
A: If it is not emitted to air then it does not need to be reported.
66. The formula that’s shown for calculating emissions (pasted below) seems unlikely to produce a correct value, particularly for substances that contain more than one reportable chemical. The main problem with the formula is the way it incorrectly accounts for wastes (W). The W term is the total amount of waste for the product or mixture. If a product contains 3 reportable ingredients (or pollutants, as you refer to them), the emission calculation for each ingredient needs to adjust the waste term to reflect the percentage of the individual pollutant that’s present in the waste. Your formula doesn’t do that.
A: Yes, this is true the red highlighted example material calculation in the “Material Balance” worksheet is confusing. However, the form instructions refer to “Emission Estimates for each pollutant found in the material” including “W” in the formula which is the product waste by weight of the air toxic pollutant shipped offsite. If a facility reported total waste shipped offsite in columns “J” and “K” than the formula relating to the onsite emissions (2016 and projected max) should only account for the individual air toxic pollutant in the waste of the product shipped offsite not total waste shipped offsite.
This is how it is currently written in the “material balance” worksheet of the reporting form (found on row 19 under column “O”):
[(C * D * K)] – W] (1 – (CE * DE))
K = % Weight Pollutant
So, the formula should actually be written:
[((C * D * K) – (W * K)) (1 – (CE * DE))]
K = % Weight Pollutant (decimal)
Here are a few options for correcting the material balance estimates if the waste shipped offsite was incorrectly applied:
1) DEQ will check material balance emission estimates based on information provided in the worksheet. If emissions are different from what is reported, DEQ emission inventory staff will make the correction and contact permit writers and facilities.
2) If the facility prefers to make their own corrections they can resubmit the reporting form on the website.
Questions and answers are pending for this section.