Air Toxics

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Air Toxics Emissions Reporting Frequently Asked Questions

​​​​​​​​​​​​​DEQ created this section to address commonly asked questions about the 2020 Air Toxics Emissions Reporting requirements. For questions regarding Cleaner Air Oregon program, including emissions inventory and reporting information, please visit the Cleaner Air Oregon website.

Title V, Standard, and Simple facilities must report their toxic air contaminant emissions inventory for calendar year 2020 to DEQ (or LRAPA) by Sept. 1, 2021.

Common Questions about Air Toxics Emissions Reporting 

 
What is an emissions inventory?
An emissions inventory, or EI, is an accounting of emission quantities discharged into the atmosphere by equipment or activities from industrial facilities, in a particular geographical location for a specific period of time. For an air toxics emissions inventory, this includes the amount of each toxic air contaminant emitted from each individual emissions-producing unit or activity. A list of toxic air contaminants recognized by DEQ is available in Table 2 of the Cleaner Air Oregon rule.
How is this three-year Air Toxics Emissions Inventory different from CAO EI requirements? Does this reporting requirement mean that my facility has been called-in to the CAO program to perform a risk assessment?

This air toxics Emissions Inventory is a separate reporting requirement than an EI submitted for a CAO risk assessment. While they may contain similar information, they serve separate purposes.

The primary objectives of this every-three-year air toxics EI is to supply statewide information that allows DEQ to establish and maintain long-term trends of air toxics emissions in our communities, and to report to EPA the best available information for our state. Subpart 2(a) of OAR 340-245-0040 allows DEQ to periodically request air toxics emissions information statewide, even when sources are not in the CAO program.

In contrast, a CAO EI is used to perform a source risk assessment for called-in existing facilities and new facilities seeking a Simple, Standard or Title V permit. Visit the Facilities section of the Cleaner Air Oregon website for more information about CAO call-ins.

​Refer to the Air Toxics Reporting Background for more information about the origin of this program.

Is reporting mandatory, what happens if I don’t submit an inventory for my facility?
For the 2020 reporting cycle, if you own or manage a Standard or Simple air quality permitted facility in the State of Oregon under the Air Contaminant Discharge Program, or the Title V program, then reporting is mandatory. Failure to provide the requested information is a violation of OAR 340-245-0040(2), for which DEQ may impose a civil penalty and issue an order to comply.

DEQ is not requiring Air Toxics emissions data for the 2020 operating year from Basic and General ACDP permit-holders for this 3-year reporting cycle.​
How do I know what type of permit (i.e. ACDP General, Basic, Simple, Standard or Title V) my facility was issued?
​​​This information is located on the first page of your issued permit. Check DEQ Permits Online to locate an electronic copy. ​
My facility is located in Lane County, do I still need to comply with DEQ reporting requirements?

Facilities in Lane County have the same 2020 reporting requirements; these facilities will report directly to the Lane Regional Air Protection Agency instead of the Department of Environmental Quality. Facilities in Lane County should contact LRAPA directly with questions or concerns at 541-736-1056.

I received a GovDelivery notice or email about air toxics reporting, but never received an official letter or email about the reporting requirement. Why?

DEQ frequently uses GovDelivery, a voluntary email listserv, to send informal update information to sources and stakeholders. Formal communications will be sent via email and/or letter on file for each facility. Please confirm with your DEQ permitting office that your facility’s contact information is up-to-date, including the email address of the responsible official. DEQ (or LRAPA) will send the official letter for this reporting requirement in April 2021.

Questions for Basic and General ACDP permit-holders

I received an email saying that I do not need to submit an air toxics emissions inventory this year. Does this mean I do not have to submit an annual report for my permit?

No. The Air Toxics Emissions Reporting effort is different and separate than the reporting sources perform for annual permitting compliance. You should continue to submit your annual reports as normal. Refer to DEQ's Basic and General ACDP Permits page for more information about annual reporting. 

Refer to the Air Toxics Reporting Background page for more information about this air toxics reporting requirement.

Do I still need to pay my permit fees this year?
Yes. This air toxics emissions inventory effort is unrelated to your permitting fees. Please contact your DEQ permitting office or your permit writer or inspector with questions about your permit compliance. 
Why don’t Basic and General ACDP sources need to report air toxics this year?
Basic and General ACDP permits are structured such that potential emissions may come from a relatively narrow set of allowable permitted operations specific to each permit category. DEQ has developed a method to estimate these emissions for sources based on information gathered from annual reports. It was necessary to request a complete inventory from these sources in 2016 in order to develop this methodology, and it may be necessary to request inventories in future years to refine the estimates.

​Questions for Title V, Standard and Simple ACDP permit-holders

What do I need to do in 2020 to prepare for the reporting submittal in 2021?
DEQ recommends taking time to review your permit and permit review report, review your 2016 submittal for Air Toxics reporting, ensure that your recordkeeping and monitoring are up to date, and have Safety Data Sheets for any air toxics- containing material products you may use. Also review available emission factors for permitted activities, review control efficiencies for any air pollution control devices, and assemble available air toxics source test data in advance. ​
I already submit a lot of this information in my annual permit reporting requirements. Do I need to do both?

Yes, facilities will need to complete a 2020 Air Toxics Emission Inventory reporting form in addition to any routine reporting requirements in their permit conditions. A standardized form is necessary for DEQ to retrieve the equivalent information from all facilities.​

Operations at my facility shut down in 2020. Will I still need to report?

It depends on which of the following situations fits the circumstances of the shutdown:

Permanent closure of facility
If your facility permanently closed during 2020 and the air permit is no longer active with DEQ, you do not need to report.

Temporary closure of facility
If your facility operated for any portion of 2020, you will need to report those operations. Facilities with a temporary closure for the full operating year do not need to report.
I manage a new facility and we started operation in 2020. Will I still need to report?
Yes. You should report all operations and emissions occurring in 2020. Please contact DEQ for more information.​
Who is responsible for reporting if my business has been sold?
The current Responsible Official listed on the air permit at the time of submission in 2021 is responsible for reporting. Contact your DEQ permitting office to confirm the contact information for this individual is accurate. Please contact DEQ if you have questions about this reporting requirement.

My facility has been ‘called-in’ to the Cleaner Air Oregon program. Do I still have to report even if I just submitted an air toxics emissions inventory to that program?
​Yes, CAO facilities must report the same as all other air quality permitted facilities for their 2020 operations. This includes existing facilities that have undergone or are currently under CAO review at the time of submission, as well as new facilities that completed the CAO risk assessment process and began operations in 2020.

New and existing CAO sources have the option to submit their approved CAO emission inventory, provided the emissions information is reflective of the 2020 operating year.

Is the 2020 Air Toxics Emissions Inventory reporting form available? When and where will I be able to find it?

The 2020 Air Toxics Emissions Inventory (ATEI) reporting form will be available in May 2021. Until that time, the CAO AQ520 form is a useful reference, as the ATEI reporting form will be almost identical in structure and function. However, only actual emissions will be required under 2020 Air Toxics Reporting - Potential to Emit, Capacity, and Max Daily emission rates are not included in this request. In addition, Stack Information will not be required.

The ATEI reporting form will be available on the Air Toxics Emissions Reporting website, under the 'How to Report' section. DEQ will send an email to facilities and GovDelivery notifications when the form is available.

Sign up here and select 'Air Toxics Emissions Inventory' to receive GovDelivery email announcements regarding website updates, reporting dates, availability of forms, and additional reporting instructions.


​​Questions about Calculating Emissions​

Will DEQ provide instructions and examples on how to fill out the reporting form?

Yes. DEQ is developing a comprehensive Air Toxics Emissions Inventory Recommended Procedures Document with instructions for completing the ATEI reporting form. The document will provide an overview of what information to provide, how to locate emissions factors, how to locate SDS information, how to account for emissions control devices, and how to use the form itself. It will also provide numerous examples from industry sectors, covering a variety of equipment types and operating scenarios.
 
The ATEI Recommended Procedures document will be available shortly after the reporting form in May 2021. After reviewing the materials, please contact DEQ if you have additional questions.​
The ATEI reporting form includes formulas for estimating emissions that are different from my permit. Which should I use?

The ATEI reporting form includes default formulas for calculating estimated emissions; however, these may not be appropriate for all facilities. In many cases, the facility permit or permit review report will dictate how emissions should be calculated for a specific emission unit or facility. If this is the case, a facility should use the permitted method for estimating emissions and include the final emissions in the appropriate column. Facilities need to indicate these instances in the References/Notes column, or within a cover letter submitted with the reporting form (see Question #3 below in the Submission FAQ).
 
Keep in mind that ‘total VOC’ or ‘Combined HAP’ emissions are not sufficient for the ATEI, and that individual VOC and HAP pollutants will need to be calculated separately.

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Please define emission factor, material balance.
General Air Quality Definitions can be found in OAR 340-200-0020.

 “Emission Factor” means an estimate of the rate at which a pollutant is released into the atmosphere, as a result of some activity, divided by the rate of that activity (e.g., production or process rate). The factor is usually expressed as pounds per unit weight, volume, length, distance, time, etc. An example is a benzene emission factor for a boiler expressed as pounds per million cubic feet of natural gas combusted, such as 0.0058 lb. benzene/MMscf natural gas. 

“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.

Additional definitions:

​​​​Annual Production: The ‘process rates’ such as material used, fuel burned, or products produced by an emission unit or activity in a given year.   

2020 Annual Production: Actual annual process rates for an emission unit or activity for the 2020 calendar year.

Emissions Units and Activities: Devices or processes at a facility that emit or have the potential to emit air toxic pollutants. This includes any machine, equipment, raw materials, products, or byproduct that produces toxic air contaminant. An activity is any process, operation, action, or reaction, e.g., chemical, at a stationary source that emits toxic air contaminants. Operation and activities that may be omitted can be found in the list of Categorically Insignificant Activities to Exclude.​

Throughput: The amount of material used, fuel burned, or products processed or produced by an emission unit or activity for a given time period (i.e. hourly, annually, etc.).

Which Emissions Units do I include in my Emissions Inventory?

All Emissions Units (EUs) included in the operating permit for a facility must be included in the emissions inventory as EUs unless they are known to not emit any air toxic contaminants listed in OAR 340-245-8020 Table 2. EUs included in the ATEI must be designated in the same manner as they are designated in the operating or construction permit, where possible.
 
In addition, any unpermitted EUs that do not meet the categorically insignificant criteria addressed in the question below, but have the potential for air toxics emissions should also be included. Such units may be included in the Permit Review Report but do not have an EU ID in the permit.
​
Are the Categorically Insignificant Activities to Exclude for this program the same as for my permit?
Facilities compiling their 2020 ATEI reporting information may be able to exclude some kinds of operations if they are considered a 'categorically insignificant activity.' Emissions from these types of activities are considered insignificant when identifying emission units and/ or materials that emit toxic air contaminants at a facility [OAR 340-200-0020(23)].

Under CAO, the following activities are not considered insignificant and therefore still need to be reported under this request [OAR 340-245-0060(3)]:

(23)(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;

My facility has a lot of emergency generators. Do they need to be included in the inventory?
It depends on whether the emergency generators qualify as Categorically Insignificant Emissions Units. If a facility has multiple generators or pumps, then aggregate horsepower rating in excess of 3,000 horsepower must be identified and included in the reporting [OAR 340-200-0020(23)(uu)].

(23)(uu) Emergency generators and pumps used only during loss of primary equipment or utility service due to circumstances beyond the reasonable control of the owner or operator, or to address a power emergency, provided that the aggregate horsepower rating of all stationary emergency generator and pump engines is not more than 3,000 horsepower. If the aggregate horsepower rating of all stationary emergency generator and pump engines is more than 3,000 horsepower, then no emergency generators and pumps at the source may be considered categorically insignificant;​
I need help quantifying emissions for my facility. Where do I begin?

Emission estimates should be based on actual 2020 calendar year production and fuel and/or material usage rates. The following list is a presumptive hierarchy of the types of information that best approximate actual emissions but each individual case may be different:

  1. Existing air toxic emission factors in current permit or emission detail sheet
  2. Source test data
    Use all site-specific source test data whenever available, even if it is only one test, provided that it is representative of the process during the time period under consideration. If there is only one test, that test result (that is, the average of the three test runs) should be used for the emission factor. If there is more than one test, the average of all the test results should be used. No correction, cushion (e.g., 20%), or standard deviation should be added to the emission factor.
  3. Source test data from similar equipment
    If representative source-specific data cannot be obtained, emissions information from equipment vendors, particularly emission performance guarantees or actual test data from similar equipment is typically a better source of information for permitting decisions than AP-42, trade or technical association data, or DEQ or other regulatory agency emission factors.
  4. Trade or technical association data
    If no emissions information from equipment vendors or actual test data from similar equipment is available, emission factors from AP-42, trade or technical association data should typically be used, if available.
  5. DEQ emission factors, including the Emission Factor Search Tools
  6. Compilation of Air Pollutant Emission Factors (AP-42), or other state emission factors (e.g., California AQMD or Washington State Ecology emission factors)
    If emission factors are available from AP-42, trade or technical association data or DEQ, the source should propose whichever they believe is most representative of their process. If a range of emission factors is provided, use the average of the range.
  7. Engineering judgment based on sound assumptions about the source type, industry, or site- specific conditions

Will DEQ provide any emissions factor information or tools?

Yes. DEQ will provide Emissions Factors Search Tools and a Material Balance Calculator Tool that will be available at the same time as the reporting form. These tools provide CAO-approved sets of emissions factors for commonly used pieces of equipment. The emissions factors will be available by unit type, and will be ready to copy/paste into the reporting form. These are the tools DEQ plans to make available; instructions will be provided with the tools and Recommended Procedures document. 
 
Combustion Activities EF Search Tool: This tool provides CAO-approved sets of emissions factors for a variety of fossil-fuel burning combustion equipment. Biomass and hogged-fuel equipment are not covered.
 
Welding Activities EF Search Tool: This tool provides emissions factors from AP-42 and other sources for various types of welding rod and welding wire. The user will need to know their specific rod or wire type to use the tool.
 
Material Balance Calculator Tool: This tool provides a template for entering relevant product information from material Safety Data Sheets and converting material usage from volume (e.g., gallons/yr) to weight (lbs/yr), required in the reporting form.

​

Where can I find emission factor information?

​​​​DEQ does not currently have a database of approved emission factors available; below are a number of links to EPA and other state agencies resources that may be useful in establishing emission factors for activities at your facility.

USEPA Resources:

      Other Resources:

      Can I use other emission factor sources, and why does DEQ need the reference information?

      Yes, facilities are encouraged to seek out emission factors that best represent their emission units and operations. DEQ requires reference information for each emission factor to confirm that the selections are appropriate.

      CAO recommends that sources use specific emission factors for diesel generators. Does that apply to this inventory, too?
      While this air toxics emissions reporting effort allows emissions factors from any resource provided they accurately reflect operations at your facility, the use of the CAO emission factors for diesel generators is highly encouraged. These are provided in the DEQ Combustion Activities Emissions Factors Search Tool. More explanation about these units can be found on the Cleaner Air Oregon webpage, CAO FAQ for Step 2.

      ​Note that the CAO page recommends that the facility provide the manufacturer recommended emission factor for diesel particulate matter (DPM), when available. Following the hierarchy presented in FAQ #8 above, facilities are encouraged to follow this strategy and use the Emissions Factor Search Tool for DPM emission factor when other options are not available.​

      What are Safety Data Sheets?
      ​Safety Data Sheets, Material Safety Data Sheets, and Technical Data Sheets are standardized documents that contain occupational health and safety data for a particular chemical product. These sheets are prepared by chemical manufacturers and describe the chemical composition and properties of the product. DEQ may request your SDS information upon submittal.

      The ATEI Recommended Procedures document and the DEQ Material Balance Calculator Tool are provided to help source locate the appropriate information on the SDS sheets, and prepare it for the ATEI reporting form. 

      ​​Questions about Submitting the Air Toxics Emissions Inventory
      How do I submit my completed ATEI reporting form to DEQ?

      DEQ has created the Air Quality Document Upload Application, an online portal for facilities to submit documents to DEQ. This application provides a centralized place for facilities to submit electronic copies of their Air Toxics Reporting form as well as other documents like annual reports and semi-annul reports.

      In June 2021, DEQ will send an automated email to the contact emails DEQ has on file for each facility. This email will contain a PIN that will allow those individuals to use the portal and submit documents. Additional instructions and information will be provided when the AQ Document Upload Application launches in June. Contact your DEQ permitting office to confirm that your facility's contact information is up-to-date.

      The link to AQ Document Upload will be available on the Air Toxics Emissions Reporting webpage.​

      What documents should I submit with my Air Toxics Emissions Inventory?
      The AQ Document Upload Application will accept Excel spreadsheets (.xls and .xlsx) and pdf documents. The application will not accept zipped files. Facilities are asked not to submit Safety Data Sheet copies for their material usage unless specifically requested by DEQ as a follow-up inquiry. The 2020 AT EI from must be submitted as an Excel spreadsheet. ​

      Can I attach a cover letter with my ATEI submission?

      Space is provided in the second tab of the ATEI reporting form if you want to include a cover letter or additional notes with your ATEI submission, add it to. Please copy/paste the letter into a text box in this space (the window can be expanded as needed).​

      My facility has confidential business information or Information Exempt from Disclosure. What should I do?

      If a facility believes any information submitted to DEQ should be exempt from disclosure under the Oregon Public Records Law, ORS Chapter 192, they must read and follow the requirements in OAR 340-214-0130. It should be noted that emissions data is not considered confidential or trade secret and therefore is not exempt. If you are marking potentially exempt information in a spreadsheet, please identify it clearly in the file name and on each spreadsheet page. Facilities planning to claim exempt information are encouraged to communicate directly with DEQ for submission procedures. 

      ​​

      Contacts
      ​For questions specific to the 2020 inventory submittal, contact Clara Funk. For all other permitting questions, contact your regional DEQ permitting office.

      For LRAPA facilities, please contact LRAPA directly at 541-736-1056.​