Frequently Asked Questions about the Emissions Inventory Questionnaire

Why does my facility have to fill out the EIQ?

What will happen if my facility does not fill out the EIQ or if it is submitted late?

What authority does the Division have to enforce the EIQ?

This document is a great burden to my company. To whom can I complain?

What is the purpose of the EIQ?

Who must file an EIQ?

What are the de minimis levels?

Who should sign the EIQ?

What is an Emission Point?

What is the Standard Industrial Classification (SIC)?

What is the Source Classification Code (SCC number)?

What is meant by Emission Factor?

What is meant by the Emission Factor units?

What is Annual Throughput?

What is the Maximum Hourly Design Rate?

How do I find overall efficiency of combined controlled devices?

How do I calculate the Actual Emissions?

How do I calculate Daily Emissions?

What is an MSDS sheet?

Where can I find information on toxic materials used at my facility?

Where should I send my EIQ?

How is the data reported on the EIQ used by the reviewing agencies?

Who can I contact?

Why does my facility have to fill out the EIQ?

The Clean Air Act mandates that all significant sources of air pollution must report their daily emissions. For sources that are in a non-attainment area, such as St. Louis is for Ozone, more demanding reporting information is required. The Emission Inventory Questionnaire is the mechanism by which the reporting is accomplished.

What will happen if my facility does not fill out the EIQ or if it is submitted late?

If the Questionnaire is not submitted by June 1st, the Division of Air Pollution Control will issue a Notice of Violation with the potential of closing down the facility.

What authority does the Division have to enforce the EIQ?

St. Louis City Ordinance #65645 establishes the authority that requires companies to supply air pollution control information on their facilities and defines the pollution level for which companies must report their emissions. Furthermore, it defines the rights of the Commissioner to request any additional information from each facility.

This document is a great burden to my company. To whom can I complain?

If your company is a category C plant, please call us at 613-7300 to discuss your particular situation. If your plant is a B or A category facility, you may want to discuss the EIQ and reporting requirements with the different elected representatives in the area in which your business operates. The EIQ and the reporting requirements developed by the various agencies are not meant to purposely hinder business. You are encouraged to discuss the EIQ with your respective trade group.

What is the purpose of the EIQ?

The Emission Inventory Questionnaire documents the emissions from each facility. Its purpose is to address the following:

How much pollution is emitted by a source;

Where the pollution is being emitted from;

What parameters govern the discharge of the pollution;

How the pollution is created;

How much material is involved in the production of the pollution;

What potential emissions are expected from the source;

What control measures are being implemented on the source; &

When the pollution is being emitted.

Who must file an EIQ?

Any installation that is a source of any regulated air contaminant (i.e., criteria pollutants and toxics) that fall in one of the five (5) reporting classifications (A1, A2, A3, B & C) that were established by the City of St. Louis Air Pollution Control Commission.

Exceptions:
• Gasoline Service Stations
• Architectural Coatings on buildings
• Auto Body Refinishing Shops
• Residential Fuel Use
• Elementary and High Schools
• Temporary Installations

What are the de minimis levels?

The de minimis level describes a specified level of total facility-wide emissions for each criterion pollutant.

Who should sign the EIQ?

The person at the facility who is legally responsible for the accuracy of the information reported.

What is an Emission Point?

There are two possible definitions for an emission point:
1. The process where the air pollutant is generated, or
2. Any specific point or area where an air pollutant is released from a process or operation into the ambient air.

What is the Standard Industrial Classification (SIC)?

This is a code that identifies each process with the type of industry that the process is in.

What is the Source Classification Code (SCC number)?

The Source Classification Code (SCC number) is an eight digit number associated with a unique process from which air pollutants are emitted. The SCC number is used to speciate the type of emissions from each particular process. The SCC number may be found in the follow document:

    Airs Facility Subsystem
    Source Classification Codes and Emission
    Factor Listing for Criteria Air Pollutants
    Publication #EPA-450/4-90-003

This document is also available through NTIS.

What is meant by Emission Factor?

An emission factor is an average value that relates the quantity of a pollutant released to the atmosphere with the amount of activity associated with the process releasing that pollutant. Such factors can be used to estimate the emissions from various sources generating air pollution. Emission factors for pollutants such as PM10, SOx, NOx, VOC, CO, Lead, and Toxics, for different processes can be found in government documents such as AP-42 and AIRS Subsystem Classification Manual.

What is meant by the Emission Factor units?

The term "Emission Factor Units" is really a misnomer. What is being requested is the throughput units. This insures that the person completing the EIQ will make certain that the units of the Emission Factor and the throughput are consistent. The following shows how the emission factor and the throughput should work together to give a quantity that the reviewer of the EIQ will recognize.

The Emission Factor is expressed as:

    pounds              Examples:       pounds/(gallon)
----------------                        pounds/(ton of coal)
throughput units                        pounds/(1000 gallons of oil)
                                        pounds/(million of ft^3)

The throughput is expressed as:

throughput units        Examples:       (gallons)/year
----------------                        (tons of coal)/year
    year                                (1000 gallons of oil)/year
                                        (million of ft^3)/year

When the Emission Factor is multiplied by the throughput, the amount of 
pollution produced per year by the process is obtained in terms of pounds
per year (prior to controls)

        pounds              throughput units        pounds
(Ef)---------------- * (Tr)----------------- = (Ea) ------
    throughput units            year                 year

Where:  Ef = Emission Factor
        Tr = Yearly Throughput
        Ea = Actual Emissions created by process

NOTE: In preparing Form 2.0, the number used should be in units consistent with the throughput. For example, if the Emission Factor is lbs/gallon, then the throughput should be in gallons/year. Thus, the Emission Factor unit entered on the form should be "gallon".

What is Annual Throughput?

Throughput is a term that is used to describe the total amount of material that a process uses in a designated period of time. There is a direct relationship between the amount of material that has gone through a process and the amount of pollution that is created. For the purpose of the EIQ, emissions for a process are directly proportional to the throughput. For example, if one (1) ton of NOx is produced by 100 million cubic feet of gas used by a boiler, then two (2) tons are produced when 200 million cubic feet of gas are used. The throughput should be in the units that are provided in the Source Classification Code (SCC) number

What is the Maximum Hourly Design Rate?

The Maximum Hourly Design Rate indicates the maximum amount of material a process can handle per hour of continuous operation by the equipment at the emission point. The units for this item must be consistent with units of the Annual Throughput. For example. if a process had an Annual Throughput of 300 gallons per year and is operated a total of 2080 hours per year, the operation rate would be .144 gallons per hour.

How do I find overall efficiency of combined controlled devices?

        Assume the following control devices are in place at a source:
        
        Control Device #1 = CEa = 90%
        Control Device #2 = CEb = 90%
        
        Each device has a VOC control efficiency of 90%. Therefore, the overall
        control efficiency of both is calculated as follows:

        (1-CEa/100)*(1-CEb/100)=(1-CEt/100)
        
        Solving for CEt:

        (1-CEa/100)*(1-CEb/100)-1= -CEt/100
        [1-(1-CEa/100)*(1-CEb/100)]*100 = CEt
        [1-(1-90/100)*(1-90/100)]*100 = 99%

How do I calculate the Actual Emissions?

The following equation can be used to calculate Actual Emissions:

                Ty*Ef*(1-CE/100)
        Ea = ------------------
                      Cf

        Where:
                Ea = Actual Emissions (Tons/Year)
                Ty = Annual Throughput (Throughput Units/Year)
                Ef = Emission Factor (lbs/Throughput Units)
                CE = Control Efficiency (%)
                Cf = Conversion Factor (2000 lbs/Ton)

How do I calculate Daily Emissions?

NOTE: The Daily Emissions of NOx, VOC, CO are required during the ozone season for St. Louis area facilities. These emissions should be reported on Form 2.0z.

                  Td*Ef*(1-CE/100)
        Ed = ----------------------
                        Cf

        Where:
                Ed = Actual Daily Emission (lbs/Day)
                Ty = Annual Throughput (Throughput Units/Year)
                CE = Control Efficiency (%)
                Cf = Conversion Factor (2000 lbs/Ton)
                Td = Daily Throughput (Throughput Units/Day)

What is an MSDS sheet?

MSDS is the acronym for Material Safety Data Sheet. The objective of the MSDS is to concisely inform you about the hazards of the materials you work with so that you can protect yourself and respond to emergency situations. The MSDS sheet gives information on:

• The material's identity, including it chemical and common names
• Hazardous ingredients
• Cancer-causing ingredients
• List of physical and chemical hazards and characteristics
• List of health hazards
• Limits to which a worker can be exposed
• Precautions and safety equipment
• Emergency and first aid procedures

Where can I find information on toxic materials used at my facility?

The information can be found on your facility's MSDS sheets.

Where should I send my EIQ?

The entire completed EIQ packet should be returned to:

and

Copies of Forms 1.0, 3.0, and 4.0, along with a check payable to "The Missouri Air Pollution Control Program" must be mailed to:

How is the data reported on the EIQ used by the reviewing agencies?

• Primarily, the annual EIQ data is used by the reviewing agency to address the ozone SIP
• CAA § 172 requires that non-attainment areas must have an inventory of actual emissions from all sources of relevant pollutants.
• RSMO 643.079 requires sources to pay emission fees beginning April 1, 1993.