FREQUENTLY ASKED QUESTIONS

• MAERS LOG-ON 
• REPORTING FUGITIVE EMISSIONS
• REPORTING THRESHOLDS
• MAERS FORMS:
  1. SOURCE FORM
  2. STACK FORM
  3. EMISSION UNIT FORM
  4. REPORTING GROUP FORM
  5. ACTIVITY FORM
  6. EMISSIONS FORM
• SUBMITTING A MAERS REPORT
• RULES AND OP-MEMOS
• NAICS CODES
• SCC CODE QUERY
• FACT SHEETS
• 208A INFORMATION AND FORMS
• ROP CERTIFICATION AND DEVIATION FORMS
• OTHER MAERS QUESTIONS
• CONTACTS

REPORTING FUGITIVE EMISSIONS 

The requirement to report annual emissions includes fugitive and other non-stack emissions, as well as emissions from releases where the emissions are quantifiable. Some examples of specific instances where fugitive emissions must be reported are as follows:

• The source operates an emission unit with a permit or emission standard which regulates fugitive emissions.
• The source operates a process or process equipment described in an AQD fact sheet which requires calculation of fugitive emissions. Fugitive emissions shall be reported for the emission unit(s) to which the fact sheet applies.
• The source is listed in a specific source category identified as having fugitive emissions under the definition of potential to emit (Rule 116(m)).*
• The source reports fugitive emissions to the Toxic Release Inventory.*

Further information on fugitive emissions may be obtained from the following USEPA websites:

• Search by Emission Type: http://www.epa.gov/ttnchie1/le
• Search by Source Category: http://www.epa.gov/ttn/chief/ap42

To identify processes with fugitive emissions, select a document of interest on these websites. Select "find" while using the term "fugitive" for the specific emission type or source category.

Fugitive, non-stack, and release emissions must be considered when determining if a company is required to report emissions as specified in Operational Memo 13.** These emissions must also be included when determining whether to report emissions from exempt processes or process equipment under Rule 212(7).

AQD may require reporting of a specific air contaminant if such reporting is considered by the Department as necessary (and is specifically requested by the Department) for the proper management of the air resources (Rule 2).

*For exempt processes referenced in Rule 212(7), reporting is required if the process is subject to a process-specific emission limitation or standard or if the total emissions from the process exceed 10% of the significance levels*** described in the following table.

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REPORTING THRESHOLDS 

*Operational Memorandum 13 Thresholds 

Rule 212(7) - "10% of Significant" Thresholds (per process) for Fee Subject Emissions from Specified Exempt Processes 

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SOURCE FORM 

The location coordinates provided must be within the facility boundaries. There are no requirements as to where the reading must be taken; however, it is probably best to give the coordinates as close to the center of the facility as possible. In the MAERS web portal under the MAERS Report tab and the Source form there are a "Get Lat/Lon" and a "Map by Lat/Long" button to help determine the location coordinates for the facility.

The proper NAICS code can be found in a reference table on the MAERS Support Resources web page that is located on this internet site.

These changes have been made to make MAERS more compatible with USEPA reporting requirements. For existing sources, locations have been converted from UTMs to decimal degrees, but the data collection methods must be provided. These fields provide some assurance regarding the source of the location coordinates.

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STACK FORM 

Yes, assuming the emissions come from a reportable emission unit. Emissions are reported at the emission unit level and not the stack level. If you do not report a stack because emissions fall below the stack reporting thresholds identified in the Stack Form Instructions and Examples, you still have to account for those emissions. Therefore, even though you do not report a stack, you do report the emission unit that is connected to the stack and all associated emissions.

Note, it is highly recommended that facilities subject to the ROP program report all stacks with applicable requirements. Stacks with applicable requirements must be reported in the ROP renewal application. If these stacks are reported in MAERS you will not have to complete stack forms in your ROP application.

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EMISSION UNIT FORM 

Which emission units must be included in MAERS depends on whether the facility is subject to the renewable operating permit (ROP) program.

Facilities NOT subject to the ROP program it should include any emission unit:

• 208a subject?
• Included in a permit to install including opt-out permits;
• Grand-fathered; or
• Not excluded from exemption per Rule 278, exempt under Rule 279-290 and listed in the Rule 201 exemption list.

ROP subject facilities should include any emission unit that:

• Is included in the ROP;
• Meets the criteria for non-ROP sources (above); or
• Emits greater than 10% of any of the significant levels listed in Rule 119(e).

Please see the diagram in the Emissions Unit Instructions & Examples for the Emissions Unit Form.

Yes. Simply be certain to fully describe the equipment in the "Operator's Emission Unit Description" field.

No. In general, if you have several Rule 201 exempt emission units that must be reported in MAERS, they can be reported together as long as they have similar rated capacities and all units are subject to an identical state or federal regulation (see exception below). It is acceptable to report multiple pieces of equipment (such as space heaters) as one emission unit when the equipment is listed in the Rule 201 Exemption List on Emissions Unit Instructions and there is an aggregate throughput threshold for reporting to MAERS. Be certain to fully describe the equipment on the "Operator's Emission Unit Description" field.

Note: Emissions from other Rule 201 exempt emission units having common activities may be combined and reported at the Reporting Group level.

However, sometimes it may not be a good idea to combine them together. For example, some facilities are tempted to aggregate boilers found in Rule 282(b) into one emission unit. Some of these boilers could be subject to a federal standard (such as New Source Performance Standard (NSPS) Subpart Dc), and if so, they should be a separate emission unit.

Both Rule 285(r)(iv) and Rule 281(h) exempt cold cleaners. Rule 281(h) only applies to cold cleaners with an air/vapor interface less than ten square feet. Since your cold cleaners have an air/vapor interface greater than ten square feet, they are exempt under Rule 285(r)(iv) and not Rule 281(h). However, as explained in the Emissions Unit Instructions, your cold cleaners would only have to be reported if together they used more than 1000 gallons of cleaner in a year. Since their total throughput was less than 1000 gallons, you do not have to include them in your MAERS report. However, per the above discussion, if the cold cleaners are located at a facility subject to the ROP program, emissions from the cold cleaners should be reported.

Emission units, including chrome-plating tanks, have to be reported to MAERS in accordance with the answer to the first question in this section. Although you do not have to report toxic emissions, criteria pollutant emissions, such as VOCs and particulate matter have to be reported in MAERS. The emission calculation fact sheet for electroplating operations states under the emission factor table that hexavalent chromium emissions may be reported to MAERS, however, they are not required to be reported.

Under the "Who Must File" heading of the MAERS Introduction, the instructions clearly state that sources are required to file an annual report for each location with source emissions for criteria pollutants. Criteria pollutants are identified under the "Definitions" heading in the MAERS Introductions.

A grandfathered emission unit is an emission unit that was installed before August 15, 1967 , that is not covered by a permit exemption in Rules 279-290, and that was never modified, reconstructed, or relocated after August 15, 1967. All grandfathered emission units must be included in MAERS.

If the emission unit was installed prior to August 15, 1967 but is covered by one of the permit exemptions and is not excluded from exemption per Rule 278, then it is not considered a grandfathered emission unit with respect to MAERS. This emission unit should be included in MAERS if it meets any of the following: It is located at an ROP subject facility; Its emissions exceed 10% of the significant thresholds; or, it is identified in and meets the criteria in the Rule 201 Exemption List found in the Emissions Unit Instructions.

No. The Rule 201 Exemption List is the same as it was last year.

Complete the Source, Contact and Signature/Password Forms.

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REPORTING GROUP FORM 

A flexible group is used in the renewable operating permit (ROP) program to combine two or more emission units that have common or identical requirements.

A reporting group is used in MAERS to combine two or more emission units with identical activities (SCC's) to simplify reporting emissions for these emission units. Sometimes, but not always, it makes sense to create a reporting group in MAERS for the emission units comprising a flexible group in the ROP.

Yes, as long as both coating lines have the same SCC.

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ACTIVITY FORM 

Use the design capacity and not the typical operating rate when selecting your SCC.

No. Since there is an SCC for water-based paints and an SCC for solvent-based paints, report each SCC separately. All of the various water-based paints should be totaled and entered for the material throughput. For the VOC content and density fields, enter the weighted average of the water-based paints. Follow the same procedure for the solvent-based paints.

You will not get errors for not completing the VOC content and density fields on the Activity Form for paint manufacturing.

An accurate density and VOC content helps the Air Quality Division ensure that the reported emissions are accurate. In addition, the Air Quality Division is required to report density and VOC content of coatings to the U.S. Environmental Protection Agency (USEPA).

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EMISSIONS FORM 

Even though your emission unit only emits chlorine, you still have to complete an Emissions form. You are not required to report toxic emissions, so you do not have to report your chlorine emissions. However, you do have to report at least one criteria pollutant. Therefore, you still report either particulate matter or VOC on the Emissions form and report the emissions as zero.

Under the "Who Must File" heading (MAERS Introductions), the instructions clearly state that sources are required to file an annual report for each location with source emissions for criteria pollutants. Criteria pollutants are identified under the "Definitions" heading in the Introductions. Currently, reporting of toxic emissions in MAERS is voluntary.

More important than the age of the test are the following: results should be from the most recent test; the test must have been conducted in accordance with USEPA protocols; and the test must have been conducted under conditions which represent current operations. A test meeting these criteria will be acceptable as the basis for reporting to MAERS.

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SUBMITTING A MAERS REPORT 

You will get errors before you start working on the database because some information must be entered this year even though it was entered last year. The material throughput on the Activity form and all Emissions forms have to be completed because the Air Quality Division does not carry these values forward from year to year. Also, any new field requirements since the last MAERS submittal (such as the Supplemental Portable form for portable sources ) will need to be addressed.

MAERS will not allow you to submit your data if any required data is missing. These errors will appear in "red" on your browser screen. You can submit your data that is error flagged in "yellow" text if not corrected. If you submit a MAERS Report with errors that can be fixed, the Air Quality Division may send the database back and have you correct the errors.

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RULES AND OP MEMOS 

• Operational Memorandum 13: Criteria Pollutant Threshold Levels for the Emissions Inventory - View
• Rule 2: Annual Reports - View
• Rule 116(m): Definition of Potential to Emit - View
• Rule 119(e): Definition of Significant - View
• Rule 212(7): ROP Source Fee Calculations - View
• Rule 278: Exclusion from Exemption - View
• Rules 279 through 290: Exemptions - View
• Rule 281(h): Cold Cleaner Exemption - View
• Rule 282(b): Furnace, Oven and Heater Exemption - View
• Rule 285(r)(iv): Cleaning Exemption - View

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OTHER MAERS QUESTIONS 

The new owner is responsible for filing the MAERS report and paying the applicable fees to the Air Quality Division.

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CONTACTS: 

• AQD MAERS Coordinator Renee Denison: denisonr@michigan.gov or (517)-373-7051
• AQD District Office Contact Information - View
• For web page technical issues contact Kirsten Clemens at: clemensk@michigan.gov or (269)-567-3548