FUGITIVE EMISSIONS REPORTING 

Do I have to report 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:

a source operates an emission unit with a permit or emission standard which regulates fugitive emissions.

• a 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.
• a source is listed in a specific source category identified as having fugitive emissions under the definition of potential to emit (Rule 116(m)).*
• a source reports fugitive emissions to the Toxic Release Inventory. *

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

          http://www.epa.gov/ttnchie1/le to search by emission type, and

          http://www.epa.gov/ttn/chief/ap42 to search by source category.

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).

Note that 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.

Reporting Thresholds

Pollutant                  **Operational Memorandum 13

                                        thresholds (per facility)         

Carbon monoxide          100 tons/year

Nitrogen oxides               40 tons/year 

Sulfur dioxide                  40 tons/year  

PM                                    25 tons/year  

PM-10                              15 tons/year  

VOCs                              10 tons/year  

Lead                                0.6 tons/year  

Pollutant                  ***Rule 212(7) "10% of significant"

                                          thresholds (per process),

                                     for fee-subject emissions from

                                       specified exempt processes

Carbon monoxide            10 tons/year

Nitrogen oxides                 4 tons/year 

Sulfur dioxide                    4 tons/year  

PM                                  2.5 tons/year  

PM-10                            1.5 tons/year  

VOCs                                4 tons/year  

Lead                            0.06 tons/year  

SOURCE FORM

How do I determine the location coordinates for my facility if it covers a large area?

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 determing the location coordinates for the facility.

Where can I find the proper North America n Industrial Classification System (NAICS) code for my 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.

Why have location coordinates changed to latitude and longitude measurements in decimal degrees?  What are the collection method fields?
These changes have been made to make MAERS more compatible with EPA 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. 

STACK FORM

If I do not report a stack, do I still need to report the emissions coming from the stack?

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 SV-101 Instructions & 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 SV-101 forms in your ROP application.

EMISSION UNIT FORM

What emission units must be included in MAERS?

Which emission units must be included in MAERS depends on whether the facility is subject to the renewable operating permit (ROP) program. If a facility is NOT subject to the ROP program it should include any emission unit (1) included in a permit to install including opt-out permits (2) grand-fathered or (3) not excluded from exemption per Rule 278, and is exempted under Rule 279-290 and listed in the Rule 201 exemption list. If a facility is subject to the ROP program, it should include any emission unit that (1) is included in the ROP; (2) meets the criteria for non-ROP sources (above); or (3) 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.

My facility has a collection of space heaters covered under an opt-out permit. Can the collection of space heaters be reported under one emission unit? These space heaters must be reported in MAERS not because they are found in the Rule 201 Exemption List on the Emissions Unit Instructions but because they are in a permit to install.

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

If I have multiple emission units that meet one of the Rule 201 Exemption List criterion on Emissions Unit Instructions do I have report them individually?

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 (New Source Performance Standard (NSPS) Subpart DC), and if so, they should be in an individual (separate) emission unit.

Rule 285(r)(iv) exempts "cleaning" On the Emissions Unit Instructions implies that this refers to cold cleaners. This seems to conflict with the exemption found in Rule 281(h). For example if I have cold cleaners that have air/vapor interfaces exceeding ten square feet whose total throughput is less than 1000 gallons per year, do I have to include them in my MAERS report?

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.

Since we don't have to report toxic emissions, do I need to include my chrome-plating tanks in my MAERS report?

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.

I'm an ROP facility and I have a grandfathered emission unit below the 10% significant levels in Rule 278, do they need to be included in MAERS?

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.

Are there any changes in the Rule 201 Exemption List (Emission Unit Instructions) from last year?

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

The only emission unit at our facility is a boiler that is subject to NSPS Subpart Dc. We are required to submit a MAERS report, but our boiler is Rule 201 exempt and does not have to be included in MAERS (i.e., it is not listed in the Rule 201 Exemption List found in the Emission Unit Instructions). What forms do we fill out to complete our MAERS report?

Complete the Source, Contact and Signature/Password Forms.

REPORTING GROUP FORM

What is the difference between a flexible group and a reporting group?

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.

Can I make a reporting group containing a coating booth with a permit to install and a coating booth that is exempt under Rule 287(c)?

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

ACTIVITY FORM

Many SCC's have a capacity stated in a range. Should I use the equipment's design capacity or my operating rate to select the proper SCC?

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

I understand that I should only provide one material description per SCC. If I have a coating line that uses numerous water-based and solvent-based coatings, should I add the gallons of water-based and solvent-based paints together and report the sum for the material throughput and provide the weighted average of all of these coatings for the VOC content and density on the A-101 form?

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.

If the SCC corresponds to paint manufacturing, do I need to fill out the VOC content and density fields on the Activity Form?

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

When using mass balance to calculate VOC emission from coating booth, why is it necessary to provide an accurate weighted average of the density and VOC content of the coatings?

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 (EPA).

EMISSIONS FORM

If my emission unit only emits chlorine, do I have to complete an Emissions form since these are toxic emissions and not particulate matter or VOCs?

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.

How old can my stack test data be?

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 U.S. EPA 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.

SUBMITTING MAERS REPORT

Why do I get errors when I run the completeness check before I start working on this year's data?

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.  

Can I submit data that contains errors?

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.

OTHER

If a new owner takes over a facility midway through the reporting year, who should file the MAERS report and who should pay the fees?

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