Emissions Inventory Reporting Requirements
An emission inventory (EI) is a listing, by source, of the amounts of pollutants actually emitted to the atmosphere over a period of time.
The emission inventory is required by Code of Federal Regulations 40 CFR Part 51 Subpart A - (Air Emissions Reporting Requirements) and requires that emissions data be collected from certain facilities by all state agencies responsible for regulating air pollution and submitted to the EPA. The EPA uses these submittals to build the National Emissions Inventory (NEI). The National Emissions Inventory is a national database of comprehensive estimate of annual air emissions of criteria pollutants, criteria precursors, and hazardous air pollutants from point, nonpoint, and mobile air emissions sources. An updated version of the NEI is released every three years.
Facilities whose potential emissions equal or exceed thresholds shown in the tables below for any of the indicated pollutants are required to submit actual emissions data to the Division of Air Pollution Control by June 1 following the year of inventory.
** Effective February 12, 2018, there is a new State of Tennessee Rule for Emissions Inventory Requirements that applies to facilities meeting the criteria specified in 40 CFR Part 51 Subpart A. The detailed information for this rule is available on the Tennessee Secretary of State website at http://publications.tnsosfiles.com/rules/1200/1200-03/1200-03-10.20180212.pdf. **
Calendar Year 2017 Thresholds1
|Pollutant||Triennial Type B sources|
|(5) Lead||≥0.5 (actual)|
|(6) Primary PM10||≥100|
|(7) Primary PM2.5||≥100|
1Thresholds for point source determination are shown in tons per year of potential to emit as defined in 40 CFR part 70, with the exception of lead. Reported emissions must be in actual tons emitted for the required time period.
Calendar Year 2018 Thresholds1
|Pollutant||Every-year (Type A sources)2|
|(5) Lead||Not applicable|
|(6) Primary PM10||≥250|
|(7) Primary PM2.5||≥250|
1Thresholds for point source determination are shown in tons per year of potential to emit as defined in 40 CFR part 70. Reported emissions must be in actual tons emitted for the required time period.
2Type A sources are a subset of the Type B sources and are the larger emitting sources by pollutant.
Tennessee Code Annotated (TCA) Section 68-201-105(b)(2) authorizes the Division of Air Pollution Control to require facilities to furnish information, including emission inventories, as necessary to maintain the air resources of the state. Individual facilities are responsible for providing complete and accurate estimates of their emissions. The Division is responsible for reviewing and accepting or rejecting such estimates. Facilities identified by the Division as needing to participate in the Calendar Year 2017 emissions inventory will receive notifications in March 2018. The completed EI must be submitted by June 1, 2018, via email to APC.Inventory@tn.gov.
Please notice that:
Emission inventory data must be submitted in an Emissions Database Layout (EDL) file in Excel format (See template).
The 2016 EDL file includes a Total Emissions Table (total allowable and total actual emissions). The Division requires facilities to report their permitted allowable emissions limits and total actual calendar emissions.
An EDL Checker Program developed by the Division is available for quality assuring emissions data in the EDL. Please access the program links below.
Emission inventory submittals must be complete and accurate.
Any facility that fails to respond to an EI submittal request by June 1, 2017, may be subject to enforcement action for violation of TCA 68-201-105(b)(2).
PM10-FIL, PM10-PRI, PM-25-FIL, PM25-PRI and PM-CON are the only acceptable pollutant codes for submittal of particulate matter. If PM-FIL or PM-PRI is submitted, the EDL file will be returned for the facility to revise.
Although reporting of hazardous air pollutants (HAPs) is voluntary, we strongly encourage you to report individual HAP emissions. The individual HAP-VOC emissions for each process must be reported in total VOC emissions for each process. The total VOC emissions must be greater than or equal to the HAP-VOC emissions.
All pollutants specified in the tables above must be reported, not just the pollutants that qualify the source as a point source.
Minor sources, conditional major sources with federally enforceable permit limits, and sources that are major for HAP only are not required to report emissions. Any sources with actual lead emissions of 0.5 tons per year or more must submit their emissions on a triennial basis.
Emission inventory data are used for:
- Attainment/nonattainment designations for criteria air pollutants
- State Implementation Plans (SIPs) for attainment and maintenance of the NAAQS
- Rule development
- PSD permit reviews
- Air Quality & Human Health Effects Research
Emission Inventory Group