Changes to Ohio Fee Emission Reporting for RY 2016 - SCC Updates and New Validation Errors



On February 1, 2017, Ohio EPA released their annual Air Services eNews letter related to fee emission reports (FER) titled, "Requirements to Submit Emissions Reports for 2016 by April 17, 2017."  In this letter, EPA identifies two significant changes that have been made to the Air Services software since last year's report, specifically:

  1. Changes to Source Classification Codes (SCCs) - U.S. EPA made hundreds of new SCCs available and deactivated many of the existing SCCs.  The deactivated SCCs are currently used by many Ohio facilities.  The deactivated SCCs will need to be updated before the 2016 reporting year FER can be submitted.
  2. New control equipment errors - The 2015 reporting year FER included new data validation "warnings" for pollutant data associated with air pollution control equipment.  For 2016, these warnings are now errors which will prevent the report from being submitted if the information is not specified.  Errors are associated with the control efficiency of each unit for each type of pollutant controlled

In order to help facilitate the SCC changes, Ohio EPA has released a document which details the Ohio facilities affected by the SCC changes.  This document also provides suggestions for what the new SCCs should be for affected emission units.  To download the Microsoft Excel file from Ohio EPA's website, click here.

Regarding control equipment errors, Ohio EPA has indicated that validation errors will be given for control equipment if all of the following conditions are met:

  • A Title V or synthetic minor facility is submitting an EIS;
  • An emissions unit has reported emissions of a criteria pollutant;
  • The emissions unit has control equipment associated with it;
  • The primary pollutant controlled and all of the required data elements are not supplied.

Control device information will need to be specified for values that are missing or outside of the valid range for the following items:

  • Criteria pollutant controlled
  • Operating control efficiency (valid range of 1-99%)
  • Capture efficiency (must be greater than zero)

Ohio EPA has identified specific primary pollutants for each control device type (e.g., condensers, thermal oxidizers, baghouses, etc.).  For the 2016 reporting year FER, the information listed above must be specified for at least one of the primary pollutants related to each control device in order to avoid validation errors.  The primary pollutants for the control device types are provided in Table 1 below:

Table 1 – Control Device Primary Pollutants

Control DevicePrimary Pollutants
NOxCOSO2PM10-filtVOCsNH3HCl
Adsorber      
Catalytic Convertor     
Condenser     
Catalytic Incinerator      
Cyclone/Multiclone      
Dry Scrubber      
Electrostatic Precipitator      
Filter/Baghouse      
Flare      
Fugitive Dust Suppression      
Other 
Passive Filter      
Settling Chamber      
Thermal Incinerator      
Wet Scrubber   

The changes listed above may take significant time to update in the Air Services facility profile.  As such, it is recommended that facilities plan for additional time to address these changes in the 2016 FER.

If you have any questions about these updates, please reach out to Andrew Dunagan at (614) 433-0733.