INTRODUCTION
Emission factors and emission inventories have long been fundamental tools for air quality
management. Emission estimates are important for developing emission control strategies,
determining applicability of permitting and control programs, ascertaining the effects of sources and
appropriate mitigation strategies, and other related applications by an array of users, including
federal, state, and local agencies, consultants, and industry. Data from source-specific emission tests
or continuous emission monitoring systems (CEMS) are usually preferred for estimating a source’s
emissions because those data provide the best representation of the tested source’s emissions.
However, test data from individual sources are not always available and, even then, may not reflect
the variability of actual emissions over time. Thus, emission factors are frequently the best or only
method available for estimating emissions, in spite of their limitations.
What Is An AP-42 Emission Factor?
An emission factor is a representative value that attempts to relate the quantity of a
pollutant released to the atmosphere with an activity associated with the release of that pollutant.
These factors are usually expressed as the mass of the pollutant divided by a unit mass, volume,
distance, or duration of the activity emitting the pollutant (e.g., kilograms of particulate matter
emitted per megagram of coal burned). Such factors facilitate estimation of emissions from various
sources of air pollution. In most cases, these factors are simply averages of all available data of
acceptable quality, and are generally assumed to be representative of long-term averages for all
facilities in the source category (i.e., a population average).
The general equation for emission estimation is:
E = A x EF x (1-ER/100)
where:
E = emissions,
A= activity rate,
EF = emission factor, and
ER = overall emission reduction efficiency, %.
ER is further defined as the product of the control device destruction or removal efficiency
and the capture efficiency of the control system. When estimating emissions for a long time period
(e.g., one year), both the device and the capture efficiency terms should account for process upset
periods (e.g., startup, shutdown, and malfunction) as well as routine operations.
Emission factor ratings in AP-42 (discussed below) provide indications of the robustness, or
appropriateness, of emission factors for estimating the average emissions for a source activity.
Usually, data are insufficient to indicate the influence of various process parameters such as
temperature and reactant concentrations. For a few cases, however, such as estimating emissions
from petroleum storage tanks, this document contains empirical formulae (or emission models) that
relate emissions to variables such as tank diameter, liquid temperature, and wind velocity. Emission
factor formulae that account for the influence of such variables tend to yield more realistic
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estimates than would factors that do not consider those parameters.
The extent of completeness and detail of the emissions information in AP-42 is determined
by the information available from published references. Emissions from some processes are better
documented than others. For example, several emission factors may be listed for the production of
one substance: one factor for each of a number of steps in the production process such as
neutralization, drying, distillation, and other operations. However, because of less extensive
information, only one emission factor may be given for production facility releases for another
substance, though emissions are probably produced during several intermediate steps. There may be
more than one emission factor for the production of a certain substance because differing
production processes may exist, or because different control devices may be used. Therefore, it is
necessary to look at more than just the emission factor for a particular application and to observe
details in the text and in table footnotes.
The fact that an emission factor for a pollutant or process is not available from EPA does not
imply that the Agency believes the source does not emit that pollutant or that the source should not
be inventoried – rather, it simply means that EPA does not have enough data to develop or provide an
emission factor at this time.
Uses Of Emission Factors
Emission factors may be appropriate to use in various situations such as making source-specific
emission estimates for area-wide inventories. These inventories have many purposes, including ambient
dispersion modeling and analysis, control strategy development, and in-screening sources for
compliance investigations. Emission factor use may also be appropriate in some permitting applications,
such as in applicability determinations and in establishing operating permit fees.
Emission factors in AP-42 are neither EPA-recommended emission limits (e.g., best available
control technology or BACT, or lowest achievable emission rate or LAER) nor standards (e.g., National
Emission Standard for Hazardous Air Pollutants or NESHAP, or New Source Performance Standards or
NSPS). Use of these factors as source-specific permit limits and/or as emission regulation compliance
determinations is NOT recommended by EPA. Because emission factors essentially represent an
average of a range of emission rates, approximately half of the subject sources will have emission
rates greater than the emission factor and the other half will have emission rates less than the
emission factor. As such, a permit limit using an AP-42 emission factor could result in approximately
half of the sources being in noncompliance.
Also, for some sources, emission factors may be presented for facilities having air pollution
control equipment in place. Factors noted as being influenced by control technology do not
necessarily reflect the best available or state-of-the-art controls, but rather reflect the level of
(typical) control for which data were available at the time the information was published. Sources
often are tested more frequently when they are new and when they are believed to be operating
properly, and either situation may bias the results.
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As stated, source-specific tests or CEMS can determine the actual pollutant contribution from
an existing source better than emission factors. Even then, the results will be applicable only to the
conditions existing at the time of the testing or monitoring. To provide the best estimate of longer-
term (e.g., yearly or typical day) emissions, these conditions should be representative of the source’s
routine operations.
A material balance approach may also provide reliable average emission estimates for specific
sources. For some sources, a material balance may provide a better estimate of emissions than
emission tests would. In general, material balances are appropriate for use in situations where a high
percentage of material is lost to the atmosphere (e.g., sulfur in fuel, or solvent loss in an uncontrolled
coating process). In contrast, material balances may be inappropriate where material is consumed or
chemically combined in the process, or where losses to the atmosphere are a small portion of the
total process throughput (e.g., UV curing technique in coating process). As the term implies, one
needs to account for all the materials going into and coming out of the process for such an emission
estimation to be credible.
If representative source-specific data cannot be obtained, emissions information from
equipment vendors, particularly emission performance guarantees or actual test data from similar
equipment, is a better source of information for permitting decisions than an AP-42 emission factor.
When such information is not available, use of emission factors may be necessary as a last resort.
Whenever factors are used, one should be aware of their limitations in accurately representing a
particular facility, and the risks of using emission factors in such situations should be evaluated
against the costs of further testing or analyses.
There are various approaches to emission estimation, in a hierarchy of requirements and
levels of sophistication, that one should consider when analyzing the tradeoffs between cost of the
estimates and the quality of the resulting estimates. Where risks of either adverse environmental
effects or adverse regulatory outcomes are high, more sophisticated and more costly emission
determination methods may be necessary. Where the risks of using a poor estimate are low, and the
costs of more extensive methods are unattractive, then less expensive estimation methods such as
emission factors and emission models may be both satisfactory and appropriate. In cases where no
emission factors are available but adverse risk is low, it may even be acceptable to apply factors from
similar source categories using engineering judgment. Selecting the method to be used to estimate
source-specific emissions may warrant a case-by-case analysis considering the costs and risks in the
specific situation. All sources and regulatory agencies should be aware of these risks and costs and
should assess them accordingly.
Variability Of Emissions
Average emissions differ significantly from source to source and, therefore, emission factors
frequently may not provide adequate estimates of the average emissions for a specific source. The
extent of between-source variability that exists, even among similar individual sources, can be large
depending on process, control system, and pollutant. Although the causes of this variability are
considered in emission factor development, this type of information is seldom included in emission
test reports used to develop AP-42 factors. As a result, some emission factors are derived from tests
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that may vary by an order of magnitude or more. Even when the major process variables are
accounted for, the emission factors developed may be the result of averaging source tests that differ
by factors of five or more.
Air pollution control devices also may cause differing emission characteristics. The design
criteria of air pollution control equipment affect the resulting emissions. Design criteria include such
items as the type of wet scrubber used, the pressure drop across a scrubber, the plate area of an
electrostatic precipitator, and the alkali feed rate to an acid gas scrubber. Often, design criteria are not
included in emission test reports (at least not in a form conducive to detailed analysis of how varying
process parameters can affect emissions) and therefore may not be accounted for in the resulting
factors.
Before simply applying AP-42 emission factors to predict emissions from new or proposed
sources or to make other source-specific emission assessments, the user should review the latest
literature and technology to be aware of circumstances that might cause such sources to exhibit emission
characteristics different from those of other, typically existing sources. Care should be taken to assure
that the subject source type and design, controls, and raw material input are those of the source(s)
analyzed to produce the emission factor. The similarity between the subject source and the sources used to
develop the emission factor should be considered, as well as the age of the information and the user's
knowledge of technological advances.
Estimates of short-term or peak (e.g., daily or hourly) emissions for specific sources are often
needed for regulatory purposes. Using emission factors to estimate short-term emissions will add
further uncertainty to the emission estimate. Short-term emissions from a single specific source often
vary significantly with time (i.e., within-source variability) because of fluctuations in process operating
conditions, control device operating conditions, raw materials, ambient conditions, and other such
factors. Testing is usually conducted at normal operating conditions in order to demonstrate
compliance with an emission limit. Therefore, the emission factors developed from these tests
generally represent long-term, steady-state average emissions. Parameters that can cause short-term
fluctuations in emissions are generally avoided in testing and are not taken into account in test
evaluation. Thus, using emission factors to estimate short-term emissions will cause even greater
uncertainty. The AP-42 user should be aware of this limitation and should evaluate the possible
effects on the particular application.
To assess within-source variability and the range of short-term emissions from a source, one
needs either a number of tests performed over an extended period of time or continuous
monitoring data from an individual source. Generally, material balance data are not likely to be
sufficient for assessing short-term emission variability because the accuracy of a material balance is
greatly reduced for shorter time intervals. In fact, one of the advantages of a material balance
approach is that it averages out all of the short-term fluctuations to provide a good long-term
average.
Pollutant Terminology And Conventions
The factors in this document represent units of pollutants (or precursors for ozone) for which
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there are National Ambient Air Quality Standards (NAAQS). These are often referred to as "criteria"
pollutants. Factors may be presented also for hazardous air pollutants (HAPs) designated in section
112 of the Clean Air Act, and other regulated and unregulated pollutants. If the pollutants are organic
compounds or particulate matter, additional species or analytical information may be needed for
specific applications. It is often the case that the ideal measure of a pollutant for a specific application
may not be available, or even possible, because of test method or data limitations, costs, or other
problems. When such qualifications exist in AP-42, they will be noted in the document. If a pollutant is
not mentioned in AP-42, that does not necessarily mean that the pollutant is not emitted, but that
EPA does not have sufficient data to create an emission factor.
Many pollutants are defined by their chemical names, which often may have synonyms and
trade names. Trade names are often given to mixtures to obscure proprietary information, and the
same components may have several trade names. For assurance of the use of the proper chemical
identification, the Chemical Abstract Service (CAS) number for the chemical should be consulted
along with the list of synonyms. Some pollutants, however, follow particular conventions when
used in air quality management practices. The pollutant terminology and conventions currently
used in AP-42 are discussed below.
Particulate Matter
Terms commonly associated with the general pollutant, "particulate matter" (PM),
include PM-10, PM-X, total particulate, total suspended particulate (TSP), primary particulate,
secondary particulate, filterable particulate, and condensable particulate. TSP consists of matter
emitted in solid, liquid, and vapor forms, but exists in the ambient air as particulate solids or
liquids. Primary particulate matter includes solid, liquid, or gaseous material at the pressure and
temperature in the process or stack that would be expected to become a particulate at ambient
temperature and pressure. AP-42 contains emission factors for pollutants that are expected to be
primary particulate matter. Primary particulate matter includes matter that may eventually
revert to a gaseous condition in the ambient air, but it does not include secondary particulate
matter. Secondary particulate matter is gaseous matter that may eventually convert to
particulate matter through atmospheric chemical reactions. The term "total particulate" is used
in AP-42 only to describe the emissions that are primary particulate matter. The term "total PM-
X" is used in AP-42 to describe those emissions expected to become primary particulate matter
smaller than "X" micrometers (µm) in aerodynamic diameter. For example, "PM-10" is emitted
particulate matter less than 10 µm in diameter. In AP-42, "Total Particulate" and "Total PM-X"
may be divided into "Filterable Particulate," "Filterable PM-X," "Condensable Organic
Particulate," and "Condensable Inorganic Particulate." The filterable portions include the material
that is smaller than the stated size and is collected on the filter of the particulate sampling train.
Unless noted, it is reasonable to assume that the emission factors in AP-42 for processes that
operate above ambient temperatures are for filterable particulate, as defined by EPA Method 5 or its
equivalent (i.e., a filter temperature of 120°C (248°F)) or under certain circumstances as defined by
EPA Method 5B (i.e., a filter temperature of 160°C (320°F)). The condensable portions of the
particulate matter consist of vaporous matter at the filter temperature that is collected in the
sampling train impingers and is analyzed by EPA Method 202 or its equivalent. AP-42 follows
conventions in attempts to define total particulate and its subcomponents, filterable particulate,
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condensable particulate, and PM-10 and their interrelationships. Because of test method and data
limitations, this attempt may not always be successful, and some sources may not generate such
components.
Because emission factors in AP-42 are usually based upon the results of emission test
reports, in the past AP-42 emission factors were not specific for designating the “type” of PM and
often may adequately characterize only the in-stack filterable PM-10. Updated parts of the AP-42
series have used a clearer nomenclature for the various particulate fractions (e.g., filterable PM,
filterable PM-10, filterable PM-2.5, total PM, total PM-10, and total PM-2.5). It is reasonable to
assume that, where AP-42 does not define the components of particulate clearly and specifically,
the PM-10 factor includes only the filterable portion of the total PM-10. Therefore, an evaluation of
potential condensable particulate emissions should be based upon additional data or engineering
judgment.
As an additional convention, users should note that many hazardous or toxic compounds may
be emitted in particulate form. In such cases, AP-42 factors for particulate matter represent the total,
and factors for such compounds or elements are reported as mass of that compound or element.
Organic Compounds
Precursors of the criteria pollutant ozone include organic compounds. "Volatile organic
compounds" (VOC) are required in a State Implementation Plan (SIP) emission inventory. VOCs have
been defined by EPA (40 CFR 51.100, February 3, 1992) as "any compound of carbon, excluding
carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium
carbonate, which participates in atmospheric chemical reactions." There are a number of
compounds deemed to have "negligible photochemical reactivity,” and these are therefore exempt
from the definition of VOC. These exempt compounds include methane, ethane, methylene
chloride, methyl chloroform, many chlorofluorocarbons, and certain classes of perfluorocarbons.
Additional compounds may be added to the exempt list in the future.
Though the regulatory definition of VOC is followed in ozone control programs, the exempt
organic compounds are of concern when developing the complete emission inventory that is needed
for broader applications. Therefore, this document strives to report the total organic emissions and
component species, so that the user may choose those that are necessary for a particular
application. In many cases, data are not available to identify and quantify either all the components
(such as some oxygenated compounds that are not completely measured by many common test
methods), the total organics, or other variations of the quantities desired. In such cases, the available
information is annotated in an effort to provide the data to the user in a clear and unambiguous
manner. It is not always possible to present a complete picture with the data that are available.
The term "total organic compounds" (TOC) or “total hydrocarbons” (THC) is used in AP-42 to
indicate all VOCs and all exempted organic compounds including methane, ethane,
chlorofluorocarbons, toxics and HAPs, aldehydes, and semivolatile compounds. Component species
are separately identified and quantified, if data are available, and these component species are
included in TOCs. Often, a test method will produce a data set that excludes methane. In such
cases, the term total nonmethane organic compound (TNMOC) may be used. Here, methane will be
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separately quantified if the data are available. Factors are nominally given in terms of actual weight
of the emitted substance. However, in some cases where data do not allow calculation of the result
in this form, factors may be given "as methane," "as propane," etc. Once the species distribution is
determined, actual mass can be calculated based on molecular weight of each compound
represented.
Many organic compounds are also HAPs. Where such species can be quantified, an emission
factor representing their individual mass will be presented. This quantity will also be included in the
total VOC and/or TOC factors, as appropriate. To avoid double counting regarding permit fees, etc.,
this fact should be taken into consideration.
Sulfur Dioxide
The primary product from combustion of sulfur is sulfur dioxide (SO2). However, other
oxidation states are usually formed. When reported in this document, these compounds are jointly
referred to as SOx, or oxides of sulfur. Hence, SO2 means sulfur dioxide, and SOx means the
combination of all such emissions reported on the basis of the molecular weight of SO2.
Oxides Of Nitrogen
The primary combustion product of nitrogen is nitrogen dioxide (NO2). However, several
other nitrogen compounds are usually emitted at the same time (e.g., nitric oxide or NO, nitrous
oxide or N2O, etc.), and these may or may not be distinguishable in the available test data. They are
usually in a rapid state of flux, with NO2 being, in the short term, the ultimate nitrogen product
emitted or formed shortly downstream of the stack. The convention followed in AP-42 is to report
the distinctions wherever possible, but to report total NOx on the basis of the molecular weight of
NO2.
Lead
Lead is emitted and measured as particulate and often will be reported for a process both
separately and as a component of the particulate matter emission factor. Lead may exist as pure
metal or as compounds. The convention followed in AP-42 is that all emissions of lead are expressed
as the weight of elemental lead. Lead compounds will also be reported on the basis of the weight of
those compounds, if the information is available.
Toxic, Hazardous, And Other Noncriteria Pollutants
Hazardous Air Pollutants (HAP) are defined for EPA regulatory purposes in Title III of the
1990 Clean Air Act Amendments (CAAA). However, many states and other authorities designate
additional toxic or hazardous compounds, organic or inorganic, that can exist in gaseous or
particulate form. Also, as mentioned, compounds emitted as VOCs may be of interest for their
participation in photochemical reactivity. Few EPA Reference Test Methods exist for these
compounds, which may come from the myriad sources covered in this document. However, test
methods are available to allow reasonably reliable quantification of many compounds, and
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adequate test results are available to yield estimates of sufficient quality to be included in this
document. Where such compounds are quantified herein with emission factors, they represent the
actual mass of that compound emitted. Totals for PM or VOC, as appropriate, are inclusive of the
component species unless otherwise noted. There are a limited number of gaseous hazardous or
toxic compounds that may not be VOCs, and whenever they occur they will be identified separately.
Examples Of Emission Factor Application -
Calculating carbon monoxide (CO) emissions from distillate oil combustion serves as an
example of the simplest use of emission factors.
Consider an industrial boiler that burns 90,000 liters of distillate oil per day. In Section 1.3 of
AP-42, "Fuel Oil Combustion," the CO emission factor for industrial boilers burning distillate oil is 0.6
kilograms (kg) CO per 103 liters of oil burned.
Then CO emissions
= CO emission factor x distillate oil burned/day
= 0.6 x 90
= 54 kg/day
In a more complex case, suppose a sulfuric acid (H2SO4) plant produces 200 Mg of 100
percent H2SO4 per day by converting sulfur dioxide (SO2) into sulfur trioxide (SO3) at 97.5 percent
efficiency. In Section 8.10 of AP-42, "Sulfuric Acid," the SO2 emission factors are listed according
to the SO2-to-SO3 conversion efficiencies in whole numbers. The reader is then directed by
footnote to an interpolation formula that may be used to obtain the emission factor for 97.5
percent SO2-to-SO3 conversion.
The emission factor for kg SO2/Mg 100% H2SO4
= 682 - [(6.82)(% SO2-to-SO3 conversion)]
= 682 - [6.82)(97.5)]
= 682 - 665
= 17 kg
In the production of 200 Mg of 100 percent H2SO4 per day, SO2 emissions are calculated:
SO2 emissions
= 17 kg SO2 emissions/Mg 100 percent H2SO4 x 200 Mg 100 percent
H2SO4/day
= 3400 kg/day
Emission Factor Ratings
A factor’s rating is a general indication of the reliability, or robustness, of that factor.
Historically, each AP-42 emission factor was given a rating from A through E, with A being the best.
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These ratings were assigned based on the estimated reliability of the tests used to develop the factor
and on both the amount and the representative characteristics of those data. In general, factors
based on many observations, or on more widely accepted test procedures, were assigned higher (i.e.,
better) rankings. Conversely, a factor based on a single observation of questionable quality, or one
extrapolated from another factor for a similar process, was rated much lower. Because the older
emission factors were based on source tests, modeling, mass balance, or other information, factor
ratings varied greatly.
From 1995 to 2018, the quality rating of AP-42 was letter based. The quality rating of
AP-42 data helped identify good data, even when it was not possible to extract a factor
representative of a typical source in the category from those data. For example, the data from a
given test may be good enough for a data quality rating of "A," but the test may be for a unique
feed material, or the production specifications may be either more or less stringent than at the
typical facility. Hence, the AP-42 emission factor rating is an overall assessment of how good a
factor is, based on both the quality of the test(s) or information that is the source of the factor
and on how well the factor represents the emission source. Higher ratings are for factors based
on many unbiased observations, or on widely accepted test procedures. For example, ten or
more source tests on different randomly selected plants would likely be assigned an "A" rating
if all tests are conducted using a single valid reference measurement method. Likewise, a single
observation based on questionable methods of testing would be assigned an "E," and a factor
extrapolated from higher-rated factors for similar processes would be assigned a "D" or an "E."
AP-42 emission factor quality ratings from 1995-2018 were thus assigned:
A — Excellent. Factor is developed from A- and B-rated source test data taken from
many randomly chosen facilities in the industry population. The source category
population is sufficiently specific to minimize variability.
B — Above Average. Factor is developed from A- or B-rated test data from a
"reasonable number" of facilities. Although no specific bias is evident, it is not clear
if the facilities tested represent a random sample of the industry. As with an A
rating, the source category population is sufficiently specific to minimize variability.
C — Average. Factor is developed from A-, B-, and/or C-rated test data from a
reasonable number of facilities. Although no specific bias is evident, it is not clear if
the facilities tested represent a random sample of the industry. As with the A
rating, the source category population is sufficiently specific to minimize variability.
D — Below Average. Factor is developed from A-, B- and/or C-rated test data from a
small number of facilities, and there may be reason to suspect that these facilities
do not represent a random sample of the industry. There also may be evidence of
variability within the source population.
E — Poor. Factor is developed from C- and D-rated test data, and there may be reason
to suspect that the facilities tested do not represent a random sample of the
industry. There also may be evidence of variability within the source category
population.
Since 2018, to reduce the subjectivity of AP-42 emission factors, a more objective rating system
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for test reports was developed (see Appendix A of the Recommended Procedures for Development of
Emissions Factors and Use of the WebFIRE Database). The rating system is intended to produce
unbiased and consistent assessments of the information included in test reports which, in turn, will help
us to better characterize the process and the quality of emissions values.
The rating system consists of a set of objective review questions developed for the EPA’s manual
and instrumental test methods that assess the quality of the process, control device, and measurement
data collected during an emissions test in the following 8 criteria areas:
• General information,
• Process and control device information,
• Sampling locations,
• Test methods and reporting requirements,
• Sampling equipment calibrations,
• Sample recovery,
• Laboratory analysis, and
• Documentation.
Each factor is given a Factor Quality Index (FQI) number that represents the derived emission
factor’s ability to estimate emissions for the entire national population. The FQI is dependent upon
the composite test rating (CTR), which is a weighted average quality indicator for a group of test
reports, as well as the number of tests used to develop the emission factor. The FQI is used to create
the three quality indicators used to characterize the calculated emission factor:
• Highly representative is assigned to emission factors having the lowest FQI rating.
• Moderately representative is assigned to emission factors having an intermediate FQI
rating.
• Minimally representative is assigned to emission factors having the highest FQI rating.
For more information on the new rating system for emission factors, please see Appendix A of
the Recommended Procedures for Development of Emissions Factors and Use of the WebFIRE
Database.
Public Review Of Emission Factors
Since AP-42 emission factors may have effects on most aspects of air pollution control and
air quality management (e.g., operating permit fees, and SIP attainment emission inventories), these
factors are always made available for public review and comment before publication.
Announcements for new draft factors are posted on the AP-42 website and an email is sent out
through the CHIEF Listserv. To subscribe to the CHIEF Listserv, send an email to join-
chief@[Link]. The Agency encourages all interested parties to take every opportunity to
review factors and to provide information for factor quality improvement. Toward this objective, EPA
invites comments and questions about AP-42, and users are invited to submit any data or other
information in accordance with this procedures document. Comments and questions can be
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submitted to efcomments@[Link].
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