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Guidance for AFS Federal Users in Reporting Air Toxic Evaluations and Investigations

 

To ensure all Air Toxic FCEs, PCEs, and investigations are counted for the Annual Commitment System (ACS) commitments for regionally selected Air Toxic evaluations/investigations pulled from AFS the data entry requirements described below must be followed. 

 

Situation 1:  The facility is subject to the particular MACT subpart targeted for evaluation or investigation.

 

When the FCE, PCE, or investigation is complete enter the activity into AFS using the appropriate action type (FE or FZ for FCE, ES or EX for PCE, and EI for investigation) against the MACT air program code and identify which MACT subpart(s) the facility is subject to via the air program plant subpart field (SPT1) in AFS.

  • ·         A Region may also chose to indicate in the RDE16 field which air toxic priorities were evaluated/investigated.

 

Situation 2:  The facility is subject to one or more MACT subpart(s) but, it turns out, the facility is not subject to the particular subpart targeted for evaluation or investigation.

 

If the FCE/PCE/investigation finds that the particular subpart targeted for evaluation or investigation is not applicable, but other MACT subparts are, the activity should be entered twice:

  • ·         Enter the activity into AFS using the appropriate action type against the MACT air program code and identify which MACT subpart(s) the facility is subject to via SPT1 field in AFS, and
  • ·         Enter the appropriate non-applicability action type (NA/NM) and note the non-applicable subpart targeted for evaluation or investigation in the RDE 16 field (for example, enter 'KK' which stands for 'Printing and Publishing').
    • The non-applicability action types were introduced to provide a way for the Regions to report Air Toxic FCEs, PCEs, and investigations at facilities that turned out not to be subject to the particular MACT subpart targeted for evaluation or investigation.  NA stands for: 'EPA MACT FCE/PCE Non-Applicability Determination'.  NM stands for: 'EPA MACT Non-Applicability Determination for Investigations'.

 

Situation 3:  It turns out the facility is not subject to any MACT standard.

 

If a Region initiates an Air Toxic FCE, PCE, or investigation, and it turns out the facility is not subject to any MACT standard, the Region should enter the activity twice:

  • ·         Using the appropriate FCE/PCE/investigation code to document the work, against an appropriate air program code (i.e., Title V or SIP), and
  • ·         Enter the appropriate non-applicability action type (NA/NM) to document non-applicability.  In addition, note the non-applicable MACT subpart targeted for evaluation or investigation in the RDE 16 field.

 

Headquarters will count the following activities for the regionally selected Air Toxic evaluations/investigations ACS measures:

  1. FCEs, PCEs, and investigations entered at the MACT air program code at facilities subject to one of the regionally selected Air Toxic priorities as shown in the subpart field.
  • For Regions that indicate in the RDE16 field which Air Toxic priorities were evaluated/investigated, headquarters will examine the RDE 16 instead of the subpart field (SPT1) to determine which activities should be counted.
  1. Air Toxic FCEs, PCEs, and investigations initiated for one of the regionally selected Air Toxic priorities, but it turned out the facility was not subject to that priority.  To do this we will search the NA and NM activities and look for regionally selected Air Toxic priorities in the RDE 16 field.

 

Please contact Betsy Metcalf at 202-564-5962 or David Sprague at 202-564-4103 if you have any questions about this guidance.

 

See Also

            Regional MACT Selections for Air Toxics National Enforcement Prioritynotes:///852571B90068232E//A3943D5B09AF65B1852571B9006AB90Anotes:///852571B90068232E/BF25AB0F47BA5DD785256499006B15A4/09DF44A61947CD838525731A00563E7E

            Guidance for NSR/PSD Non-Applicability/Undetermined Investigations

            Supplement AFS FCE, PCE, and Investigation report logic and guidance documents

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