In our environmental reporting blog series, we have already discussedhowto leverage reporting requirements into better business outcomes andhowto prepare for Tier II, TRI, and hazardous waste reports. In this third installment, we will discuss reporting under the Clean Air Act (CAA) and Clean Water Act (CWA) with a focus on air emissions inventory reports and stormwater permit annual reports, and steps to take to efficiently and successfully complete these reports.
Clean Air Act
空气排放库存报告
Regulatory Background
There are several types of reports that may be required under the Clean Air Act (CAA) or by your local air permitting authority; however, in this blog we are focusing on one of the most common reports, the air emission inventory report.
The CAA requires that all states compile an inventory of air emissions each year. This responsibility is carried out by the state or local air permitting authority. State or local jurisdictions may also have their own regulations that require inventorying air emissions.
To fulfill their requirements with the most accurate data possible, state and local regulatory agencies rely on facilities to report the type and quantity of pollutants they emit to the air each year. Because discretion is granted to state and local authorities to collect this data, there are differences across jurisdictions on what is required to be reported, how it is reported, and when the report is due. Therefore, it is important to do your homework ahead of time to know what is required of you and so that you can keep records throughout the year to make reporting as seamless as possible.
Steps to Successful Air Emissions Inventory Reporting
知道您是否需要报告
并非所有设施都需要向报告和报告的设施提供报告，可能不需要报告所有排放量。通常，设施不需要报告某些“de minimis”活动的排放。例如，在明尼苏达州，设施一般不需要向已定已定义的设备和过程中报告称为“微不足道活动”的过程中的排放。您的国家环境机构的网站是一个很好的地方，可以在您需要报告以及您需要报告的情况下了解。如果您持有空气排放许可证，您将很可能需要报告。
知道您需要报告的内容
通常，所有空气排放库存报告都要求您报告标准污染物（颗粒物质，二氧化硫，一氧化碳，氮氧化物，挥发性有机化合物和铅）。一些司法管辖区要求您还报告Air Toxics和/或温室气体。温室气体包括二氧化碳，甲烷，氧化亚氮，六氟化硫，氢氟烃（HFC），全氟化碳（PFC）和其他氟化气体。Air Toxics包括“清洁空气法”第112（b）条中列出的187个危险空气污染物（哈普河），以及已被确定为环境污染的重要贡献者的额外污染物。你的sdss环保署的排放因素can help you determine if you are emitting air toxics.
Know When You are Required to Report
Reporting deadlines vary by state and range from February to July, but most reports are generally due in March or early April. Depending on the state and size of your source you may be able to report less frequently than annually.
记录
In many cases, the records you keep in compliance with your air quality permit, air quality regulations, or other regulatory programs are the same records you can use for your emissions inventory. These files may be usage, purchase, or delivery records. Take advantage of this overlap to minimize duplication of effort. Similarly, the air emissions records you keep can be used in reports for other regulatory programs such as the Toxics Release Inventory.
Calculate Emissions
大多数司法管辖区具有计算库存排放的优选方法的层次，其中应使用该设施最优选的方法。典型的发射计算层次结构是：
- Continuous emission monitors
- 源（堆栈）测试
- Material or mass balance
- 排放因子
- Fuel analysis
- Emission estimation models
- Engineering judgment
计算排放量最常见的方法是排放因子。一个emissions factoris a representative value that relates 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 pollutant divided by a unit weight, volume, distance, or duration of the activity emitting the pollutant (e.g., pounds of particulate emitted per cubic foot of natural gas burned). The records discussed above are used to determine the “activity rate” to multiply your emissions factor by (e.g., records of cubic feet of natural gas burned in the year). Always maintain records of the calculations you do to derive your emissions.
Become Familiar with the Software
Most states require facilities to enter emissions inventory data into online reporting systems. It is a good practice to make sure you understand how to use the database and have access to the database prior to the submittal due date. Many systems require that the regulatory agency grant you access to the database. Depending on the jurisdiction this authorization can take several business days.
Look at Your Data Critically
Before you hit “submit”, make sure the emissions you have calculated make sense. Some agency databases will automatically calculate emissions for certain processes and equipment. If you enter the incorrect units, you may end up with emission rates that are drastically higher or lower than they should be. If the emissions you report are higher than you permit limits, significantly different that previous years, or just don’t seem right, it is important to take another look at your calculations and your data. An air emissions inventory can be the basis for permit revisions, fees, regional modeling, and regulatory decision-making, so it is important to make sure they are as representative of your actual emissions as possible.
清洁水法案
National Pollution Discharge Elimination System (NPDES) Stormwater Permit Annual Reporting
Regulatory Background
在清洁水法（CWA）或当地的水允许权威下有几种类型的报告。在这里，我们专注于影响大多数NPDES Stormwater Plant持有人的共同报告 - 年度报告。
Although not specifically called out in the requirements listed under 40 CFR Section 122.41(l) covering reporting requirements applicable to NPDES permits, annual reports are required by EPA’s Multi-Sector General Permit as well as by many state stormwater permitting rules and stormwater permits.
一个nual reports generally provide the regulatory authority with a summary of the site’s compliance with its stormwater permit and regulations over the past year and highlight any changes to the site or its compliance practices. Like most environmental regulatory programs, the NPDES stormwater permitting program is largely “self-policed” by the permit-holder. Therefore, the annual report provides an important opportunity for the regulated party to demonstrate to its regulator sustained environmental compliance over the course of the year, that the facility is organized and keeping good records, and that when non-compliance or the need for enhanced BMPs was identified, the facility instituted timely and appropriate corrective actions.
Steps to Successful Stormwater Permit Annual Reporting
知道您需要报告的内容
好消息是，通常，年度报告不需要任何新信息，而是需要概述现有信息。当然，易于完成本报告取决于您全年留下记录的程度。您的雨水许可证将界定年度报告中需要的信息。此外，EPA和许多国家在其网站上发布了报告表格以供您审查。
年度报告所需的具体内容将因司法管辖区而异，但一般来说，年度暴风水许可证报告所需的信息类型包括：
- General facility information
- 过去一年的检验日期，调查结果和在报告年度过程中进行的任何BMP维护的摘要
- 雨水污染Preve确认ntion Plan (SWPPP) accurately reflects facility conditions and/or a description of any changes to the facility affecting stormwater discharge or additional potential sources of pollutants and a description of the modifications made to the SWPPP as a result of these facility changes
- 过去一年的监测结果摘要
- A summary of any noncompliance in the past year and the corrective actions taken to address non-compliance
- 由负责任的官员认证
Know When You are Required to Report
Reporting deadlines will be contained in your stormwater permit. Reporting deadlines vary by state and may be a set date for all facilities or depend on the date your permit was issued. EPA has authorized most states to administer the NPDES stormwater permitting program, but for jurisdictions covered by EPA’s Multisector General Permit (Idaho, Massachusetts, New Hampshire, New Mexico, the District of Columbia, most Indian Country lands, and other designated activities in specific such as oil and gas activities in Texas and Oklahoma), annual reports must be filed by January 30theach year.
记录
The records you keep to comply with your stormwater permit, stormwater regulations, or other regulatory programs are the same records you can use for your annual report. The success of your annual report depends on complying with your permit and keeping appropriate records. Reporting can be made easier by keeping these records organized in a centralized location or easily accessible to staff preparing the report.
Become Familiar with the Software
Many states require facilities to submit annual reports electronically. EPA requires submittal through electronic NPDES eReporting tool. Just like with the air emission inventory report, it is a good practice to make sure you understand how to use the database and have access to the database prior to the submittal due date. Many systems require that the regulatory agency grant you access to the database. Depending on the jurisdiction this authorization can take several business days.
Look at Your Information Critically
Reporting season can often be a scramble, and a summary report may not seem like a value-added endeavor; however, the annual report can be a good opportunity or incentive to review compliance with your stormwater permit holistically as well as evaluate whether you are keeping records in a way that makes annually reporting as seamless as possible.
其他CWA和CAA报告
Air emission inventory reports and annual stormwater permit reports are one of many reports that may be required of a facility under the CAA or CWA. Under the CAA “Title V” or “Part 70” permit holders are required to submit semiannual compliance or deviation reports, Federal standards such as National Emission Standards for Hazardous Air Pollutants and New Source Performance Standards all have their own reporting and notification requirements, and EPA’s Greenhouse Gas Reporting Program requires large emitters of greenhouse gases to report to EPA annually. The CWA requires additional reports including discharge/effluent monitoring reports and reports of unauthorized discharges or releases.
Braun Intertec has experienced consultants that can help you determine what reporting requirements apply to you and help you prepare and submit your reports. Contact us if you have any questions.