The following text is an abridged and edited transcript of the video that follows at the end of this post. This post was updated on February 24, 2017.
With the annual emissions report (AER) deadline right around the corner, we’d like to share some of the most commonly overlooked areas that can affect reporting accuracy. Accuracy is especially important because mistakes could lead to compliance problems as well as higher fees.
As a reminder, this year’s report is due to the South Coast Air Quality Management District (AQMD) on Thursday, March 2, at 5 PM.
Let’s look at six ways to ensure your AER is accurate and properly submitted.
1. Ammonia Emissions
The AER contains several default emission factors used to calculate the emissions of ammonia from the combustion of fuel. Unfortunately, the incorrect emission factor is often used, usually because the report preparer uses the emission factor based on the incorrect control device for the piece of equipment.
Within the AER, the default ammonia emissions are broken down into two groups: internal combustion (engines) and external combustion (boilers). Within each of these categories, the ammonia emission is further characterized by the type of control device found on each piece of equipment. That means you’ll see default emission factors for an internal combustion engine with a selective catalytic reduction (SCR), an internal combustion engine for a piece of equipment that has a selective non-catalytic reduction (SNCR), and an internal combustion engine with no control device. You’ll also have the same three emission factors for external combustion equipment — so six emission factors in all.
You can easily determine the type of control device on your equipment by asking, looking at your permit, or examining the equipment itself.
On top of that, the AER reporting software has a default emission factor for each equipment type (external and internal combustions) — and, unfortunately, the software’s default often describes equipment most facilities don’t have. For example, the reporting tool’s default ammonia emission factor describes external combustion equipment with an SNCR, even though this is not correct in most cases. If you’re moving quickly through the reporting tool, you may select the wrong default ammonia emission factor, which can cause you to overestimate your ammonia emissions and incurring higher fees.
2. RECLAIM Fuel Usages
The fuel usages on your AER should match the fuel usages you use to prepare reports for the Regional Clean Air Incentives Market Program (RECLAIM), a cap-and-trade initiative for nitrogen-oxide and sulfur-oxide emissions in the South Coast Air Quality Management District. If you’re in the RECLAIM program, you’re required to submit both quarterly and annual reports of your NOx and/or SOx (or “knocks and socks,” in industry jargon) emissions. The reports are based on fuel usages, and you need to maintain all documentation so that you can back up all of the calculations you submit.
The problem we often see is facilities taking fuel usages from a data method other than the one that was used to complete the RECLAIM report. But these two reports must use the same numbers — otherwise the accuracy of your report might be called into question, which could lead to a compliance problem.
You also want to be sure to subtract any AER-exempt sources, such as emissions from PERP equipment (equipment registered under the California Portable Equipment Registration Program).
A general formula for reporting AER emissions is to sum up all fuel usages from your annual report, then subtract any AER-exempt equipment. That means you’ll have to review the different sources reported on the RECLAIM reports and determine which are AER-exempt.
3. AER-Exempt Compounds
You’ll want to be sure you’re not reporting any AER-exempt emission sources on your report, because that could result in higher fees. We’ve already discussed this a bit above, but there are other exemptions, including:
- Architectural coatings (unless it is part of the production process)
- Any compounds or emission points that are exempt under AQMD Rule 102, such as acetone
- Mobile sources of emissions, such as trucks or vans
- Equipment that is regulated under PERP
4. Use of Source-Test Results
Source tests are often far more accurate than a default emission factor, but any source-test results used on your AER must be pre-approved, a process that generally takes anywhere from six to 12 months.
The source test must have occurred prior to 2017 and have undergone the entire six-step approval process. If the source test results are not approved, you’ll have to either use the default emission factor or the results of the most recently approved source test.
5. Use of Facility-Specific Sampling Data
Wherever possible, use facility-specific sampling data. When calculating emissions on an AER, report preparers often use default emission factors. That’s fine if you don’t have another data set available. But since environmental compliance programs are often fairly complex, with a lot of different regulations that each has reporting and monitoring requirements, any business that already adheres to these other regulations more than likely already has facility-specific data, which is far more accurate than a default emission factor.
For example, we’ve seen facilities collect material samples for the EPA’s Toxics Release Inventory (TRI) report and wastewater samples for a self-monitoring report (SMR) for the Los Angeles County Sanitation District (LACSD). Both of these data sets can sometimes be used on the AER to develop more accurate emission factors.
Using facility-specific data is also beneficial because using a default emission factor could result in overestimations, which in turn results in higher fees. This is especially true when reporting emissions from cooling towers. There are studies that have tried to derive corrections for this overestimate, but we highly recommend just using facility-specific data within the standard emission calculation formula.
6. Submission Completion
This may sound obvious, but you need to make sure that you submit a complete report, which consists of two parts: an electronic submission using the reporting tool, and a hard-copy submission, along with wet signatures on the form and a check, if any fees are due. Don’t forget any of these pieces or your report will be incomplete.
We hope these tips will help you complete your 2016 AER. If you have any questions or need help completing your report, contact us.