The following text is an abridged and edited transcript of the video that follows at the end of this post.
Today we’re going to talk about using a source test, or the results of a source test, on an annual emission report (AER).
Why use the results of a source test on an AER? [00:26]
Let’s start by asking why you would want to use the results of a source test on your AER. As I mentioned in an earlier post, a source test is one of the most accurate ways to determine an emission factor. Remember that there are four ways to determine an emission factor: by using a look-up table, conducting an engineering calculation, you can do a mass balance, or you can do a direct measurement.
Although doing a direct measurement will give you the most accurate results, it’ll end up costing you quite a bit of money. Many times, an emission factor from a look-up table overestimates because the emission factor was developed using a large data set, and depending on the quality of the data set, you could have very high amounts of variability.
Unintended Consequences of Overestimating Emissions on an AER [02:10]
As it relates to an annual emission report, overestimating emissions can have several unintended — and not pleasant — consequences, the main one being that you might be subjected to higher fees. And when you use a default emission factor, it will likely be overestimated.
The second potential consequence is that you could be subject to the SCAQMD’s Title V and/or RECLAIM program rules, which in turn will cause your facility to become subject to an array of rules and regulations that will almost always increase your required amount of monetary reporting and recordkeeping. Being subject to those regulations is simply based on emissions and, more specifically, emissions reported on your AER.
Lastly, you could exceed the emission limits on your permit without even realizing it, which can lead to a slew of compliance issues.
Now, we’ll get to the benefits of using a source test in a minute, but let’s first cover whether or not you can use the results of a source test to calculate emissions on your annual emission report.
Yes, you can use the results of a source test for your AER*. [04:40]
While you can use the results of a source test to calculate emissions for your annual emissions report, the source test needs to be approved before use. To do that, you must go through the source-test approval process:
- Prepare and submit a source-test protocol to the SCAQMD.
- If you are given approval, notify the SCAQMD 14 days before you conduct the test.
- Once you provide this notification to the air district, you can conduct a test as outlined in the protocol, with no deviations from what you told the air district you were going to do.
- Submit the results from the source test to the SCAQMD within 45 days of completing the test.
As with anything related to the SCAQMD, you should first reach out to your permit engineer and say that you’d like to get a source test approved. More often than not, the permit engineer will even guide you through the process.
Following the submittal of the report, you need to wait for an approval letter from the SCAQMD documenting that your source test has been reviewed and approved. Only after you receive that notification can you use the results of the source test on your annual emission report.
If you go through this process and don’t hear back from the district, follow up as much as possible. Your first point of contact should be your permit engineer.
Tip: Once you receive the approval letter from the SCAQMD, upload it to the reporting tool when you’re preparing your annual emission report. The folks in the AER department will then have the approval letter on hand when they review your AER. The results of the source test and the approval letter are therefore filed with your annual emission report, which keeps the file clean.
And, as always, keep records of all correspondence and documents. Having everything in writing and all your ducks in a row will make communicating with the air district much easier — and usually faster.
Benefits of a More Accurate AER [07:36]
Now let’s talk about some of the benefits of using the source test for your annual emission report. As mentioned above, a default emission factor will almost always overestimate emissions, so when you use a source test, your calculated emissions will most likely be lower. And when you lower the emissions of your equipment, your facility pays lower fees to the SCAQMD.
Because a lot of the records and compliance reports you submit to the air district becomes part of the public domain, you want those documents to be as accurate as possible so that no one can accuse you of high emissions — and possibly even file a suit.
