It’s that time of year again – time for industries responsible for reporting emissions to pull together data and other required information for annual emissions inventories (EI). Meeting annual reporting requirements can be a challenge for your company, not to mention putting in place the processes needed to collect relevant and specific data to ensure an accurate and compliant report.
The U.S. Environmental Protection Agency (EPA)’s Air Emissions Reporting Rule (AERR) requires state, local and tribal agencies to collect and submit emissions data to the EPA to build the National Emissions Inventory (NEI). This means that local industry and governmental agencies are the boots on the ground when it comes to collecting, reviewing and collating data, and submitting it to state environmental departments by hard and fast deadlines each year so that the EPA has information it needs to produce an accurate picture of where the nation is in terms of air quality.
Many states require submission of annual emission inventories (EIs) that include emissions from point sources (fossil fuel fired power plants, smelters, industrial boilers, petroleum refineries, and manufacturing facilities) and non-point sources (area, on-road mobile, non-road mobile, and biogenic). Deadlines vary by state, but the majority fall in the spring. For example, Michigan EIs are due March 15, Texas EIs are due March 31, and early June is the deadline for state of Georgia reports.
EIs detail the estimation of the amount of pollutants discharged by your facility into the atmosphere that can be broken down by specified source categories in a certain geographical area and within a specified time span. Mandatory pollutants are outlined by the EPA, but states can add to that list. For example, in Texas, the Texas Commission on Environmental Quality (TCEQ) requires applicable facilities to submit an EI that consists of actual emissions of volatile organic compounds (VOC), nitrogen oxides (NOX), carbon monoxide (CO), sulfur dioxide (SO2), lead (Pb), particulate matter with an aerodynamic diameter less than or equal to 10 microns (PM10), particulate matter with an aerodynamic diameter less than or equal to 2.5 microns (PM2.5), emissions of all hazardous air pollutant (HAPs), and other contaminants requested by TCEQ.
The reporting method also varies, but most states are gravitating to an online system for submitting annual emissions inventories.
Beginning with the 2015 reporting year, the State of Texas Air Reporting System (STEERS)-Air Emissions Inventory (AEIR) online system became the required method for Texas companies to report annual emissions inventories. There are key points to keep in mind when planning and implementing your EI, including:
- The type of EI your company submits – an initial emissions inventory, annual emissions inventory update and/or special inventory – is dependent on criteria outlined in Texas state law.
- It is important that your facility is consistent across all platforms of reporting. For example, your toxic release inventory (TRI) emissions should reflect what you report in your EI.
- Though the reporting requirements generally remain static, there are occasional changes and clarifications made to the law that governs the process. For example, in mid-2016 a new requirement came into play that requires a certifying statement to accompany an EI that contains no emissions events in a reporting period
Need help preparing your annual emissions inventory prior to your state’s deadline? Or need to determine if you are required to file the report, period?
The team at EDGE has the expertise and experience needed to help you navigate the entire process from collating data to advising the proper steps to take to complete the online submission protocol. In addition to this, we offer a range of Clean Air Act services that complement EI reporting, including Pollution Prevention and Control Technology Evaluations, Toxic Release Inventory (TRI) Reporting and Routine Recordkeeping.
We are here to answer your questions, and to make recommendations about implementing best practices so that your projects move forward efficiently and achieve positive economic and ecological results.
Call EDGE, and we will start the discussion. Bringing further insight.