Hello everyone, welcome to another edition of Envera at the Board (E@TB). Today we’re going to do something a little different because we just started a new year. We’re going to talk about almost all of the air compliance reports that will be due during the first quarter of 2016. There are a lot of them, and what we’re trying to do is give you an idea of what will be due during the first quarter. That way you’ll have a better idea about what your workflow will look like during the first quarter of 2016.
In our experience, there’s a lot that goes on within a facility during the first quarter, and sometimes up to the first three quarters. We have seen that the more you know about what your work-flow will look like, the more prepared you will be to get everything done by the time things are due.
[01:23] Title V semi-annual monitoring (SAM) report
The first report we’ll talk about is the Title V semi-annual monitoring (SAM) report. The semi-annual monitoring report is required by all Title V facilities, and is due on February 28. The SAM due to both the EPA and the AQMD. The report summarizes all of the monitoring activities that occurred during the reporting period, which was from July to December 2015, and any deviations that occurred [00:02:00] during the reporting period. Again, it’s a summary of all monitoring and you submit the report to both the EPA and the AQMD and is due on February 28.
[02:13] A quick comment about deadlines
One thing to keep in mind is that all of the dates we’ve presented are “canonical” dates. That means the deadlines will differ for some of the reports, but these are the dates that we like to go by. As a good rule of thumb, it’s always wise to have your report submitted seven to ten days before the deadline, or these canonical deadlines, to ensure that you get it submitted on time. The best way to know when things are due is to visit the AQMD website and look up the deadlines.
In general, a lot of these reports are routine, but some of there reports that we’ll get to at the end are one-off type reports, but regardless of the type of report, you’ll want to be sure that you check the regulatory agency’s website for the exact due dates. Like I said, as a rule of thumb, it’s best to get these reports submitted between seven and ten days before the date that we have listed here.
[03:27] Title V Annual Compliance Certification (ACC)
The second report on the list is the Title V Annual Compliance Certification (ACC), and the ACC is due on February 28 for Title V facilities that are not in the RECLAIM program, or if they are in the RECLAIM program, they are classified as a cycle 1 facility meaning that these RECLAIM Cycle 1 facilities, compliance year that spans from January to December. For the non-RECLAIM [00:04:00] and Cycle 1 RECLAIM facilities, the Annual Compliance Certification is due February 28, and it must be submitted to the EPA and to the AQMD. The Compliance Certification is the annual certification that’s submitted by Title V facilities to the regulatory agency, certifying under perjury of law that the facility is in compliance with all of the rules and regulations applicable to the facility. If it is not, a little bit of history or a little bit of information as to why the facility is not in compliance must be provided. Again, for non-RECLAIM and RECLAIM Cycle 1 facilities, the Title V ACC is due February 28.
For the non-RECLAIM [00:04:00] and Cycle 1 RECLAIM facilities, the Annual Compliance Certification is due February 28, and it must be submitted to the EPA and to the AQMD. The Compliance Certification is the annual certification that’s submitted by Title V facilities to the regulatory agency, certifying under perjury of law that the facility is in compliance with all of the rules and regulations applicable to the facility. If it is not, a little bit of history or a little bit of information as to why the facility is not in compliance must be provided. Again, for non-RECLAIM and RECLAIM Cycle 1 facilities, the Title V ACC is due February 28.
You may ask, “What happens if my facility is Title V but it’s in the RECLAIM Cycle 2 program?” In that case, your compliance year goes from July to June, and so your ACC is due in August, therefore, you wouldn’t submit it in February.
[05:15] RECLAIM Cycle 1 APEP
Moving on from the Title V program, let’s talk about the RECLAIM program. Cycle 1 RECLAIM facilities are facilities that have a compliance year that is based on the calendar year, that is, from January to December. For these RECLAIM Cycle 1 facilities, the annual Certification of Emissions to the RECLAIM program must be submitted to the AQMD by February 28.
One thing to note is that this APEP is the final certification of all the emissions being reported to the RECLAIM program [00:06:00] for that compliance year. Therefore, you will not only want to ensure that the emissions you’re reporting are correct but that you also have enough RECLAIM trading credits in your account to cover those emissions. In this case, we recommend a 10-15% in case anything happens during the auditing process. Again, the RECLAIM Cycle 1 APEP is due February 28.
[06:32] RECLAIM Cycle 2 QCER
For the folks who are in the RECLAIM Cycle 2 program, a quarterly certification of emissions will be due to the AQMD on January 30. Similar to the annual emissions for the RECLAIM Cycle 1 facilities, if you’re submitting a Cycle 2 QCER by January 30th, you’ll also want to ensure that your emissions are correct and that you’re holding enough RECLAIM trading credits to cover the emissions being reported for the October to December 2015 reporting period.
[07:20] AQMD Rule 1173 annual report
Moving away from these larger reporting programs and into some of the rule-specific reports, we have the Rule 1173 report which is due sixty days after the end of the calendar year, which puts the due date at about February 28. The Rule 1173 report is submitted to the AQMD, and that report summarizes all of the VOC leaks that have been found at your facility if you’re subject to the leak detection and repair requirements of Rule 1173 as well as other information that includes when [00:08:00] have these leaks been fixed, what kind of leaks have been found, the size of leaks, the kind of equipment was subject to the leak and so forth. Is it a light liquid leak? Heavy liquid? Is it a gas leak? Is it on a valve? Is it on a pump? A lot of these reports are prepared by your leak detection and repair (LDAR) contractor, so you would need to submit it to the AQMD. Again, the annual report for the LDAR program needs to be submitted to the AQMD within sixty days of the end of the year, which puts it about February 28.
[08:33] AQMD Rule 461 annual report
In addition to Rule 1173, there’s also the Rule 461 annual report, in which you’ll need to summarize the monthly through puts of gasoline from your facility for the previous calendar year. Facilities are usually subject to 461 because there’s gasoline dispensing equipment on site. Again, that report is an annual summary of monthly throughput, and it must be submitted to the AQMD by March 1.
[09:09] AQMD Rule 1110.2 quarterly report
There’s also the AQMD Rule 1110.2 quarterly report, which applies to large stationary engines greater than 50 brake horsepower (BHP). These engines could be co-generation engines, generators, blowers, water pumps and these engines serve a variety of purposes at industrial facilities. If you have an engine that’s greater than 50 brake horsepower and is subject to Rule 1110.2, a Rule 1110.2 quarterly report will be due to the AQMD on January 15. This quarterly report summarizes all of the deviations associated with operating that engine during the October through December reporting period.
[10:00] AQMD annual emission report
Another big report within the AQMD is the Annual Emission Report (AER). Under the AER program, you’ll need to quantify the types as well as the amounts of air pollutants that were released by your facility in the previous calendar year. Based on the emissions that you calculate, you’ll have to pay fees, and the amount you pay depends on the amount you emit. If you emit a high amount of pollutants, you’re going to have a high amount of fees. This report needs to be submitted to the AQMD by about March 1.
[10:48] AER reporting deadline
Again, you want to check the website for the exact deadline. We place the deadline at about March 1 because that’s about sixty days from the end of the year, or from the start of the year, but since the AQMD is closed on weekends and Mondays, this sixty-day mark could fall on one of those days. If it does, the AQMD doesn’t move it to a day the district is open. You might want to check the website every year to know the exact deadline of the AER.
Another reason you want to check the AQMD’s website for the AER deadline is because you want to be able to know if there are any opt dates to the program that the agency will be rolling out. Last year, the district updated its reporting tool, so the deadline was pushed back a number of months in order to incorporate all of the changes and to allow facilities to get up to speed with the new reporting tool.
This year, I believe that they have made more changes to the reporting tool and so it’s recommended that you go to the AQMD’s website [00:12:00] to know what the changes are and if the deadline has changed. I don’t expect the deadline to change. I think the deadline will be the same. It will be due about sixty days after the start of the year, but the exact deadline is something you should look up on the AQMD’s website.
[12:17] CARB Refrigerant Management program registration
In addition to the AER, there’s also the California Air Resources Board (CARB) Refrigerant Management program (RMP) submission. The CARB has been regulating refrigerants at industrial facilities and equipment with refrigerants from all sizes.This year small facilities—those that have equipment with refrigerants that are between 50 and 200 pounds of charge—are subject to the RMP program, which will require inspections of your equipment. You’ll also be required to file reports and keep records of maintenance activities related to the pieces of equipment that have this refrigerant in them. As part of the RMP program, if you have a small facility that has pieces of equipment with refrigerants that are between 50-200 pounds of charge, you have to register by March 1, and you have to register using the CARB’s R3 Tool.
[13:40] EPA Greenhouse Gas (GHG) report
There are two more reports, one of which is the EPA Greenhouse Gas (GHG) report. This is an annual report that is submitted by larger facilities, refineries, power plants, industrial facilities, or any facility that combusts fuel that results in Greenhouse Gas Emissions greater than 25,000 metric tons CO2e. [00:14:00] If your facility falls into that category, you’ll be subject to the EPA’s Greenhouse Gas reporting rule, which requires you to file an annual report of GHG emissions.
This report is submitted to the EPA using the EPA’s Electronic Greenhouse Gas Reporting Tool (e-GGRT). The e-GGRT tool is an app within EPA’s Central Data Exchange (CDX) suite of apps that are used by different types of reporters to transmit data and submit reports to the EPA. Often times, facilities that are submitting these types of reports will often be subject to the toxic release inventory (TRI) reporting requirements. The TRI is submitted through an app called TRI-Me web, which is also an app within the EPA’s CDX database. I won’t talk about that because it’s not due in the first quarter, but just know that the CDX tool is the tool you would use to submit your TRI report as well as the EPA’s GHG report. You will need to get access to the e-GGRT app within the CDX account. It’s something you may want to look up on the website if you’re new to your facility.
Getting back to the report at hand again, if you have a facility that has GHG emissions in excess of 25,000 metric tons per year, you’ll need to submit an annual report of those emissions to the EPA by March 31. That deadline has moved. It used to be due in April, but now it’s due at the end of March. If you’re submitting the EPA GHG report, you’ll also be submitting a California Greenhouse Gas report under Assembly Bill (AB 32).
[15:47] AB32 greenhouse gas report
The AB 32 program is a much more complicated program than the Federal EPA GHG program, but they’re similar in that you’ll have to submit annual reports [00:16:00] if your facility is a large facility like a refinery or a power plant, or if your facility combusts fuel that produces CO2, or GHG emissions, in excess of 25,000 metric tons per year. In that case, you’ll need to submit under both programs.
Getting back to the CARB report, if you’re filing the EPA report, you’ll also need to file the CARB report. Again, the CARB report is an annual report of GHG emissions. Although there are similarities between the CARB and the EPA report, there are also key differences. People think the CARB report will be exactly the same as the EPA report, but that’s not necessarily true. If you have an oil and gas facility, the way the CARB wants the emissions calculated differs from the way the Federal EPA wants them calculated. Therefore, it’s best to treat the CARB report and EPA report as two separate reports.
The CARB report is due April 10. The deadline is outside of Q1, but since the CARB report is so similar to the EPA report, and they’re due only ten days apart, we’re going to classify the CARB report as a Q1 report and again, it must be submitted to the California Air Resources Board using the California Electronic Greenhouse Gas Reporting tool (Cal e-GGRT).
[17:42] E-GGRT vs Cal-EGGRT
One thing a lot of people get confused about is that they have access to the Federal e-GGRT, but now they will need access to the Cal e-GGRT. These are different reporting tools because they’re different programs. Even though they may look the same, they’re not, [00:18:00] and you’ll need to get access to both the Federal e-GGRT and the California e-GGRT to submit these reports.
[18:09] AB32 greenhouse gas report verifications
If you’re submitting a California AB 32 report by the April 10 deadline, you’ll also need to have your emissions verified by a third party. That verification needs to happen by September 1 because the emissions, when verified, serve as an entities compliance obligation for the Cap and Trade program.
I’m not going to talk about the Cap and Trade program, but for facilities that are reporting by the April 10 deadline and having their emissions verified, those facilities are also going to be subject to the Cap and Trade program. There’s a whole suite of things that need to be done if you’re subject to the Cap and Trade program, so that verification is very important. The verification also serves as the bridge between the mandatory reporting program, where reports are due in April, and the Cap and Trade program, where an entity has to surrender credits to the California Air Resources Board.
[19:27] 2016 Q1 Report summary
We’d like to close by running down the list one more time. The Title V SAM is due February 28 to the EPA and AQMD, and it summarizes all Title V monitoring activities. If you have a non-RECLAIM or a Title V/RECLAIM Cycle 1 facility, you will also have an Annual Compliance certification (ACC) that will be due to both the EPA and the AQMD on February 28. If you have a RECLAIM Cycle 1 facility, your [00:20:00] Annual Certification of Emissions (APEP) is due to the AQMD on February 28. If you have a RECLAIM Cycle 2 facility, your quarterly report will be due to the AQMD on January 30.
If you have an 1173 LDAR program, your annual report is due February 28 to the AQMD. If you’re subject to Rule 461 because you have gasoline dispensing equipment on site, your annual report of monthly throughput will be due to the AQMD on March 1. If you have an engine greater than 50 brake horsepower subject to Rule 1110.2, your quarterly report will be due on January 15. If you’re subject to the AQMD’s annual emission report (AER), you will have an Annual Emission report due on March 1. Again, you’ll want to check the AQMD’s website to know the exact deadline.
If you have equipment containing refrigerants between fifty and two hundred pounds, you will need to register for the CARB’s RMP program by March 1 using the CARB’s R3 tool. Lastly, if your facility has GHG emission in excess of 25,000 metric tons per year, you’ll need to submit a GHG report to the EPA by March 31 using the Federal e-GGRT tool. You’ll also need to submit a Greenhouse Gas report by April 10 to the California Air Resources Board using the California e-GGRT tool. If you’re reporting to the California Air Resources Board by this April 10 deadline, you’ll need to have a verification of your emissions completed by September 1.
Again, we call these dates ‘canonical dates’ because these are the dates by which we like to operate internally, but we always advise our clients to get the reports submitted seven to ten [00:22:00] days before these dates. For the AER in particular, check out the AQMD’s website. We’ve included in the notes a link to the AQMD’s page, and you can check if there are any updates to the program, the reporting tool, and the exact date when these reports are due.
We hope knowing when reports are due in 2016 can help you better plan your quarter. We know it’s a busy time, and we’re here to help. Let us know if you have any questions. Take care.
Let’s take this over to you
Before we end, I’ve got three things for you.
Thing 1. Do you know of a colleague who needs to prepare any of these air quality reports?
If so, please share this E@TB video with them so that they will have a better idea of what reports are due during the first quarter of 2016.
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Thing 3. Preparing air quality reports for our clients is one of the ways that we are able to free up their time so that they can focus on higher level priorities. Do you need help preparing your 2016 Q1 air quality reports? Contact us to consider them done.
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