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

Air Emission Inventory Reporting

Regulatory Background

清洁空气法（CAA）或当地空气允许权威有几种类型的报告;但是，在本博客中，我们专注于最常见万博app手机版官网下载的报告之一，空气排放库存报告。

CAA要求所有国家每年编制空气排放量。该责任由国家或地方空气允许权限进行。州或地方司法管辖区也可能有自己的规定，要求库存空气排放。

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.

成功空气排放库存报告的步骤

Know If You are Required to Report

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。

Know What You are Required to Report

Generally, all air emissions inventory reports will require that you report criteria pollutants (particulate matter, sulfur dioxide, carbon monoxide, nitrogen oxides, volatile organic compounds, and lead). Some jurisdictions require that you also report air toxics and/or greenhouse gases. Greenhouse gases include carbon dioxide, methane, nitrous oxide, sulfur hexafluoride, hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and other fluorinated gases. Air toxics include the 187 Hazardous Air Pollutants (HAPs) listed in Section 112(b) of the Clean Air Act, plus additional pollutants that have been identified as significant contributors to the contamination of the environment. Your SDSs or环保署的排放因素可以帮助您确定您是否正在发出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.

Keep Records

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
• 排放估计模型
• Engineering judgment

计算排放量最常见的方法是排放因子。一个排放因子is 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

大多数国家要求设施将排放量数据进入在线报告系统。确保您了解如何使用该数据库并在提交到期日之前访问数据库，这是一个很好的做法。许多系统要求监管机构授予您访问数据库。根据管辖权，此授权可以采取几个工作日。

Look at Your Data Critically

在“提交”之前，请确保您计算出的排放是有意义的。某些机构数据库将自动计算某些流程和设备的排放。如果输入不正确的单位，您可能最终可能会出现巨大或低于应的排放率。如果您报告的排放量高于您的限制，显着不同，前几年，或者似乎不对，重要的是要另一次查看您的计算和数据很重要。空气排放库存可以是允许修订，费用，区域建模和监管决策的基础，因此必须确保它们作为您的实际排放的代表是重要的。

Clean Water Act

National Pollution Discharge Elimination System (NPDES) Stormwater Permit Annual Reporting

Regulatory Background

There are several types of reports that may be required under the Clean Water Act (CWA) or by your local water permitting authority. Here we are focusing on a common report that affects most NPDES stormwater permit holders – the annual report.

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.

年度报告通常提供监管盟thority 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

Know What You are Required to Report

The good news is that generally, annual reports do not require any new information, but rather require a summary of existing information. Of course, the ease of completing this report depends on how well you have been keeping records throughout the year. Your stormwater permit will delineate what information is required in the annual report. Additionally, EPA and many states have reporting forms posted on their websites for your review.

The specific content required in the annual report will vary by jurisdiction, but generally the types of information required by an annual stormwater permit report include:

• General facility information
• A summary of the past year’s inspection dates, findings, and any BMP maintenance conducted during the course of the reporting year
• A confirmation that the Stormwater Pollution Prevention 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
• A summary of monitoring results from the past year
• A summary of any noncompliance in the past year and the corrective actions taken to address non-compliance
• A certification by a responsible official

Know When You are Required to Report

报告截止日期将包含在您的雨水许可中。报告截止日期因国家而异，可能是所有设施的设定日期或依赖于您的许可证的日期。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 30^theach year.

Keep Records

您遵守您的雨水许可证，雨水规则或其他监管计划的记录是您可以使用的年度报告的相同记录。年度报告的成功取决于遵守许可证并保留适当的记录。通过将这些记录保持在集中位置或员工准备报告的员工可以轻松访问，可以更容易地提高报告。

Become Familiar with the Software

许多州要求机构提交年度再保险ports 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.