Air Quality

Environmental

Air quality regulations and requirements are continually advancing, forcing companies to strategically plan their operations and expansions or risk costly retrofits in the future.  MugenKioku services clients throughout the United States, but its primary location in the South Coast Air Quality Management District (SCAQMD) affords a unique advantage in forecasting future regulatory changes elsewhere.

The SCAQMD regulates the South Coast Air Basin in Southern California and is a leader in the nation’s efforts to reduce air pollution emissions.  Our extensive experience as Certified Permitting Professionals with the SCAQMD grants insight into regulatory and technological advancements first tested in this region, setting the benchmark for the rest of the country.

Recordkeeping

Regulatory agencies require daily, monthly, quarterly, and annual recordkeeping of material usage, production, and emissions to evaluate compliance with regulatory and permit limits.

 

Reporting and Notifications – Monthly, Quarterly and Semi-Annual Requirements

  • VOC and HAP/TAC Emissions
    • SCAQMD Rule 109 requires daily and monthly recordkeeping of adhesives, coatings, solvents, and/or graphic arts materials. These reports must be completed and signed by a responsible official by the 14th day of the following month.
    • SCAQMD Rule 109 also requires that facilities maintain a VOC Listing of each VOC-containing material that must be updated within 7 days of receipt of the material onsite.
    • MugenKioku offers a proprietary online Environmental Compliance Recordkeeping and Reporting Platform, allowing for real-time metrics reporting and remote compliance oversight.
  • Title V Semi-Annual Monitoring Report (SAM)
    • The Title V Program is a federal program with regulations applicable to facilities exceeding certain annual emissions thresholds.  Subject facilities must report whether or not they have completed all of the monitoring required by the terms and conditions in the permit during the reporting periods (January through June, and July through December).  Reports are due February 28th and August 30th.
    • MugenKioku assists facilities in maintaining compliance with all monitoring requirements and with preparing and submitting the required Title V Semi-Annual Monitoring reports.
  • Title V Annual Compliance Certifications (ACC)
    • The Title V Program is a federal program with regulations applicable to facilities exceeding certain annual emissions thresholds.  Subject facilities must report annually whether they have been in continuous (or intermittent) compliance with each provision of the Title V Permit.  Reports are due February 28th OR August 30th, depending on whether the Facility is assigned to Cycle 1 or Cycle 2.
    • MugenKioku assists facilities in maintaining continuous compliance with all permit provisions and with preparing and submitting the required Title V Compliance Certification and associated SCAQMD forms.
  • RECLAIM
    • The South Coast AQMD’s RECLAIM (Regional Clean Air Incentives Market) Program applies to stationary sources emitting more than four tons per year of NOx or SOx.  MugenKioku assists facilities complying with RECLAIM requirements for Major Sources, Large Sources, Process Units, and Rule 219 Sources.
    • Monthly Reporting
      • MugenKioku assists facilities with preparing and submitting the required SCAQMD forms and electronic submissions.
    • Quarterly Certification of Emissions Reporting (QCER)
      • RECLAIM facilities must submit quarterly reports documenting emissions and demonstrating that they have (if needed) purchased adequate RECLAIM Trading Credits (RTCs) to offset emissions.  The reports are due 30 days after the end of Q1, Q2, and Q3, and 60 days after the end of Q4.
      • MugenKioku assists facilities with preparing and submitting the required SCAQMD forms and electronic submissions.
    • Annual Permit Emissions Program (APEP) Reporting
      • RECLAIM facilities must submit an annual report documenting their compliance with the program. Reports are due February 28th or August 30th, depending on whether the Facility is assigned to Cycle 1 or Cycle 2.
      • MugenKioku assists facilities with preparing and submitting the required SCAQMD forms and electronic submissions.
    •  Inspections
      • MugenKioku assists facilities in preparing for RECLAIM Inspections and meeting with SCAQMD inspectors both during and after inspections to facilitate success outcomes.
  • Annual Emissions Reporting (AER)
    • SCAQMD requires certain facilities to report emissions of criteria pollutants and Toxic Air Contaminants (TACs) and pay associated fees.  While there are some exemptions, in general, reports must include all emissions from both permitting and un-permitted equipment.  Reports must be submitted, along with any required fees, by March 17, 2022.
    • MugenKioku has extensive experience preparing AERs, including compiling all supporting documentation and preparation of emissions calculations.
  • Greenhouse Gas Emissions Reporting
    • The State of California (through the California Air Resources Board, CARB) requires facilities with more than 10,000 metric tons per year of e-CO2 emissions to report annually on their greenhouse gas emissions.  Facilities below this threshold should calculate and document their e-CO2 emissions to demonstrate that reporting obligations are not applicable.

Permitting Projects

  • New Facility Permitting
    • Obtaining permits from the SCAQMD for a new Facility is a lengthy and complex process.  It is imperative the permits ultimately issued by the agency be accurate, maximize operational flexibility, and minimize the risk of noncompliance.
    • The SCAQMD has established the Certified Permitting Professional (CPP) program that certifies individuals that are knowledgeable in all aspects of permit application preparation, including rule assessments, emission offset requirements, Health Risk Assessments, and Best Available Control Technology (BACT) assessments.
    • As licensed Certified Permitting Professionals, MugenKioku is well qualified to prepare permit applications with supporting analyses and negotiate the terms of proposed permit limits with the agency on a client’s behalf.
  • Title V Permit Renewals
    • Title V Permits must be renewed every five years.  MugenKioku has significant experience preparing renewal applications and assisting facilities through the process.
  • Title V Permit Modifications
    • When a Facility wishes to modify their operations in a way that requires a modification to the existing permit, they must submit a Permit Modification Application.  MugenKioku has extensive experience preparing Title V Permit Modification applications and assisting facilities through the process.
  • New Construction Permits
    • Adding new equipment to an existing Facility requires a construction permit issued by SCAQMD.  The application process can be lengthy and complex.  It is imperative that the permits ultimately issued by the agency be accurate, maximize operational flexibility, and minimize the risk of noncompliance.
    • The SCAQMD has established the Certified Permitting Professional (CPP) program certifying individuals that are knowledgeable in all aspects of permit application preparation including rule assessments, emission offset requirements, Health Risk Assessments, and Best Available Control Technology (BACT) assessments.
    • As licensed Certified Permitting Professionals, MugenKioku is well qualified to prepare permit applications with supporting analyses and negotiate the terms of proposed permit limits with the agency on a Facility’s behalf.
  • Permit Modifications for Equipment, Material, or Operational Changes
    • When a Facility wishes to modify their operations in a way that requires a modification to an existing operating permit, they must request a construction permit from SCAQMD.  The application process can be lengthy and complex. It is imperative the permits ultimately issued by the agency be accurate, maximize operational flexibility, and minimize the risk of noncompliance.
    • The SCAQMD has established the Certified Permitting Professional (CPP) program certifying individuals that are knowledgeable in all aspects of permit application preparation including rule assessments, emission offset requirements, Health Risk Assessments, and Best Available Control Technology (BACT) assessments.
    • As licensed Certified Permitting Professionals, MugenKioku is well qualified to prepare permit applications with supporting analyses and negotiate the terms of proposed permit limits with the agency on a Facility’s behalf.
  • Permit Modifications for Change in Ownership
    • Construction and Operating Permits issued by SCAQMD must be modified when Facility ownership changes.  MugenKioku assists facilities with this administrative process.

Large Spark Ignition (LSI) Engine Regulatory Requirements

  • The State of California (through the California Air Resources Board, CARB) regulates emissions from Large-Spark Ignition (LSI) Engines such as forklifts, sweeper/scrubbers, and industrial tow tractors.  Owners and operators of such equipment typically need to comply with equipment labeling, recordkeeping, and annually certification requirements.  Annual compliance certifications must be submitted between June 1 and June 30.
  • MugenKioku assists facilities with all LSI requirements.

Air Quality Management District Inspection Support

  • SCAQMD Inspections (announced or unannounced) typically include on-site visits and an evaluation of all required recordkeeping and reporting.   An inspector will assess whether each source is accurately permitted and operating in accordance with permit and regulatory requirements.
  • MugenKioku assists facilities in preparing for on-site inspections, attending announced inspections, and responding to agency requests for records.

Emissions Testing Support

Regulatory Analysis

  • SCAQMD has promulgated hundreds of regulations designed to improve air quality, and numerous additional programs exist at the local, state, and federal levels.
  • MugenKioku assists facilities in identifying applicable rules and programs, evaluating any potential exemptions, and preparing an analysis of regulatory requirements.

Warehouse Emissions

  • In May 2021, the SCAQMD created a new program called WAIRE to reduce air pollution from warehouse-related activities.  The compliance obligations (and their due dates) depend on the size of the warehouse, though most begin in 2024 and beyond.  Most warehouses will need submit a Site Information Report and will need to select pollution mitigation activities from a menu of options (or pay a mitigation fee).  For many facilities, an Initial Notification was due on September 1, 2021.
  • MugenKioku can help you determine whether your Facility is subject to this rule and what you must do to stay in compliance.

Refrigerant Management

  • In order to protect the ozone layer and reduce global warming impacts, the Clean Air Act regulates the handling of most refrigerants through 40 CFR 82 Subpart F.  To comply with these regulations, owners and operators of refrigerant-containing equipment must maintain records, meet certain equipment maintenance standards, and manage disposal of equipment.
  • California and the individual Air Districts impose additional requirements.
  • MugenKioku has extensive experience helping facilities effectively manage their refrigerants, including implementing the Sphera Refrigerant Compliance Management Software (https://sphera.com/refrigerant-management-software/)
    • For decades the Sphera Refrigerant Compliance Management (RCM) software recordkeeping and reporting tool has helped operations and environmental managers maintain compliance with US EPA regulations and requirements. Likewise, the Refrigerant Compliance Service division has helped organizations initiate and sustain refrigerant compliance efforts. Service offerings include assessments/mock EPA audits, regulatory training, software training, compliance plans, consulting, and Certified Refrigerant Compliance Manager (CRCM) training and testing in partnership with the National Registry of Environmental Professionals.