Emissions and
Release Inventory

Annual emissions inventory reports provide a foundation for emission fees, emissions trading, and community-right-to-know programs. Ultimately, your reported emissions of criteria pollutants and toxic air contaminants (TAC) can impact your bottom line and community reputation. Davenport Engineering specializes in emission and release calculations and understands the importance of thorough, accurate, and well-documented emissions inventory reports.

SARA 313 Toxic Release Inventory

The federal SARA 313 Toxic Release Inventory (TRI) is a complex report that summarizes the releases and transfers of toxic chemicals to the air, water, and waste leaving a facility. It is a part of the Section 313 of the Emergency Planning and Community Right-to-know Act (EPCRA), also known as Title III of the Superfund Amendments and Reauthorization Act (SARA). Congress created EPCRA in 1986 to help communities plan for chemical emergencies and increase the public’s knowledge of chemicals used and released at individual facilities.

Facilities are subject to the TRI reporting program if:

  • · Its operations are classified under a covered primary NAICS code. A full list of covered NAICS codes can be found on EPA’s TRI website, and
  • · Total annual facility work hours reach or exceed 20,000, taking into account all employees and contractors working for the facility.

Facilities subject to the TRI program must annually determine whether any of the 600+ TRI toxic chemicals exceed reporting thresholds for the previous calendar year. The reporting thresholds for most TRI chemicals are listed below. It is important to note that certain TRI chemicals, such as specific persistent and bioaccumative toxics (PBTs), have lower, more stringent reporting thresholds.

  • · Amount manufactured >/= 25,000 pounds/year, or
  • · Amount processed >/= 25,000 pounds /year, or
  • · Amount otherwise used >/= 10,000 pounds /year

A facility’s chemical thresholding evaluation may result in a different set of chemicals being reported each year. For each chemical that triggers TRI reporting, the facility must submit information on releases, transfers, and handling by July 1 for the previous calendar year. Reports are submitted electronically to EPA via EPA’s TRI-ME webtool.

For many facilities across the nation, the TRI report represents one of the more arduous reporting efforts of the year. Davenport Engineering is a leading preparer of TRI reports and can help you tackle yours. We have an advanced understanding of the TRI program and a toolbox full of templates and references to efficiently calculate threshold determinations, emissions and releases, and other elements of the report.

Emission Report (AER)

Facilities subject to AER reporting are those that exceed any one of the annual emission thresholds below:

  • · Sulfur oxides (SOx) >/= 4 tons/year
  • · Volatile organic compounds (VOCs) >/= 4 tons/year
  • · Nitrogen oxides (NOx) >/= 4 tons/year
  • · Specific organics (SPOG) >/= 4 tons/year
  • · Particulate matter (PM) >/= 4 tons/year
  • · Carbon monoxide (CO) >/= 100 tons/year
  • · Individual Toxic Air Contaminant (TAC) > Threshold in Rule 301 Table IV
  • · Individual Ozone depleting compound (ODC) > Threshold in Rule 301 Table IV

The South Coast Air Quality Management District (SCAQMD) is the local air quality agency for the Southern California air basin. SCAQMD requires certain businesses to submit an Annual Emission Report (AER) and pay fees based on the business’s reported annual emissions.

The AER report is electronically submitted to SCAQMD by March 15 each year for the previous calendar year via SCAQMD’s AER webtool.

Davenport Engineering was initially built upon preparing AER emission inventories for clients in the SCAQMD region. Since our founding in 1997, AER reporting has remained one of our core business areas. At present, we have prepared countless AER reports and look forward discussing how we can help prepare your AER report as well.

BAAQMD Regulation 12-15
Annual Emission Inventory Report

The purpose of the Bay Area Air Quality Management District’s (BAAQMD) Regulation 12-15 is to track air emissions from petroleum refineries and their support facilities, such as hydrogen plants, sulfuric acid plants, and electrical generation plants, in the San Francisco bay area.

Towards that end, Regulation 12-15 requires an Annual Emission Inventory Report due on April 15 for the previous calendar year. The report provides a facility-wide emissions inventory of criteria pollutants, certain toxic air contaminants (TACs), and greenhouse gases (GHG).

Davenport Engineering began supporting Regulation 12-15 the very first year regulated facilities were required to submit emission inventory reports for calendar year 2016. We are the go-to resource for Regulation 12-15 support given our long history serving petroleum refineries and preparing emission inventory reports. These Regulation 12-15 reports are now among our standard body of seasonal emissions inventory work.