EHS professionals and plant engineers who wear many hats may sometimes feel that their routine environmental compliance reports do not get sufficient attention in the face of other priorities. Davenport Engineering can help by taking the reins and managing your monthly, quarterly, semi-annual, and annual environmental reports. Our goal is to give you peace of mind that this essential baseline work is being expertly handled.

Reporting Support

Davenport Engineering has significant experience with stepping in to manage and execute a facility’s routine environmental reports. Often, our first step is to develop a compliance calendar to track all routine reports and ensure none are overlooked. We can then work onsite or offsite, independently or in tandem with facility staff, to collect and interpret data and complete the required reports before each due date.

Davenport Engineering can be a great solution when you need to supplement your existing resources or just need to temporarily backfill for an absent or lost employee. We can free up your time to focus on more strategic environmental concerns while we handle your baseline environmental reports.

Title V Semi-Annual
and Annual Reports

The Title V semi-annual monitoring (SAM) report and the Title V annual compliance certification (ACC) are two key routine environmental reports that Davenport Engineering has completed hundreds of times for multiple facilities.

Facilities operating under a Title V permit must maintain compliance with the listed terms and conditions at all times. A key feature of the Title V program is self-reporting by a facility if it experiences a deviation from compliance.

All deviations are compiled and submitted to the air agency semi-annually in a Title V semi-annual monitoring (SAM) report. Some deviations in the Title V SAM reports will be those already self-reported to air agency at the time of the deviation through a notification and written follow up report. However, in the SCAQMD region, other deviations with no excess emissions are only subject to semi-annual self-reporting; these are primarily monitoring, work practice, or recordkeeping deviations with no excess emissions, such as missed or late reporting or monitoring.

Another major element of Title V is annual compliance certification (ACC) by the Responsible Official, usually the Plant Manager. In the Title V ACC report, the Responsible Official must certify the facility’s compliance status based on information and belief formed after reasonable inquiry. The annual report identifies each permit term or condition applicable to the facility, whether compliance was continuous or intermittent, the methods used to determine compliance, and any deviations that occurred during the year. Certification carries both personal and criminal liability for the Responsible Official and the company. As such, the Responsible Official should understand and feel comfortable with the level of review conducted for the report, and be aware of any deviations discovered.

Davenport Engineering can take control of compiling previous deviation reports, collecting and evaluating field data, facilitating the reasonable inquiry process, and ultimately preparing your Title V SAM and ACC reports.

NSPS and NESHAP Reports

Many facilities are subject to one or more federal NSPS or NESHAP standards, many of which require periodic reports, typically on a semi-annual or annual basis.

EPA, under the authority of the Clean Air Act (CAA), maintains a series of regulations in 40 CFR Part 60 called the New Source Performance Standards (NSPS). Each NSPS regulation establishes emission limits and/or work practice requirements for an equipment category, sometimes in a certain industry, to control one or more criteria pollutants such as NOx, SOx, PM, and VOC.

EPA also maintains a series of regulations in 40 CFR Part 61 and 40 CFR Part 63 called the National Emission Standards for Hazardous Air Pollutants (NESHAP). The NESHAP program regulates 187 hazardous air pollutants (HAPs) known to cause cancer or other health issues, including benzene, mercury, and asbestos. The original Part 61 NESHAP standards, promulgated before the 1990 Clean Air Act (CAA) Amendments, regulate seven (7) individual HAPs. The Part 63 NESHAP standards, promulgated after the 1990 CAA Amendments and also known as the Maximum Achievable Control Technology (MACT) standards, regulate a much broader range of HAPs in specific source categories.

Several NSPS and NESHAP standards contain requirements to submit periodic reports to EPA that detail the facility’s performance against the applicable emission limits and work practice standards. Some of the newer standards require facilities to electronically submit their reports to EPA via its webtool named Compliance and Emissions Data Reporting Interface (CEDRI).

A small sampling of the NSPS and NESHAP standards, the source categories they regulate, and the periodic reports they require are listed below:

  • · NSPS Subpart Db regulates steam generating units (boilers) and requires semi-annual reports submitted to EPA
  • · NSPS Subpart GGG regulates equipment leaks at petroleum refineries and requires semi-annual reports submitted to EPA
  • · NESHAP Subpart CC (Refinery MACT I) regulates petroleum refineries and requires semi-annual reports submitted to EPA.
  • · NESHAP Subpart DDDDD (Boiler MACT) regulates process heaters and boilers, and for most devices burning gaseous fuels, requires annual reports submitted to EPA electronically via CEDRI.

NSPS and NESHAP periodic reports are among the many routine environmental reports that Davenport Engineering can prepare. We are subject matter experts on numerous NSPS and NESHAP source categories and can hit the ground running on any NSPS and NESHAP reporting demands that come our way.