The new year is finally here, which means now is the time to think about annual and semiannual environmental reporting for 2021! Many air permit programs require certain reports to be submitted by January 31 of each year, including but not limited to:
- New Source Performance Standards (NSPS) semiannual reports: 40 CFR pt. 60, subp. Dc – Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units.
- National Emission Standards for Hazardous Air Pollutants (NESHAP) semiannual reports: 40 CFR pt. 63, subp. JJ – NESHAP for Wood Furniture Manufacturing Operations.
- Annual Compliance Certification: Title V permits and some state air permits.
- Semiannual Deviations Report: Title V permits and some state air permits.
- Annual Emissions Report: common for facilities with 12-month rolling sum emission limits.
- Annual Production/Operation Report: common for facilities with 12-month rolling sum operating limits.
- Plantwide Applicability Limit (PAL) Semiannual Emissions Report: not very common.
Some of these reports require submittal through the United States Environmental Protection Agency’s (US EPA’s) Compliance and Emissions Data Reporting Interface (CEDRI). This is generally specified within the rule text, but are also identified in US EPA’s CEDRI website. Other reports may require submission directly to the state or local agency.
For Minnesota-specific facilities, some additional annual reports that may apply are:
- Annual Performance Test Schedule Report: Common only for facilities with performance testing requirements.
- Annual Report Describing Changes Made at the Facility: Common for facilities with flexible “Pre-Cap” emissions limits.
Gather and Review Records Early
Depending on how the supporting information is being recorded and maintained, it may require a significant amount of time to gather and review this information. This may include review of production or materials usage records, control equipment monitoring records, continuous emissions monitoring system (CEMS) data, or other site-specific records required by your permit.
Know What Applies to Your Facility and Operations
We encourage you to know which reports you are required to submit by the end of January and to which environmental regulatory agencies you are required to submit (e.g., state or local agency, the Environmental Protection Agency, or both) and make a plan to complete, certify, and submit them on-time, if you have not already.
Contact Our Environmental Consultants
Braun Intertec has experienced consultants that can help you determine what environmental reporting requirements apply to you and help you prepare and submit your environmental reports. Contact us for assistance or questions.
