Third-Party Verification Of Greenhouse Gas Emissions Reports No Longer Required By The MassDEP Reply

On August 26, 2015, the MassDEP issued an e-mail to Massachusetts Greenhouse Gas (GHG) emissions reporting facilities that it will no longer require verification of GHG reports by an approved verification body once every three years as stated in 310 CMR 7.71(7).  This decision applies to reports for reporting year 2014 and future years thereafter.  Verification of emission reports for years prior to 2014 must still be completed and submitted to MassDEP.

The reason for the change is that MassDEP believes the third party verification program has been successful in improving the quality of reported GHG emissions data to-date.  Each reporting facility in the state has completed verification for at least one emission year.  MassDEP believes the reviews have resulted in significant changes to many reports and that going forward, facilities will continue to implement these changes in future years as part of their own internal verification processes.

MassDEP intends to publish a draft report on the verification requirement in the near future which will include supporting data that was considered in deciding to no longer require the third-party verification.   MassDEP  will likely be proposing amendments to 310 CMR 7.71(7) to replace the current verification requirement with other verification options such as self-certification of reported emissions.

Despite the removal of the third party verification requirement, the accuracy and consistency of data should remain a priority that needs to be addressed by alternate means such as a periodic peer review or GHG emissions audit.

CAPACCIO works closely with companies in assisting with the tracking of GHG emissions and in the preparation and submission of GHG reports to both the MassDEP and the Federal EPA.  CAPACCIO will continue to provide GHG program audits and peer reviews of GHG tracking systems, programs, and reporting.

CAPACCIO will continue to follow any developments from the MassDEP and our air quality experts can help with all your compliance needs.  If you have questions or require assistance, please contact Bob King at 508-970-0033 ext. 113 or bking@capaccio.com or John Baycroft at 508-970-0033 ext. 144 or jbaycroft@capaccio.com.

TUR Fee due September 1 Reply

If you filed a Toxics Use Reduction (TUR) report in 2015 for chemical use during 2014, there is a TUR fee due to the MassDEP by September 1.

Companies subject to TURA are required to pay annual toxics use fees. These are based on a formula that takes into account the number of people the company employs and the number of listed chemicals it manufactures, processes or otherwise uses in excess of applicable thresholds. A company calculates its fee using a worksheet/invoice that the facility submits along with its annual TUR report.

This worksheet/invoice serves as the company’s first notice of payment due. The fee must be paid in full by September 1 of the filing year. (http://www.mass.gov/eea/agencies/massdep/toxics/tur/about-tura-reporting-and-fees.html#ToxicsUseFees )

The last sheet of your facility’s TUR reporting package includes the fee calculation worksheet and serves as the invoice for the fee.  No additional notice is sent by MassDEP regarding this fee.

Print the Worksheet/Invoice page as documentation and send a copy with your check to:

MassDEP, PO Box 4062, Boston MA 02211

Payment is due by September 1, 2015. If your payment is not received by September 1, a second invoice including the $1000 late fee mandated by MGL 21I will be sent to the facility.

If you need assistance determining or submitting your TUR invoice, please contact your project manager at CAPACCIO, or Jill Vernes at jvernes@capaccio.com.

Filing An NOE? EPA now requires electronic submission Reply

Did you know? The EPA issued a new No Exposure Certification (NOE) form under the 2015 Multi-Sector General Permit on June 4, 2015. You now must submit your No Exposure Certification electronically using the NPDES eReporting Tool on the EPA Central Data Exchange CDX website, https://cdx.epa.gov/ unless you have a waiver from the EPA Regional office to use the paper form.

Please refer to the following guidance on using the NeT:

http://water.epa.gov/polwaste/npdes/stormwater/Stormwater-eNOI-System-for-EPAs-MultiSector-General-Permit.cfm

If you are given a waiver from your local EPA office corresponding to your facility location to use a paper NOE form, you may complete and submit the paper form available at:

http://water.epa.gov/polwaste/npdes/stormwater/uploadmsgp2015_appendixk.pdf

For assistance or further information, please contact msgp@capaccio.com.

Have you missed the August 3 deadline for Endangered Species? Reply

For existing permit holders

If you missed the August 3 deadline and realize you have endangered species on your property,  the EPA may be able to provide an expedited ESA review or provide an extension to the September 2, 2015 deadline on a case-by-case basis. Please call or email Lucy Servidio at CAPACCIO at 508-970-0033 ext. 114 or lservidio@capaccio.com for additional information. Visit our stormwater portal for valuable information and tools to assist you with your MSGP submittal on our home page at http://www.capaccio.com.