Draft Storm Sewer General Permit for 200+ Small Massachusetts Municipalities Reply

News Release
U.S. Environmental Protection Agency
New England Regional Office
September 30, 2014

Contact: David Deegan, (617) 918-1017
Re: Draft Storm Sewer General Permit for 200+ Small Massachusetts Municipalities Will Help Clean Water Protection

BOSTON – EPA is releasing for public comment draft general permit for small “Municipal Separate Storm Sewer Systems” (MS4) located in Mass. The new permits, when finalized, will update efforts in up to 260 municipalities, better protecting rivers, streams, ponds, lakes and wetlands across Massachusetts.

EPA previously released draft general permits for small MS4s in North Coastal Watersheds in 2010 and in the Interstate, Merrimack and South Coastal Watersheds in 2011. In response to many of the public comments submitted previously, and the availability of new technical and census information, EPA has revised the two general permits into one document and is now releasing the revised draft general permits for public input. EPA has also made changes to the newly proposed draft permit in response to public comments seeking more clarity, guidance and flexibility in meeting permit requirements.

The draft general permit, a detailed fact sheet, and information on public meetings and public hearing can be found at: http://www.epa.gov/region1/npdes/stormwater/MS4_MA.html

To read EPA’s full press release, please visit: http://yosemite.epa.gov/opa/admpress.nsf/d0cf6618525a9efb85257359003fb69d/e34e1b71021cf54885257d63005ba5b4!opendocument

IMPORTANT: Source Registration e-mail from MassDEP Reply

You may have recently received an e-mail from the MassDEP with the subject line: IMPORTANT-Notice of EPA’s retirement of air pollution control devices effective for the 2013 submission. This does NOT mean that your control device needs to be replaced. The EPA recently changed their naming system which does not match all the options that are available on the MassDEP’s Source Registration forms. Therefore, the MassDEP is being forced to change the naming system in the Source Registration program. If your facility’s air pollution control device is not on the revised EPA list, the MassDEP will be sending you an e-mail listing your current control device and a list of similar names on the revised EPA list. The MassDEP is asking that you respond to their e-mail stating which revised name matches your air pollution control device. The MassDEP will then update your 2013 Source Registration to the revised name.

If you have any question or concerns, please contact Lynn Sheridan at 508.970.0033 ext. 122 or lsheridan@capaccio.com.

TURA Fee Increase Update Reply

As a follow-up to the TURA update in our last e-blast, CAPACCIO attended the TURA Administrative Council meeting on September 19, 2014. The Council voted 4 to 2 to move forward with increasing TURA Fees. In particular, they would like to see Option B be approved. The three options for increasing fees are at the link below:

http://www.capaccio.com/handouts/eblast/TURA_Fee_Adjustment_Proposal_8-19-14.pdf

Industry and public interest groups were both there to present comments. This will still have to go to public hearings in the fall and the Administrative Council said they would send notices of public hearings to all TUR filers and TUR planners. The Council also agreed to have public hearings in 4 regions of the state so that all stake holders can easily attend. If the fee increase of 50% is passed, it could add an additional $10,000 to big companies using a lot of chemicals. We’ll keep you posted.

For more information, please contact Lucy Servidio, CHMM, TURP, at 508.970.0033 ext. 114 or lservidio@capaccio.com.

Important Toxics Use Reduction Act (TURA) Updates Reply

There are two recent policy developments in the TUR program.

First, at recent meetings of the Administrative Council, the Council voted to designate five chemicals/categories of chemicals as Higher Hazard Substances (HHS). The chemicals include: dimethylformamide (CAS 68-12-2), toluene diisocyanates (listed as: 2,4-TDI [584-84-9]; 2,6-TDI [91-08-7]; and TDI mixed isomers [26471-62-5]), hydrogen fluoride (CAS 7664-39-3), cyanide compounds (TURA #1016) and 1-bromopropane (n-propyl bromide (CAS 106-94-5). These designations are based on recommendations from the Science Advisory Board, TURI policy analyses, and discussions at TURA Advisory Committee and Council meetings. When a chemical/category is designated as a HHS, its reporting threshold is reduced from 10,000/25,000 pounds to 1,000 pounds for manufactured/processed or other-wise used in a calendar year.

Second, the Administrative Council is deliberating the need to address reduced revenues to the TURA program. These revenues have declined because the annual fee adjustments, required by the Act, have not been implemented since the inception of the program. At its next meeting, the Council will discuss three options for increasing fees (see link below):

http://www.capaccio.com/handouts/eblast/TURA_Fee_Adjustment_Proposal_8-19-14.pdf

All the options would provide revenues sufficient to meet the minimum mandatory statutory requirements. The TURA program is recommending option B, because it provides for mitigation of higher fees, particularly on smaller business. The Council is meeting on Friday, September 19th to discuss and vote on whether there will be a TURA fee increase. There will be a 21- day public comment period this fall.

The above information was supplied by Rich Bizzozero, Executive Director TUR Administrative Council, Executive Office of Energy and Environmental Affairs. If you would like to be notified of the 21-day public comment period, please contact rich.bizzozero@state.ma.us.

CAPACCIO’s Senior Vice President Lucy Servidio, CHMM, TURP, serves on the TURA Advisory Committee. If you have any questions, please contact her at 508-970-0033 ext. 114 or lservidio@capaccio.com.