Greenhouse Gas and Source Registration Due Dates Approaching Reply

The Environmental Protection Agency (EPA) and Massachusetts Department of Environmental Protection (MassDEP) Greenhouse Gas (GHG) and Source Registration reporting deadlines are fast approaching.

EPA Mandatory Greenhouse Gas Reporting – Due April 1st

The EPA mandatory GHG reporting regulation [40 CFR 98] requires any person owning, operating, or controlling the following facilities to report their 2012 carbon dioxide equivalent (CO2e) emissions to the EPA:

• One of 17 identified industry categories
• One of seven identified industry categories, that emit greater than 25,000 metric tons or more of CO2e per year
• Facilities that do not meet the above, that have combustion units in aggregate equal to or greater than 30 million Btu per hour, that emit 25,000 metric tons or more of CO2e per year from fuel combustion
• Identified suppliers, producers and importers of GHGs

All requested data must be reported using the EPA’s online Electronic Greenhouse Gas Reporting Tool (e-GGRT) by April 1, 2013.

Mass Air Source Registrations and Emissions Statements Annual Filer Reports – Due April 15

MassDEP requires submittal of Air Source Registration/Emission Statements annually for some sources and triennially (every three years) for others. The MassDEP has implemented staggered filing deadlines as follows:

Annual filers
 Operating Permit facilities must file by April 15, 2013
 Non-Operating Permit facilities that are required to file annually must file by May 15, 2013
Triennial filers
 Facilities required to file every three years will receive notification from the MassDEP that their filing is due on either June 3 or July 15, 2013

MassDEP expects filers to use its eDEP on-line source registration filing system. Submittal of hardcopy form is not required.

If your facility meets the criteria under 310 CMR 7.12 for filing Source Registration (SR), reports are due regardless of whether MassDEP sends you a letter. However, you should check the mailing list on the SR web page at Filing Schedules & Deadlines first to see if your facility has been deferred to a later year. If you think there is a mistake in the list, and you should (or should not) be on it (or scheduled for a different year), e-mail air.quality@state.ma.us explaining why the list is wrong.

NOTE: You may be directed by MassDEP to submit a Source Registration through communications other than the annual notice letters. For example, you may be directed to submit as part of an inspection, enforcement action, or permit. You must submit when so directed regardless of whether or not you receive one of the annual Source Registration notice letters.

Mass Mandatory Greenhouse Gas Reporting – Due April 15

The MassDEP mandatory GHG Reporting regulation [310 CMR 7.71] requires any person owning, operating, or controlling the following facilities to report their 2012 carbon dioxide equivalent (CO2e) emissions to the MassDEP:

• All Operating Permit facilities with GHG emissions (310 CMR 7.00, Appendix C)
• All facilities that emit greater than 5,000 short tons of CO2e per year

All required data must be reported to the Climate Registry Information System (CRIS) by April 15, 2013.

Please note: Per an update to the General Reporting Protocol dated January 2nd, 2013, there are updated emission factors that are to be used for reporting this year. See the link below for more information:

http://www.theclimateregistry.org/downloads/2013/01/2013-Climate-Registry-Default-Emissions-Factors.pdf

Reporting facilities that have not previously been verified will also be required to verify their reporting year 2012 emissions by December 31, 2013.

For assistance with your SR or GHG reporting, please contact John Baycroft at 508.970.0033 x144 or jbaycroft@capaccio.com. We can sit alongside and assist you in the process, peer review your submittal, or complete the entire process for you.

Formaldehyde and Hexavalent Chromium Compounds Designated as Higher Hazard Substances Reply

As of January 1, 2012, formaldehyde and hexavalent chromium compounds have become designated as Higher Hazard Substances and are subject to Toxics Use Reduction Act (TURA) reporting requirements. The deadline for the first reporting period for both chemicals is July 1, 2013 for facilities that have 10 or more employees and that manufacture, process or otherwise use 1,000 pounds or more of either reportable chemical. The first TUR Plan is due July 1, 2014.

Please remember to consider formaldehyde that may be manufactured as a byproduct when processing materials such as resins. Also, it is important that you separate out trivalent chromium compounds from hexavalent chromium compounds when calculating threshold quantities.

If you would like assistance in putting together an effective methodology for threshold and emission calculations, please contact Travis Wheeler at twheeler@capaccio.com or 508.970.0033 ext. 115.

TRI-ME Web Updates

There have been a few minor changes to the Tri-ME Web reporting software. There is now a tool that assists with calculating production ratio. There have been changes to the data quality alerts. You will now receive data quality alerts when large increases or decreases in emissions are noted without an associated change in production or source reduction technique. You will be prompted by the software to fix the error. There are also some interface changes such as pull down menus which will make reporting a little easier.

TRI/TURA Workshops

The Massachusetts Department of Environmental Protection and the Office of Technical Assistance are partnering with the U.S. Environmental Protection Agency (EPA) to hold four training sessions on calendar year 2012 TURA/Toxic Release Inventory (TRI) reporting requirements. These workshops are designed for experienced reporters and are free, but require registration via email.

Workshop Dates and Locations

Thursday, April 25, 2013
North Central Massachusetts Chamber of Commerce
860 South Street, Fitchburg

Thursday, May 2, 2013
Massachusetts Mutual Insurance Co. Learning & Training Conference Center
350 Memorial Drive (Route 33), Chicopee

Tuesday, May 14, 2013
ATMC Conference Center
151 Martine Drive, Fall River

Tuesday, May 21, 2012
Parker River National Wildlife Refuge Headquarters Building
6 Plum Island Turnpike, Newburyport

For more information or to register, please email Nicholas Leonardi of the EPA at leonardi.nicholas@epa.gov. Toxics Use Reduction Planners who attend one of these training sessions will qualify for six (6) continuing education credits.

CAPACCIO to present “SEC Conflict Minerals Ruling: Ensuring Compliance and Meeting Customer Demands” at SESHA National ESH Symposium In March Reply

Capaccio Environmental Engineering Inc. (CAPACCIO) will present “SEC Conflict Minerals Ruling: Ensuring Compliance and Meeting Customer Demands” at this year’s Semiconductor Environmental Safety and Health Association (SESHA) ESH Symposium and Exhibition March 18-22 in Long Beach, California. SESHA is the premier international organization which promotes the effective communication of safety, health and environmental information on cutting edge high technology ESH topics to the electronics and related high technology industries.

In August 2012, the SEC adopted a ruling mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act that requires publically-traded companies to disclose their use of conflict minerals originating from the Democratic Republic of the Congo (DRC) or an adjoining country. Conflict minerals, including tantalum, tin, tungsten, and gold, are largely found in electronic and semiconductor components. Conducting due diligence and tracing the use of conflict minerals to comply with the ruling will be a substantial undertaking requiring dedicated time, resources, and expertise.

CAPACCIO’s presentation will delve into an overview of the requirements for conflict minerals, how to be prepared to respond to customer surveys inquiring about your supply chain, and ways to identify systems and solutions for streamlining the reporting process. Additionally, effective approaches to incorporating conflict minerals reporting into a sustainability management system or corporate social responsibility program will also be discussed. Although the report to the U.S. Securities and Exchange Commission (SEC) is not due until May 31, 2014, having a plan in place regarding the source and chain of custody of conflict minerals will be of the upmost importance as data will need to be collected for the 2013 reporting year, beginning on January 1.

CAPACCIO has tracked this regulation from the very beginning and has developed a program to assist companies with the conflict minerals process and reporting. For those not attending the SESHA conference, CAPACCIO will be offering a free webinar covering this material in February of 2013. Stay tuned to your email or our website, http://www.capaccio.com, for more information. Subscribe to our EH&S Regulatory and Industrial News blog to receive immediate notification of this webinar and other important news items: http://news.capaccio.com.

For more information on conflict minerals, please contact Julie Muszalski at jmuszalski@capaccio.com or 508.970.0033 ext. 124.

CAPACCIO’s 2013 Compliance Calendar Available For Download Reply

CAPACCIO has just posted its 2013 Compliance Calendar! Always a hot item, our calendar provides 2013 deadlines for meeting regulatory requirements required by the MassDEP, EPA, DOT, and OSHA. In addition to these requirements, there are many non-date specific requirements throughout the year including:

• Initial training and annual or periodic retraining or refresher training required by
  OSHA or other regulatory agencies for affected employees
• Inspections, testing, monitoring, and/or certification of equipment and systems
• Payment of compliance assurance, renewal, or usage fees
• Permit, certificate, and license renewals
• Internal or external program audits and reviews
• Documentation and recordkeeping

Visit http://www.capaccio.com/Resources/DLoads/AnnCal/dload_anncal.html
to download an Adobe pdf version which includes brief summaries of the various health and safety requirements mandated by OSHA in their General Industry Standards and any corresponding timelines. An additional separate version of the calendar, compatible with Microsoft Outlook, is also available for download.

Download your calendar today! For more information on any of these requirements, please contact Lucy Servidio at 508-970-0033 ext. 114 or lservidio@capaccio.com.