Massachusetts Facilities: Have you consolidated your air plan approvals? Reply

Has your facility been in business for a number of years and is it operating under a variety of air plan approvals issued by the Massachusetts Department of Environmental Protection (MassDEP)?  Do you have more than one air plan approval for a process or piece of equipment that contains different emission limits or restrictions?  Are you confused as to what plan approval you should be following? If so, the MassDEP offers a simplified approach, which is to consolidate your current air plan approvals into one.

The MassDEP has posted a consolidation form on its website to assist companies with streamlining their emission limits, restrictions, monitoring, and reporting requirements:

 http://www.mass.gov/dep/air/approvals/aqforms.htm

When you access this link, scroll down to: LPA/CPA Consolidation of Previously Issued Plan Approvals (August 2011).

The form enables a facility to combine permit limits and restrictions into one air plan approval along with all generally applicable requirements listed in 310 CMR 7.00.  Currently, there is no application fee for consolidation. If you want to consolidate your facility’s air plan approvals and also have a new process that needs to be permitted, the MassDEP is requiring that facilities first apply for a plan approval for the new process, and then submit the consolidation form. The new consolidated plan approval will supersede all prior approvals that have been combined into the consolidated approval.   

Why should you consolidate your air plan approvals?

  • You will save time as you will no longer need to try and keep up with your various air plan approval requirements.
  • Your consolidated air plan approval will be easier to understand as it will list all requirements that are applicable to your processes in one document.
  • With only one document to review, you will reduce risk. Having numerous air plan approvals can lead to requirements being overlooked, which can lead to potential fines.

CAPACCIO’s air permit experts can assist in consolidating your air plan approvals.  We have more than twenty years of experience filing air plan approvals and have worked closely with MassDEP permit engineers to ensure the process goes smoothly.

If you have any questions, or need assistance, please contact Lynn Sheridan at 507.970.0033 extension 122 or lsheridan@capaccio.com.

 

 


MassDEP Rideshare Program Stakeholder/Regulated Facilities under the Massachusetts Rideshare Regulation (310 CMR 7.16) Reply

In April 2012, the Massachusetts Department of Environmental Protection (MassDEP) held a meeting with rideshare program stakeholders to discuss opportunities to streamline the program’s reporting and survey requirements.  The MassDEP is planning to implement the following ten recommendations to streamline the survey and reporting requirements this year: 

  1. The reporting forms will be automated and converted into Excel spreadsheets.
  2. The current rideshare guidance will be revised in order to simplify the instructions and provide more relevant examples.
  3. The “vehicle use” question will be revised in the reporting forms and the guidance document for employers to determine the number of applicable commuters.
  4. The rideshare guidance will be revised to allow employers to use direct counts of commuters parking in garages/lots as drive alone commute trips.
  5. The MassDEP will allow flexibility on how employers conduct their surveys and capture other modes of commuting that may be otherwise missed during a specific target week. 
  6. The MassDEP will offer a series of workshops in October, November and December to help employers complete the rideshare reports.    
  7. The MassDEP will attempt to provide earlier notification of deficient reports. In addition, MassDEP will include a checklist in the report that outlines all key information and documents that are required for submittal.
  8. MassDEP will link to environmental calculators on the Rideshare web page that can be used as an optional tool to estimate environmental benefits from reduced drive alone commuter trips.
  9. MassDEP will allow employers to use the entire population of employees who typically commute during the work week or employers may continue to use the current methodology to identify applicable commuters. 
  10. MassDEP will provide a spreadsheet that will help employers estimate changes in mode shares.  The guidance will be revised to more clearly explain how the increase/shift in commuting modes can be reported in the reports.  

The meeting and changes were part of the MassDEP’s Regulatory Reform Initiative (http://www.mass.gov/dep/about/priorities/regreform/actionplan_final.htm). MassDEP anticipates that the changes will be fully implemented and made available on MassDEP’s Rideshare webpage (http://www.mass.gov/dep/air/approvals/ridesh02.htm) by October 2012 for the 2012 reporting year.   

If you have any questions, please contact Linda Swift at 508.970.0033 ext. 119 or lswift@capaccio.com, or Dan Forsythe at 508.970.0033 ext. 135 or dforsythe@capaccio.com.

September is National Preparedness Month Reply

In August 2011, Hurricane Irene caused widespread power outages and flooding in New England.  Thousands of homes and businesses were without power.  Some areas were without power for several days following the storm. This summer, millions of businesses were affected by Hurricane Isaac. Business interruptions like these can cause companies to lose productivity and profits. Having a Business Continuity Plan in place can help.

A Business Continuity Plan is used to detail how a business will continue if a disaster or emergency occurs. The plan can help provide quick recovery from business interruptions. 

One of the first steps that businesses can take to ensure that they are prepared for an emergency is to update existing emergency plans. The Occupational Safety and Health Administration (OSHA) requires that companies have a written emergency action plan and fire prevention plan.  Since September is National Preparedness Month, this is a good  time to review these plans.

Is your emergency contact list up-to-date?  Take the time to ensure that there is a list of every employee that includes their office, home, and cell phone numbers. Employers should develop a procedure for communicating with employees in the event of a disaster. Also, include critical supplier and customer contact information in your plan.

Organizations can visit http://readyrating.org/  and complete an online self-assessment of their preparedness. There is also free information and tools available to help with your preparedness at http://www.ready.gov/business

For more information on emergency preparedness, contact Colleen Walsh at 508.970.0033 ext. 129 or cwalsh@capaccio.com.

CAPACCIO’s Linda Swift to present 527 CMR 33 at CMBEN Reply

Linda Swift, CAPACCIO’s Manager of the EH&S Compliance and Systems Group, will present New Hazardous Materials Processing Regulations and Preventive Emergency Planning  at the upcoming Central Massachusetts Business Environmental Network (CMBEN) meeting on September 11  from 9-11 a.m. The meeting is in partnership with the Worcester Regional Chamber of Commerce and will be held at WRCC, 446 Main Street, Suite 200. There is no cost for this meeting, however space is limited, so please register soon. To register, e-mail Mary Hubbard of the Worcester Regional Chamber of Commerce at mhubbard@worcesterchamber.org, or call her at (508) 753-2924.

Ms. Swift’s presentation will delve into the wide scope of the new Massachusetts Department of Fire Services (DFS) Hazardous Material Processing regulation (527 CMR 33), which involves compliance to requirements of a number of agencies. Ms. Swift will talk about the applicability of and compliance to 527 CMR 33, and include the scope of the regulation, exemptions, determining applicability to the regulation, how to achieve compliance with the regulation, and other requirements that may be applicable.

Rick Reibstein of the Massachusetts Office of Technical Assistance will discuss the requirements in the context of emergency planning generally and how an efficient response will include an examination of options for accident and pollution prevention, as well as combining related compliance and performance efforts.

For more information on the new regulation and how it may pertain to your facility, please contact Linda Swift at 508-970-0033 x119 or lswift@capaccio.com.