Source Registration and GHG forms are now available for 2016 data! Reply

It’s the news many of us have been waiting for: the new Source Registration (SR) web forms and Greenhouse Gas (GHG) emissions reporting forms – are now available!

This is great news for annual filers, but, right now, you will only be able to submit your 2016 data. MassDEP will notify you when annual reporting web forms for 2017 become available.

If you are a triennial filer, you, too, will have to wait. MassDEP has deferred 2016 triennial reporting to the 2017 reporting year due to delays in the web forms availability. One caveat is some triennial SR filers also submit annual GHG reports and will need to do so using the new forms for 2016 data by the date listed below.

As all of this can be confusing, below is a table outlining the dates:

Facility Type Year of Reporting Due Date
Annual SR Filer 2016 October 19, 2018
Annual GHG Filer 2016 October 19, 2018
Triennial SR filer 2016 Deferred to year of reporting 2017 – Due Date Unknown
Annual SR Filer 2017 Unknown
Annual GHG Filer 2017 Unknown
Triennial SR filer 2017 Unknown

For all reporters: Be sure any new equipment or processes that emit air contaminants which were installed since your last submission are included.

CAPACCIO can help you navigate the new reporting system, deadlines, and ensure you are including everything needed in this new process. We provide a full range of reporting services to meet your needs, from peer review to full submission.

For assistance, please contact Lynn Sheridan, EIT, at 774-249-2565 or lsheridan@capaccio.com.

At CAPACCIO, we live our mission of “Helping Industry and the Environment Prosper”. We align EH&S with your overall business objectives to strategically position you for success. Our unique approach combines our extensive EH&S experience with cutting edge technologies, such as our EHS DashboardTM, to effectively address your challenges.  Our comprehensive solutions have resulted in award-winning EH&S and overall business performance for our clients. We are certified WBENC, WBE. To learn more visit us at www.capaccio.com.

 

 

MassDEP Announces RY2019 Source Registration Deadlines Reply

The August 2017 proposed modifications to the MassDEP air regulations have been finalized and the air source registration reporting deadlines have been changed!  Going forward for RY2019, the new reporting deadlines are as follows:

  • April 1st
    • Triennial filers
  • May 1st
    • Facilities that are subject to 310 CMR 7.0: Appendix C in the prior year (Operating Permit)
  • June 1st
    • Facilities that have a Restricted Emissions Status (RES)
    • Facilities that had ACTUAL emissions of lead equal to or greater than 0.5 tons, or ACTUAL emissions of NOx or VOC equal to or greater than 25.0 tons in the previous year

In addition, MassDEP has changed the fuel utilization thresholds.  A facility will now be required to file a source registration if its facility-wide maximum energy input from all fuels is equal to or greater than 40 MMBTU/hr.  In addition, if the facility operates an emission unit that combusts natural gas, propane, butane, or distillate oil with a maximum energy input equal to or greater than 10 MMBTU/hr the facility will be required to file a source registration.

Facilities will also be required to file a source registration if their actual emissions in the previous calendar year were equal to or greater than any of the following:

  • Lead:  0.5 tons
  • NOx: 25.0 tons
  • VOC: 25.0 tons

The question remains as to when source registrations will be due this year as the new reporting system and forms are not yet available.  Once the system and forms are up, CAPACCIO will be conducting a webinar to walk through the new forms and answer any questions which may arise regarding the reporting deadlines, which are expected to be released at the same time.

If you have any questions or require assistance, please contact Lynn Sheridan, EIT, at 774-249-2565 or lsheridan@capaccio.com.

 

To “Air” is Human Reply

In our continuing series about auditing and how it can be similar to an annual physical, we will discuss an often overlooked area; a deep dive into air permitting. Just as an annual physical may gloss over some of the more specific parts of the body, air permits can also sometimes be overlooked but doing so can lead to a potential problem in the long run.

Every year, the Doctor asks a list of questions, such as, “Has anything changed in your immediate family’s health (diagnosed with diabetes, heart disease, ADHD)? Who lives at your home? Do you have any pets? Do you have any concerns at the moment?  In a similar fashion, prior to an air audit, the auditor will send you a list of questions. Do you have an air plan approval?  Do you have air emissions tracking sheets?  Do you have a control device? All of these questions help the Doctor/Auditor get an overview of your health/facility and any specific areas that may be of concern.

Your responses become the roadmap for the auditor. If you stated you do not have an air plan approval, the auditor may request a listing of how much solvents are used onsite to determine if the facility needs to further evaluate/justify whether a plan approval is needed or if there is an exemption that excludes a facility from obtaining an air plan approval.  The auditor will check if you are maintaining documentation that states how you are complying with the regulation or why your facility meets the listed criteria exemption.

As with your annual checkup, the more symptoms/details you can provide to the Doctor increases their ability to provide you with advice on what you need to do to maintain a healthy lifestyle. Are there warning signs that you may not have noticed with your air permits?

  • Your volatile organic compound (VOC) emissions from a small process is approaching permitting level
  • The state updated their Regulated Toxic Air Pollutant (RTAP) list and you missed the notice
  • EPA has finalized a regulation that applies to you
  • An emergency generator was installed at your facility and was not self-certified
  • Emission statements were not submitted

These are some of the most common findings found during an air audit. What happens if you don’t see the warning signs or you ignore them for too long?  The small warning signs can compound each other to create one larger issue. Just like your health, it is good to go through the annual checkup to help catch the small warnings before it becomes a larger issue and is too late to be fixed.

Just like there are apps to track your health on your phone, computer, or other electronic device, CAPACCIO’s EHS DashboardTM can help you track your facility’s data making an audit by the state or federal inspectors that much easier. Learn more about the dashboard at www.ehsdashboard.com.

For more information on air permits or other air compliance related questions, please contact Lynn Sheridan, EIT, at 508-970-0033 ext. 122 or by cell at 774-249-2565 or email lsheridan@capaccio.com.

Source Registration and Greenhouse Gas Reporting Update Reply

Recently, many facilities received an email from the Massachusetts Department of Environmental Protection (MassDEP) regarding the upcoming Source Registration (SR) and Greenhouse Gas (GHG) reporting deadlines and requirements. This e-mail states that the MassDEP is suspending the April 15, 2017 deadline for both SR and GHG reporting while they continue to work on combining these two reports into one web based platform.  During this process, the current reporting platforms will not be available.  It is currently not known when the system will be up and reports will be due.  When the reporting platform is ready, the MassDEP will be sending out letters with reporting deadlines to facilities. In the meantime, CAPACCIO recommends that facilities continue to compile their 2016 data and complete required calculations.
Let us know if you need assistance.

If you have any questions, please contact Lynn Sheridan at (508) 970-0033 ext. 122 or lsheridan@capaccio.com.