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.

Reminder – Source Registration Deadlines Approaching Reply

Just a reminder that deadlines for air source registration filing are fast approaching. Prevent last minute scrambling and begin to assemble your air permits and approvals, fuel usage data, and hours of operation for fuel combustion equipment.

Each owner/operator of a facility required to file this year should have been informed of their filing schedule via a letter from the Massachusetts Department of Environmental Protection (MassDEP). If you did not receive a letter, the MassDEP has posted a list of filers with their due dates which can be found at the link below:

http://www.mass.gov/eea/agencies/massdep/service/online/filing-schedules-and-deadlines.html

The due dates for this year are listed below.

  • April 15 – Operating Permit facilities due
  • May 16 – Non-OP annual filers due
  • June 1 – Deadline for a portion of the facilities filing every 3 years (see List of All Facilities for facility-specific deadlines)
  • July 15 – Deadline for a portion of facilities filing every 3 years (see List of All Facilities for facility-specific deadlines)

NOTE:  If you were an Operating Permit facility during any portion of 2015, you will need to file a 2015 Source Registration, even if your classification changed or the facility closed.

EXCEPTIONS: Please note that some air permits require the facility to file annually.  If this is the case, then your facility is required to file by May 16, regardless of what the MassDEP list states.

Based on your current level of record keeping and available data, a peer review of your filing, or assistance with the MassDEP online filing system (eDEP) may be all you need. If interested, we would be happy to discuss where you are in the process and what is needed to ensure your deadlines are met.  For more information, please contact Linda Swift at 508-970-0033 ext. 119 or lswift@capaccio.com.

 

 

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.