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.

 

Just released, CAPACCIO’s 2018 Compliance Calendar! Reply

Capaccio Environmental Engineering, Inc.’s most popular and anticipated download, the annual Compliance Calendar, is here and ready for download! Our free calendar highlights this year’s regulatory deadlines required by the MassDEP, the EPA and OSHA. Each item is explained in detail for better understanding of what the requirement might entail.
In addition to these requirements, there are also pages which outline non-date specific requirements which occur 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
There are two options of downloads: an Adobe pdf version which includes the compliance calendar front page with the regulatory dates circled as well as the backup information pages. An additional version of the calendar, compatible with Microsoft Outlook, is also available for download.
For more information on any of the technical information contained in the calendar, please contact Linda Swift at 508-970-0033 ext. 119, by cell at 978-621-6433, or email at lswift@capaccio.com. For sales, please contact Lucy Servidio at 508-970-0033 ext. 114, by cell at 508-380-9217, or email at lservidio@capaccio.com.

Changes to the Hazardous Waste Biennial Report Reply

Large Quantity Generators are required to report hazardous waste (HW) activity by March 1st of each even numbered year (every two years) for the preceding calendar year.  Reports are to be sent to the facility’s state authority (in Massachusetts, MassDEP).

Previously, there was an independent software used to prepare these reports. This year (reports to be submitted in March 2018) HW Biennial Reports have to be prepared and submitted using the EPA RCRAInfo Industry Application (RIA) software.

Here’s what’s new:

    • The Biennial Reporting software is a part of the EPA RCRAInfo Industry Application (RIA) which is also a part of the EPA CDX system – so everyone who prepares and submits a HW biennial report needs a CDX account and to register in the RIA system.
    • MassDEP noted to be sure you understand that there are a number of roles for RIA and whoever signs up as the Site Management Role will have control not only of the HW Biennial Report roles and content but also any roles related to the eManifest (expected this summer), and Generator Notification form (expected in the near future), etc.  (Basically anyone with a waste role on CDX related to the client’s facility). So CAPACCIO is advising clients to be careful who they assign to that role.  Once roles are assigned, you need to make sure that those people have CDX accounts.  If they don’t have accounts, one of the first things you need to do is set a up CDX account and then register on RCRAInfo. 
Having trouble submitting your Hazardous Waste Biennial Report?
  • That’s because EPA has not loaded the SI form template (form with your site information) into the RCRAInfo Biennial Report site and you cannot submit the report without completing an SI form.  The form will likely be available in mid-January.
If you have questions regarding the Hazardous Waste Biennial report, contact Linda Swift at lswift@capaccio.com or Alexis Dallaportas at adallaportas@capaccio.com.

Always Make Safety Your Top Priority Reply

Extra! Extra! Read All About It!

The Assault on Health and Safety Begins!

Deregulation policies a threat to worker safety!

OSHA Delays Electronic Record-Keeping Rule!

Talk of scrapping two regulations for each new one adopted!

OSHA Further Delays Silica Rule Enforcement!

Proposed $2.5B Cut to Dept. of Labor’s Budget, Elimination of Chemical Safety Board

During the past six months, there has been lots of talk (and action) in Washington about reducing and eliminating regulations, repealing OSHA rules, and imposing major staff reductions and budget cuts in agencies dedicated to increasing worker health and safety (OSHA, MSHA, NIOSH, and The Chemical Safety Board). Despite all the headlines, businesses throughout the country must continue to operate and, unfortunately, workers continue to be injured or killed on the job on a daily basis.

Although safety regulations and enforcement actions can have a positive effect on reducing worker injuries, they do not prevent them. It still remains everyone’s responsibility within the workplace to promote, create, and maintain a safe and healthy work environment despite whether or not a formal regulation is in place.  From top management down through all levels of the business hierarchy to the employees on the shop floor, safety should be everyone’s top priority.

Regulations or the threat of enforcement penalties and fines should not be the sole driving force in providing safe and healthy work environments. Many highly successful businesses foster safe working conditions and decide on their own to implement safety programs that exceed the basic requirements spelled out in safety regulations.

Bottomline –Safety should remain at the top of your priority list every day for yourself, your fellow employees, and your family and friends while you are away from the workplace.

For more information or of you require assistance with your health and safety programs, please contact Bob King, CIH, CSP, at 508-970-0033 ext. 113 or bking@capaccio.com.