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.

Toxic Use Reduction Annual Fees Due September 1, 2017 Reply

By July 1, 2017, each Large Quantity Toxics User of chemicals in the state of Massachusetts was required to file an annual toxics use report that included a Massachusetts Form S for each TURA listed chemical they manufactured, processed or otherwise used above applicable thresholds during 2016.

Companies subject to this reporting are required to pay annual toxics use fees. A fee worksheet/invoice was generated as part of your eDEP TURA report. This worksheet/invoice serves as your first notice of payment due. The fee must be paid in full by September 1, 2017.

In order to avoid late fees, don’t forget to print your worksheet/invoice, and send a copy with your check to:

MassDEP
PO Box 4062
Boston, MA 02211

Please note that if payment is not received by September 1st, a second invoice including a $1,000 late fee, will be sent.

If you have any questions about these programs and updates, please contact Alexis Dallaportas at 508-970-0033 x142 or by cell at 508-380-6716.

 

EPA Haz Waste Generator Rule Updates Reply

The Environmental Protection Agency’s (EPA) Resource Conservation and Recovery Act’s (RCRA) hazardous waste generator regulatory program was originally promulgated in 1980. Since that time, the EPA has become aware of the need for more clarity, consistency, and flexibility within the program. EPA’s final rule, which was promulgated on May 30, 2017, revises the hazardous waste generator regulations making them easier to understand, and providing greater flexibility in how hazardous waste is managed.

Some key provisions where EPA is finalizing flexibility are:

  1. Allowing a hazardous waste generator to avoid increased burden of a higher generator status when generating episodic waste provided the episodic waste is properly managed, and
  2. Allowing a very small quantity generator (VSQG) (previously called conditionally exempt small quantity generators) to send its hazardous waste to a large quantity generator under control of the same person.

This program update is also implementing some Improvements to environmental protection and, therefore, several of the revisions to the hazardous waste generator regulations are more stringent than those in the previous version. One such revision requires Small Quantity Generators (SQGs) to periodically re-notify the EPA regarding their generator status every four years (SQGs needed to only notify once under the previous system).

You may Click Here for additional information on the RCRA Program Updates.  Please note that though the Federal regulations are currently in effect, the Massachusetts Department of Environmental Protection (MassDEP) has indicated they will not be adopting these updates until 2018.

We can help! Capaccio has RCRA experts that can assist you with the reporting and planning challenges associated with Federal and state hazardous waste programs.  If you have any questions about these programs and updates, please contact Alexis Dallaportas at 508-970-0033 ext. 142 or adallaportas@capaccio.com.