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.

 

 

Does Impaired Waters Monitoring Apply To You? Reply

Discharging to impaired waters can require a higher level of responsibility from the discharging site, and these responsibilities must be fulfilled to remain in compliance. Follow the flowchart below to see if impaired waters monitoring applies to you.

Before using this flowchart, confirm that your facility satisfies the following criteria:

  1. Prepared a Stormwater Pollution Prevention Plan (SWPPP) per the 2015 MSGP.
  2. Submitted a Notice of Intent (NOI) and received word of acceptance from the EPA.

 

stormwater flowchart

1Determine if your facility discharges to impaired waters using EPA’s ‘How’s My Waterway’ Tool http://watersgeo.epa.gov/mywaterway/

2 Existence of EPA Approved or Established TMDLs can be determined using the ‘How’s My Waterway’ tool.

3 In some cases, monitoring is required when TMDLs exist; however, EPA will notify dischargers of any monitoring requirements.

4 Determine if an EPA Approved analytical method exists by consulting EPA guidance at http://www3.epa.gov/region1/npdes/stormwater/assets/pdfs/MSGP2008Part624ParametersMA.pdf

CAPACCIO has also posted a You Tube video, which walks you through this process. The recording is posted at:   https://youtu.be/uoD4tnJFMNs

For more information or assistance with your impaired waters monitoring, please contact Cristina Mendoza at 508) 970-0033 x128 or cmendoza@capaccio.com.

 

REMINDER–Deadline for EPCRA 312 Tier II Report is March 1 Reply

Facilities that store chemicals above the threshold planning quantities are required by the Emergency Planning and Community Right-To-Know Act (EPCRA) to report those chemicals on a Tier II report to the State Emergency Response Commission (SERC). The report is due annually on March 1 and the deadline is fast approaching. CAPACCIO can assist your company in completing the entire report or we can simply conduct a peer review of work completed by your staff.

Guidance regarding the data required by the Commonwealth of Massachusetts for Tier II reporting is located at this link:

http://www.mass.gov/eopss/agencies/mema/emergency-info/haz-mat/serc/

The EPA software is available at this link:

http://www2.epa.gov/epcra/tier2-submit-software

Visit http://www.capaccio.com and see our blog posted on December 21 for more
in-depth information on Tier II reporting.

For assistance or peer review of your Tier II report, please contact Bill Potochniak, PE, Practice Area Leader for Healthcare and Education, at 508-970-0033 ext. 134 or wpotochniak@capaccio.com.

Paris climate agreement – Historic COP21 Reply

On Saturday night, December 12, 2015, an air of optimism surrounded the topic of climate change after 190 countries unanimously agreed on a unified effort to strategically address this challenge, forming the Paris climate agreement. This United Nations event, COP21, was attended by over 40,000 participants at the host location in Paris. Over 3,000 journalists reporting on the event ensured that the content and messages from COP21 were heard around the globe.

Receiving a unanimous agreement of a global warming temperature limit was the broader, long-term goal. Remarkably, what began as a 2 degree Celsius consensus global warming temperature limit, progressed to a 1.5 degree Celsius consensus limit. This ambitious goal is attainable, but emphasizes the need to implement significant efforts immediately.

The Paris climate agreement is just that, an agreement, and not a legally binding treaty. While this limits enforcement of the content, it allowed the process to be expedited, and not held up in legislation, as it would have been in the United States if presented as a treaty. An accountability system to review country progress every five years will be the alternative form of enforcement.

This agreement is unique in that it encompasses both developing and developed countries, holding them all to emissions reductions targets. Angst did surround the potential roadblocks that the role of developing countries could have posed at the event. One such concern being the cooperation of China and India, as both countries have significant development goals and outlooks. It was noted that the Obama administration played an important role in reaching out to these countries to shift their outlooks. An extra incentive for China was its realization of the opportunity that lies in the manufacture and production of renewables and energy efficient goods.

To support success of the event, despite the challenges mentioned, four pillars were established to guide the negotiations, including,

  1. Climate action plans or Intended Nationally Determined Contributions (INDC’s) were required from each country prior to COP21,
  2. A strategy for financing the transition to disrupting the global carbon addiction would be developed,
  3. Engagement of civil society including cities, regions, farmers, energy providers, and energy users must be considered as vital to implementation; and
  4. Outreach to engage the creative community to deliver the positive message that this change is possible must be encouraged.

The agreement is not perfect, and certain timelines and specifics have yet to be sorted. Viewpoints from the scientific community span from full support to harsh critique, some calling the effort ‘too little too late’. However, with creative solutions and innovation as drivers of the movement, as opposed to pessimistic outlooks, the Paris climate agreement has succeeded in establishing worldwide awareness and action on the issue.

Greenhouse gas accountability is the focus in all participating countries, the U.S. being one of those key participants. As a result, tracking and reporting on this topic is very likely to increase in both the private and public sectors. Whether you are required to comply with annual greenhouse gas reporting, attempting to complete a Carbon Disclosure Project (CDP) questionnaire, or would like to be proactive and take steps to evaluate and enhance your company’s sustainability program, we are here to help you on this journey by offering all of these services, and more. For more information, please contact Cristina Mendoza at 508-970-0033 ext.128 or cmendoza@capaccio.com.