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.

Climate Change and Sustainability in Massachusetts in the Current Political Climate Reply

Deregulation around climate change has had scientists, citizens, and organizations deeply unsettled in recent months. If looking from the outside in at the message being sent by the federal government, it appears that the U.S. has deprioritized sustainability and is actively revoking its support for the fight against climate change. It wouldn’t be out of place to think this, either. For example, in recent months, the U.S. has pulled out of the Paris Agreement, passed an executive order to revoke the Clean Power Plan, and most recently, the U.S. has revoked a ruling to ban hydrofluorocarbons (HFC’s) in refrigeration and air conditioning.

Regarding HFC’s…

  • On 8/8/17, a federal court ruled that HFC’s cannot be banned.
  • The reversal is due to a technicality in how the Clean Air Act is being used to support the EPA’s effort to ban HFC’s.
  • HFC’s have been and are of increased concern due to their high global warming potential, relative to CO2. In other words, for every one unit of CO2 removed from the environment, a one unit addition of HFC’s to the environment negates the CO2 removed from a global warming standpoint, and leaves the atmosphere with even more greenhouse gas (GHG).

But not so fast! There is a very different story unfolding in Massachusetts (and many other states around the U.S.).

First, for some country-wide good news related to the revoked HFC ban, despite this ruling, U.S. chemical companies are still committed to producing climate friendly HFC alternatives, per the Montreal Protocol in which approximately 150 countries vowed to phase out HFC’s beginning in 2019.

Meanwhile in Massachusetts, on August 11, 2017, Massachusetts published six final regulations to reduce GHG emissions in the Commonwealth. Granted, this was in response to a Supreme Judicial Court ruling (Kain v. DEP, May 2016), requiring the Commonwealth to “beef up” its emission reductions efforts. Enter Governor Baker’s Executive Order No. 569 – “Establishing an Integrated Climate Change Strategy for the Commonwealth” – and the resulting amendments (or new regulations) made to meet 2020 statewide emissions limits set in the Global Warming Solutions Act (GWSA). Below, those regulations are summarized, and more details can be found on the MassDEP website.

 

Regulation 310 CMR 7.72

Reducing Sulfur Hexafluoride Emissions from Gas-Insulated Switchgear (GIS)

What is it? Establishment of annually declining, mass-based limits added to existing max leak rates for SF6.
Who is affected? -Large utilities

-Federal reporting GIS owners

Why Was it implemented? Adding the mass-based limits is accounting for potential SF6 increased emissions associated with deployment of new GIS equipment – not accounted for prior to revision.

 

Regulation 310 CMR 7.73

Reducing Methane Emissions from natural Gas Distribution Mains and Services

What is it? Establishment of annually declining emission limits on Massachusetts gas operators in 2018, 2019, and 2020. This regulation establishes the annually declining limits on GHG emissions.
Who is affected? -All Massachusetts gas operators

-Gas operators with a Gas System Enhancement Plan (GSEP) order from Department of Public Utilities (DPU)

Why Was it implemented? Emissions limits were not established in the Clean Energy and Climate Plan for 2020. It simply required updates and fixes to leaks. Per the GWSA, limits needed to be imposed to ensure reductions.

 

Regulation 310 CMR 7.74

Reducing CO2 Emissions from Electricity Generating Facilities

310 CMR 7.75

Clean Energy Standard

What is it? Two regulations to reduce CO2 emissions from Power plants in Massachusetts.

7.74 sets a minimum percentage of electricity sales that utilities and competitive suppliers must procure from clean energy sources.

7.75 sets a sector-wide, annually declining limit on aggregate CO2 emissions from twenty-one large fossil fuel-fired power plants in Massachusetts.

Who is affected? -All owners and operators of an electric generating facility
Why Was it implemented? These two regulations are intended to increase procurement of clean energy (from utilities) and ensure emissions reductions associated with fossil fuel-powered power plants.

 

Regulation 310 CMR 60.05

Global Warming Solutions Act Requirements for Transportation

What is it? Establishment of annually declining aggregate targets on CO2 emissions from Massachusetts’ transportation system.
Who is affected? -MassDOT; MPO’s; RTA’s; DEP; EOEEA
Why Was it implemented? Previous regulation did not include requirements for the MassDOT to meet enforceable limits on carbon dioxide (CO2) emissions.

 

Regulation 310 CMR 60.06

CO2 Limits for State Fleet Passenger Vehicles

What is it? New regulation setting limits on CO2 from passenger vehicles owned and leased by the Commonwealth’s Executive Offices.
Who is affected? Executive Offices that own or lease 30 or more passenger vehicles, as determined by the MassDEP.
Why Was it implemented? To reduce CO2 emissions from certain Commonwealth owned or leased vehicles through imposition of mass-based limits that decline each year from 2018 through 2025.   This requires each Executive Office to monitor, record, and report CO2 emissions from vehicles.

 

Industry in Massachusetts has stayed on course in terms of preparing for and doing their part to mitigate climate change through often extensive sustainability programs. Consistent with these efforts is the message that Massachusetts continues to stay the course as well, as evidenced by these new regulations.

For more information on this topic, please contact Cristina Mendoza at 508-970-0033 ext. 128 or by cell at 774-249-2418, or email cmendoza@capaccio.com.

CAPACCIO to present “ISO 14001:2015 Are you Ready for the Changes?” on Sept. 12 1

The Central Massachusetts Business Environmental Network (CMBEN) in partnership with the Worcester Regional Chamber of Commerce present ISO14001:2015 Are you Ready for the Changes?

When: Tuesday, September 12, 2017, 9:00 – 11:00 A.M.

Where: Saint-Gobain-Norton Hall, 1 New Bond St, Worcester, Massachusetts

The following are the speakers and the topics they will present on:

Linda Swift of Capaccio Environmental Engineering, Inc. will speak on changes from ISO 14001:2004 to ISO 14001:2015

-Cristina Mendoza of Capaccio Environmental Engineering, Inc. will speak on specific areas that companies are having a difficulty understanding (e.g., context of the business)

Pam Eliason of TURI will give a short presentation on how these changes affect the EMS Alternative to traditional TUR Planning

Networking will be from 9:00 to 9:30 and the program will begin after that.

To register e-mail Isabelle Lavigne from Irwin Engineers at ilavigne@irwinengineers.com, or call her at (508) 653-8007 ext. 10. Although there is no cost for this meeting, seating is limited so please register soon, and no later than September 8th.

For more information, contact Lucy Servidio at 508-970-0033 ext. 114 or 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.