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.

 

 

Handling Extremely Hazardous Chemicals – A Discussion of the General Duty Clause Reply

In the Clean Air Act Amendments of 1990, Congress enacted Section 112(r)(1), also known as the General Duty Clause (GDC), which makes the owners and operators of facilities that use listed or other extremely hazardous substances responsible for ensuring that their chemicals are managed safely. The General Duty Clause applies to any facility producing, processing, handling, or storing extremely hazardous substances (i.e., any chemicals listed in 40 CFR Part 68, or any other chemicals which may be considered extremely hazardous).

Although the GDC appears in the Chemical Accident Prevention Program (aka Risk Management Plan (RMP)) regulations, it does not compel subject facilities to prepare and implement an RMP. Instead, facilities subject to the GDC (i.e.  any facility with extremely hazardous substances) are required to:

  • Identify and understand the hazards associated with the extremely hazardous substances used (hazard assessment)
  • Design and maintain a safe facility (prevention program)
  • Minimize the consequences of accidental releases that do occur (emergency response program)

Without specific regulatory requirements to follow, many facilities find it difficult to know if they have satisfied their obligations under the GDC. To demonstrate due diligence we recommend  the following:

  • Conduct a hazard analysis / review using experience, analytical methods such as HAZOP, or creative methods such as what-if brainstorming
  • Identify the consequences of the release identified in the hazard analysis / review
  • Adopt best industry practices, codes or consensus standards
  • Understand the unique site situations that may require specific accident prevention techniques
  • Apply lessons learned from accidents and incidents in similar operations
  • Develop an emergency response plan
  • Develop standard operating procedures, training programs, management of change procedures, an incident investigation program, self-audits involving a third party, and a preventative maintenance program
  • Identify at-risk receptors in the event of a maximum possible release and alternative release scenarios identified in the hazard analysis/review
  • Coordinate interaction needed between facility management, employees, and local response agencies

If you have questions on the GDC or the RMP program, consider attending our free webinar on Wednesday, March 23, 2016. Please register  on our website at http://www.capaccio.com.

For more information on this topic, you may also contact Christine Silverman at 508.970.0033 ext. 127  or csilverman@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.