Permitting & Compliance
May 08, 2013
Massachusetts Air Source Registrations and Emissions Statements (April to July)
MassDEP requires submittal of Air Source Registration/Emission Statements annually for some sources and triennially (every three years) for others. MassDEP has implemented on-line source registration filings and has staggered filing deadlines as follows – Annual filers – Operating Permit facilities must file by April 15, 2013; Non-Operating Permit facilities must file by May 15, 2013. Triennial filers- Facilities required to file every three years will receive notification from MassDEP that their filing is due on either June 3 or July 15, 2013.
Massachusetts Permit to Process Hazardous Material (June)
New Massachusetts Hazardous Materials Process Regulations are still in the implementation phase. Facilities that “involve or process” chemicals as defined in the Hazardous Materials Process or Processing Regulations (527 CMR 33.00) are required to have a permit issued by the local Fire Department. Category 4 facilities (vessel capacity greater than 300 gallons), are required to submit an application to process by June 1, 2013. The deadline to submit an application to process for Category 5 facilities, which are those that involve or produce a Hazardous Material which occurs in a vessel with a capacity that is equal or in excess of threshold quantities stated in 29 CFR 1910.119 Appendix A, or 40 CFR Part 68, was January 1, 2013. Deadline to submit an application for Categories 2 & 3 facilities (vessel capacity between 2.5 gallons and 300 gallons), is January 1, 2014.
Toxics Use Reporting (July)
Toxics Release Inventory (Form R) reporting to USEPA is due July 1, 2013. Facilities located in Massachusetts and subject to the Toxics Use Reduction Act (TURA) must report similar data (Form S) by this same date.
We can help!
SAK’s team of compliance specialists has supported the needs of industry for over 25 years. For assistance in determining what requirements might apply to your facility, contact Sherry Albert at 978-688-7804 x113 or firstname.lastname@example.org.
Common Mistakes That Can Lead To Regulatory Enforcement
Waiting until the last minute to prepare your filings. This can lead to late submittals and inaccurate reporting.
Assuming you are not required to report.The only way to be sure that your facility is not subject to these requirements is to complete a detailed review of your chemical processes. If, in fact, your operations are below regulated thresholds, keep documentation of your review on file as a bench-mark management tool and in the event of inspection by regulators.
Not keeping track of changes in manufacturing activity. Facility expansions, incremental increases to operations and new equipment that are not tracked can unknowingly push the facility into reporting requirements for the first time, or beyond the plant’s permit limit, if you already have a permit.