Succes wtih MassDEP Source Registration Reporting

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Information about Succes wtih MassDEP Source Registration Reporting
News & Politics

Published on February 19, 2014

Author: trc_companies



Facilities in Massachusetts may face a host of air emissions reporting requirements due in April. This presentation reviews who must file; key reporting dates; reporting requirements; how to open a package for submittal; creating and validating reporting forms; and how to submit a successful final reporting package.

MassDEP Source Registration Reporting February 19, 2014

Presenter - David Cotter, PE Mr. Cotter is a professional engineer with over 20 years of experience in the air quality field. He has extensive experience in the industrial, commercial, institutional, and public sectors. Representative industry experience includes; Biotechnology/Life Sciences, Electronics/Semiconductor, Textile Dyeing and Finishing, Metal Finishing/Fabrication, Printing, Food Manufacturing, Food Waste Processing, and Transportation. 2

Company Profile A pioneer in groundbreaking scientific and engineering developments since 1969, TRC is a national engineering, consulting and construction management firm that provides integrated services to three primary markets: Energy | Environmental | Infrastructure  Expert problem solvers  100+ U.S. offices London office  3,000+ employees  NYSE: TRR 3

Why Clients Choose TRC  Multi-disciplinary teams implement complex projects  Nationwide network is a crucial asset that can be integral to project success  TRC helps clients:  realize a higher return on investment  manage risks  align project solutions with operational priorities  integrate multiple areas of expertise to arrive at a better solution Concept Delivery & Operations Permitting, Engineering, & Construction 4

Introduction  Agenda - Who needs to file and when - What sources need to be reported - Collecting data - Accessing eDEP - Creating a submittal - The eDEP forms - Report validation and submittal 5

Who Needs to File A source registration is required to be filed by any source that meets one of the following criteria:  Contains fuel utilization equipment with energy inputs in aggregate greater than: - 10,000,000 Btu/hr: Natural gas, distillate oil, residual oil - 3,000,000 Btu/hr: solid fuel, used oil, landfill gas 6

Who Needs to File  Has non-combustion potential emissions for the following pollutants equal to or greater than: - Particulate Matter (PM): 2 tpy - Oxides of Sulfur (SOx): 2.5 tpy - Volatile Organic Compounds (VOC):10 tpy - Nitrogen Dioxide (NO2): 4.4 tpy - Lead: 5 tpy - Individual Hazardous Air Pollutant (HAP): 10 tpy - Total HAPs: 25 tpy 7

Who Needs to File  Is or contains a hazardous waste incinerator  Is or contains an incinerator with the capacity to reduce 50 pounds per hour or more of waste  Is or contains a stationary reciprocating internal combustion engine (except for emergency or standby engines) with a maximum energy input capacity of 3,000,000 Btu per hour or greater (burning any fuel)  Is required to file Source Registration as a condition of a plan approval or operates under a Restricted Emission Status (RES) issued since January 1, 1990 8

When to File – Reporting Dates  Annual Filers - Tuesday, April 15th: Operating Permit (OP) Sources - Thursday, May 15th: Non-OP filers  Triennial Filers - Monday, June 2nd - Tuesday, July 15th - The date you will file by will be contained in the letter sent to you by the MassDEP 9

What to Report  If a facility is required to file a report it must report for all emission sources at the facility except for those listed as insignificant under 310 CMR Appendix C(5)  Basic Rule: If a source emits pollutants it most likely should be reported 10

Insignificant Sources Not to Report  Selected insignificant sources include: – Interior maintenance activities; this does not include any cleaning of production equipment – Maintenance shops activities such as welding, gluing, and soldering – Food preparation to service facility cafeterias and dining rooms – Portable space heaters – Ventilating and exhaust systems for laboratory hoods used by: • Academic institutions for academic purposes • Hospitals and medical care facilities used for medical care purposes and medical research only • Laboratories which perform laboratory scale activities as defined by OSHA • Facilities for QA/QC testing and sampling activities 11

Polling Question?  Have you (or your firm) previously submitted a source registration using the MassDEP’s eDEP online reporting system? 12

eDEP – Logging in   Click on the green eDEP Online button  What you will need: - eDEP username - eDEP password  If you do not have an eDEP login, or have lost your old information, you can create a new one  eDEP is phasing in new security. You will be asked to complete a one-time setup of new security questions 13

Creating a Submittal Package  From your personal home page mouse over the “Forms” button on the green bar menu and select “Air and Climate”  Search down the list for “Source Registration” and click “Start Transaction”  What you will need: - Facility Tax Identification Number (TIN) - Facility AQ/SEISS identifier  Will need Adobe Reader 10.1.2 if using Internet Explorer, or you can use an earlier version with the Firefox Web Browser 14

Getting Started  Once the package is created it will show up on your home screen  When you click on the link on the home screen it will bring you to the Transaction Summary page.  The summary page will list all the forms in the submittal package  The first form to complete is the Source Registration Overview Form 15

Source Registration Overview Form  Section A: – Click either existing (facility has previously filed) or new (first time facility is filing)  Section B: – If you have new emission sources to report, then you should check the“ Click here to add new units” box • It is recommended that you click this box as explained on the next slide – If you filed previously there will be a list of sources (all should have their boxes checked indicating that new forms will be created for the submittal).  Click the “Validate this form:” button which will create all the forms for the submittal. 16

New Unit Creator Form  If you checked the new units box on the overview form then this new form will be created.  Enter in the total number of each form you will need - It is recommended that you create at least one or two new AP-1 and AP-2 forms. You can delete the forms later if they are not needed.  If you determine later that you will need additional forms then you will need to go back to the new unit creator form to enter a new value and revalidate the form. 17

Sharing a Submittal  The individual who opens the submittal is the “owner” of the submittal  The owner can share with other people who are responsible for completing forms and the “responsible official” who will be certifying the submittal  Sharing is done on the “Transaction Overview Screen”  Owners can also transfer ownership of the package to others 18

Some Things to Gather Before You Begin  Copies of air permits (if applicable)  Fuel use records (monthly bills or purchase statements)  Process material use records  Generator hours operated logs 19

Reporting Forms  AP-SR: Company Information Form  AP-Stack: Emission Unit Stack Information Form  AP-1: Emission Unit Form – Fuel Utilization  AP-2: Emission Unit Form – Process Equipment  AP-3: Emission Unit Form - Incinerator  AP-4: Emission Unit Form – Organic Material Storage  AP-TES: Total Emissions Statement and HAP List Form 20

AP-SR Form  Provides basic information on the facility - Section A: Facility Information - Address and contact information - Section B: Preparer - Person who completed the submittal - Section C: Notes and Attachments - Section D: Certification - Name of “Responsible Official” who will certify submittal Note: Validating this form does not certify the submittal. That is done at the end of the process as explained later. 21

AP-Stack Form  This form contains information for all physical stacks that emit reported pollutants  Stack forms should be created before the AP-1, AP-2, or AP-3 forms so that the sources on those forms can be linked to the stack forms as required 22

AP-Stack Form  Section A: Stack Description - Name and identifying number - Physical data: height, diameter, exit velocity, temperature - this data can be from manufacturer literature or it can be measured/calculated  Section B: Emission Units Associated with Stack - This information will be populated from the individual APForms  Section C: Notes and Attachments 23

AP-1 Fuel Utilization Equipment  Used report emissions from equipment that combust fuels. - Note: if equipment is part of a process (such as a drying oven, or baking oven) then that unit should be reported on the AP-2 form.  Examples include - Boilers Hot Water Heaters Space Heaters HVAC Units Stationary Engines - emergency engines - turbines 24

AP-1 Fuel Utilization Equipment  Data needed to complete form - Equipment specifications - Manufacturer - Model number - Maximum rated heat input - Date of installation - Fuel use records - Permit restrictions 25

AP-1: Form Sections  Section A: Equipment Description – You can combine units on a single form as long as: • They are the same general type (but not identical) • Use the same fuel • The same regulations apply to their operation • The total combined heat inputs are less than: – 10 million Btu per hour (fuel oil and natural gas) – 3 million Btu per hour (solid fuel, used oil, landfill gas) 26

AP-1: Form Sections  Section A (continued) – Pollution Control Devices • Selective Catalytic Reduction (SCR) • Fabric Filters/Baghouse • Oxidation Catalyst – Things that are NOT control devices • Low NOx burners • Flue Gas Recirculation Note: While the above are not reported as control devices, their affect on emission factors should be taken into account when reporting emissions. 27

AP-1: Form Sections  Section B: Fuels and Emissions - This section will auto calculate emissions based on the fuel use data entered on the form. You may also enter precalculated data if non-standard emission factors (such as stack test data) are used.  Section C: Notes and Attachments - Add any descriptive notes pertaining to the source or the submittal here. An example might be that the unit has a low NOX burner or the reference for any special emission rates used. You can also attach electronic attach files if desired. 28

Polling Question?  Will your facility be reporting emissions from processes other than fuel combustion? 29

AP-2 Form (Processes)  Used to report emissions from processes  Examples include: - Coating, Plating, Finishing - Cleaning, Drying - Baking - Grinding, Polishing 30

AP-2: Form Sections  Section A: Emission Unit Process Description - Equipment identifiers - Permit information - Process/Equipment information - Operating information - Monitoring equipment information - Control equipment information  As with the AP-1 form, units can be combined  Monitoring equipment  Pollution control devices 31

AP-2 Form Sections  Section B: Emissions for Raw Materials/Finished Products - If multiple materials/products are reported, then a new “child” form will be completed when the form is validated. The child form(s) will be displayed on the transaction overview page and will need to be completed and validated separately. 32

AP2: Form Sections  Section B (continued) – Enter permit emission and/or material use restrictions (only those that apply to this unit) – Enter calculated emission data • Unlike the AP-1 form, emissions are not automatically calculated on this form and must be calculated offline  Section C: Notes and Attachments – Same as AP-1, you can add descriptive notes about the source being reported or attach electronic files. 33

AP-3 Incinerators  Use this form to report emissions from incineration of waste  DO NOT use this form for air pollution control equipment such as flares or thermal oxidizers. These units should be reported on the AP-2 form for the process to which they are connected 34

AP-4 Organic Material Storage  Organic Material: Any organic chemical compound (OCC) or mixture that contains an OCC. - Note: VOC, HOC, and HYC are organic chemical compounds  Applies to above or below ground storage containers with capacities of 500 gallons or greater  Does not include: - Waste tanks - Lube oil tanks  Units can be combined if: - They store the same material - The containers are of the same construction - The combined storage volume does not exceed 50,000 gallons 35

AP-TES Total Emissions Statement  Automatically summarizes the emissions reported on the AP-1 through AP-4 forms as you validate them  Enter Facility-Wide Permit Restrictions  GHG Check List  HAP Check List - Check if use more than 500 gallons or emit more than 1 ton of HAP  HAP Questions  HAP Reporting (if required) 36

Form Validation  Validation - At anytime during completion of a form you can click the validation button to see what information is missing. - Each form must be validated when it is completed to submit package - The AP-TES form should be the last form validated 37

Certify and Submit  Once all forms are complete and validated, the submittal can be certified and submitted  The Responsible Official (RO; who should be listed on the AP-SR form) will log into eDEP  On the Transaction Overview Screen the RO will click “Next” (or the signature arrow link)  The RO will type their name in the signature box, click the “Certification for all forms” box and click the “I Accept” button. This will lock the submittal.  Confirm email address and click the “Submit” button  Print the receipt page and click “Exit”. 38

MassDEP Resources  How to File: Tips, Factsheets, Instructions & Training  online/how-to-file.html  Source Registration: Troubleshooting eDEP  online/source-registration-troubleshooting-edep.html 39

Questions? David Cotter P: 978-656-3648 | E:

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