www.trcsolutions.com

February 19, 2014

MassDEP Source Registration Reporting

Presenter - David Cotter, PE

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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.

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

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Company Profile

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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

Why Clients Choose TRC

Concept

Delivery & Operations

Permitting, Engineering, &

Construction

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

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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

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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

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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

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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

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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

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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

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Polling Question?

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

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eDEP – Logging in

https://edep.dep.mass.gov/DEPLogin.aspx

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

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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

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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

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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.

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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.

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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

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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

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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

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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.

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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

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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 AP-Forms

Section C: Notes and Attachments

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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

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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

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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)

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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.

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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 pre-calculated 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.

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Polling Question?

Will your facility be reporting emissions from processes other than fuel combustion?

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AP-2 Form (Processes)

Used to report emissions from processes

Examples include:

- Coating, Plating, Finishing

- Cleaning, Drying

- Baking

- Grinding, Polishing

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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

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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.

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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.

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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

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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

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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)

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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

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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 http://

www.mass.gov/eea/agencies/massdep/service/online/how-to-file.html

Source Registration: Troubleshooting eDEP http://

www.mass.gov/eea/agencies/massdep/service/online/source-registration-troubleshooting-edep.html

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Questions?David CotterP: 978-656-3648 | E: dcotter@trcsolutions.com

www.trcsolutions.com