A number of Massachusetts facilities operate with voluntary or imposed limits on their emissions of specific air pollutants. These facilities are required to keep on-site records of operating parameters, and many also must report monthly and 12-month rolling emissions data to the Department of Environmental Protection (MassDEP) on an annual basis. They must also notify MassDEP if they exceed any of the emission limits specified in their approval letters from the agency. Facilities may now complete their annual reports on Microsoft Excel spreadsheets and submit them to MassDEP.
Timely facility reporting of emissions and exceedances, and maintenance of accurate on-site records, are integral components of the MassDEP compliance and enforcement program. They are among the mechanisms that the agency uses to determine a facility's compliance status.
BWP AQ 09 - Permit Restrictions (Restricted Emissions Status or RES)
You may apply for Restricted Emission Status (RES) if you want to legally limit the amount of potential emissions from your facility through a restriction on raw materials use.
Emissions Notification Form: 50% or 25% Facility Emissions Cap
If your facility has federal potential emissions equal to or greater than a major facility threshold, and you want to avoid applicability to the operating permit program, or you want to limit your facility's emissions to lower the annual compliance assurance fee, then you may elect to comply with one facility-wide emissions cap.
Owners/operators of facilities with restricted emissions status (including facilities with 25% or 50% emissions cap status) are required to keep on-site records documenting emissions. The interactive Microsoft Excel Workbook below can be used for that purpose, and can also be submitted to MassDEP to fulfill annual reporting requirements. Facilities with 25% or 50% emissions caps are not required to submit annual reports unless specifically directed to do so. The Excel Workbook is designed to be completed electronically, and will automatically populate all reporting dates and calculate 12-month rolling totals as monthly emissions values are entered.
Found at Tabs 2 through 7 of the Workbook, this form should be used to report your facility's actual monthly and 12-month rolling emissions data. You must submit the Annual Air Quality Reporting Form to the appropriate MassDEP Regional Office by March 15 of each year, unless otherwise specified in your approval letter from MassDEP.
- Click on the second tab, labeled Report1, and enter facility-specific information including facility name, street address and community where the equipment is located, MassDEP approval number and transmittal number (all of which will automatically appear on all subsequent pages), and all short-term and long-term pollutant specific emission limits specified in your relevant MassDEP approval letter.
- Calculate the actual monthly emissions for each pollutant with a restriction specified in the approval. A total of 23 months of data, beginning in February of the previous year and ending in December of the calendar year for which you are reporting is required to calculate the 12-month rolling totals. The applicable 12-month ranges for each 12-month rolling total are noted on the form.
- On-Site Record Keeping Form Worksheets should contain the supporting documentation for the actual emissions entered into the Annual Air Quality Reporting Form. You should maintain your facility's on-site records using the provided On-Site Record Keeping Form Worksheets or an equivalent format. Note: MassDEP routinely audits facilities to confirm that emissions data submitted on the Air Quality Reporting Form is based on accurate and complete on-site records.
- Each page of the Annual Air Quality Reporting Form has space for two pollutants. If your facility has more than two (2) limited pollutants, you will need to use multiple pages. Each pollutant has both a short-term emission limit (monthly) and a long-term emission limit (12-month rolling total). These emission limits are specified in your facility's MassDEP approval letter and should be compared with the actual monthly and 12-month rolling totals. If you use the interactive Microsoft Excel? spreadsheet, your 12-month rolling totals will be calculated automatically as you enter the monthly values.
- If any of the monthly or 12-month rolling values exceeds the permitted limit, place an 'X' in the appropriate column.
- A responsible official working at your facility is required to complete the Certification section on Page 1 of the Annual Air Quality Reporting Form, attesting to the validity of the information being submitted. Without a completed Certification, MassDEP will consider the entire submittal invalid.
- Send the completed Annual Air Quality Reporting Form to the attention of the Bureau of Waste Prevention in the appropriate MassDEP Regional Office no later than the deadline date of March 15.
Found at Tabs 8 through 17 of the Workbook, and these sheets should be used to record operating parameter data (e.g., gallons of fuel used, tons of product made or hours of operation per month) that help demonstrate compliance. Each facility is expected to maintain this detailed information as a condition of its MassDEP approval.
The On-Site Record Keeping Form Worksheets are similar to the Annual Air Quality Reporting Form, but provide space for more detailed information and explanatory notes. Use them to fulfill your On-Site Record Keeping requirements as specified in your relevant MassDEP approval letter (these records are the basis for calculating your facility's actual monthly and 12-month rolling emissions). MassDEP depends on the information you supply on the On-Site Record Keeping Form Worksheets to validate the actual emission estimates you provide when you submit your Annual Air Quality Reporting Form on March 15 of each year.
If your facility exceeds any emissions limit specified in its Air Quality Plan Approval or RES Approval from MassDEP, you must:
- Notify the Bureau of Waste Prevention in the appropriate MassDEP Regional Office via fax as soon as possible thereafter of the exceedance and its duration; and
- Within seven (7) days of the initial notification, mail to the attention of the Bureau of Waste Prevention at the same MassDEP Regional Office copies of the Annual Air Quality Reporting Form and On-Site Record Keeping Form Worksheet(s) with sections relevant to the exceedance completed, along with a description of the exceedance and a list of specific steps the facility is taking to prevent exceedances from happening again.