As 2010 winds down and we all get ready to ring in the New Year, it is a great time to start thinking about the pending annual environmental compliance tasks.  Numerous reporting activities are just around the corner and there is no time like the present to start preparing to meet those upcoming requirements.  The items required for Title V facilities in Massachusetts include annual compliance certifications, semiannual compliance certifications, and annual emission statements.  In addition, greenhouse gas (GHG) reporting is required in early 2011.  In addition to the Title V facilities, any facility whose stationary sources emit greater than 5,000 short tons of combined carbon dioxide equivalent emissions annually are also subject to GHG reporting program to the state.

Trinity is working with clients to prepare for the upcoming reporting deadlines.  The annual reporting deadlines are fast approaching, with submittals due beginning in January 2011.    The annual compliance certification for reporting period, January to December 2010 for Title V facilities is due to the Massachusetts Department of Environmental Protection (MassDEP) no later than January 30, 2011.  This report should include a determination and certification of compliance status with each condition in the permit.  The report is required to be submitted to the Department and must include information on any items where non-compliance was identified.   Similar to the annual compliance certification, two semiannual reports are required each year which summarize the compliance status and any deviations which occurred at the facility during the previous six-month period.   The semiannual report for the reporting period, July 2010 to December 2010 is due to the Department no later than January 30, 2011.  The second semiannual report for the reporting period, January to June 2011 will be due no later than July 30, 2011 to MassDep.

Additional reporting requirements include the annual emission statement and greenhouse gas reporting.  The Annual Emission Statement (Source Registration Submittal) for Title V facilities is due to the Department no later than April 15, 2011.  This submittal should document the actual emissions from the facility during the reporting period, January to December 2010.  For non-Title V facilities, the deadline for source registration submittal is staggered from May through August by MassDep, and this schedule is typically posted by the Department on its web-page.   Facilities that are subject to the mandatory greenhouse gas reporting under 310 CMR 7.71 should report actual greenhouse gas emissions from their facilities no later than April 15, 2011.

Trinity Consultants has expertise working with clients in Massachusetts for all required submittals.  For assistance with any of the aforementioned submittals or other questions, please contact Trinity’s New Jersey office at 732-356-9121.