Printreg Archive
Re: General minor source permitting questions

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Date: Tue Oct 22 1996 - 14:15:25 CDT

re: state permits for small business

Massachusetts has a number of approaches on the menu...
Industrial Waste Water - required for disposal of industrial waste to sewer,
in addition to permit from POTW. Rule may be recinded this year, if
peremitted to POTW.

Haz/Waste - no permits, altho all generators are regulated, LQG, SQG and VSQG
(which corresponds to federal CESQG). Annual compliance fee is charged for
LQG and SQG.

Air - permits are required for companies having actual emmissions > 1 tpy;
about 20 exemptions are available for specified industrial groups if they
follow stringent controls and recordkeeping (basically same as RACT).
Facilities between 1-5 tpy (potential) are required to obtain Limited Plans
Approval, which can be done by facility. Over 5 tpy potential requires a
Comprehensive Plans Approval (CPA), which is more complex and requires larger
fees and sign-off by a PE. Below 50% of major source threshold, no Title V
permit required (EPA 50% policy); over 50% but less than 100% of major
threshold (actual emissions) can get "restricted emission status" which is a
FESOP. That's mostly it, except for Title III, where you become major at 10
tons for individual HAPs or 25 tons combined HAPs.

However, the Mass. Printers Partnership (MP2), an outreach and reg
simplification program, enabled printers to avoid air permit, IWW permit and
haz/waste compliance fees by submitting a 36-question self-certification
statement which is multi-media and P2 oriented. Check w/ Kerry Drake
(TNRCC), who is fairly familiar w/ this propgram.

George Frantz MA/OTA (ph) 617-727-3260 x631; (fax) 617-727-3827
                (email) []

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