Specialty:
Air Quality
Location:
Industrial
Type:
Permitting / Compliance
Timespan:
2015 - CurrentLocation:
Plymouth, Avon and Stoughton, MA
Project Number:
4086T.L. Edwards Toxics Use Reduction Reporting and Stormwater Compliance
SERVICE:
Toxics Use Reduction Act (TURA) Reporting & Stormwater Compliance
DESCRIPTION:
T.L. Edwards operates four facilities in Massachusetts, in Plymouth (asphalt and recycled material crushing plant), Avon (asphalt batch plant) and Stoughton. Tech reviewed the Toxics Use Reduction (TUR) Plan for Avon and assisted in www.paybestwatch.me updating the Plan. Tech calculated the Toxics Use Reduction Act (TURA) emissions based on the updated Plan and current facility usage data. Tech set up the MassDEP TURA report online in eDEP for submittal on-line in advance of the July 1st deadline. Tech also prepared the Toxic Release Inventory (TRI) forms to comply with EPA's Emergency Planning and Community Right-to-Know Act, Section 313 reporting. Tech assisted with accessing the EPA system for on-line submittal of the forms.
Tech reviewed the Tier II hazardous waste generation and reporting requirements to assess facility regulatory applicability. Tech staff conducted site inspections to review the Tier II Hazardous Materials compliance. Tech prepared the EPA Tier II Hazardous Materials Report before the March 1st deadline.
Tech completed detailed site tours and permit file audits to catalogue all facility compliance records and provide T.L. Edwards with site-specific Permit & Compliance binders with inspection and record-keeping checklists. The major program records included: air quality, industrial wastewater, water withdrawal, stormwater, AST/UST, waste oil recycling, Tier II, employee training requirements and O&M Plans.
Tech also assisted with a variety of tasks related to Stormwater compliance, including a review of the Stormwater permitting and an update of permits to reflect current standards. Tech staff assisted with developing required Stormwater management plans (SWPPP), sampling schedules and regulatory reports. Tech will also establish the EPA electronic reporting process required under the 2015 MSGP program. Tech reviewed and updated the Spill Prevention, Control and Countermeasures Plan (SPCC) plans.
The storage tank records were reviewed for all ASTs and USTs, including a review of current registration status, system maintenance and record-keeping. Tech confirmed that the periodic testing/inspection and certification by a qualified third-party inspector had been conducted and that the records were properly filed according to future annual/tri-annual testing schedules.