CAPACCIO’s EH&S Regulatory and Industrial News Blog

In an effort to “help industry and the environment prosper,” CAPACCIO has developed this blog to provide the latest news on environmental, health and safety related regulatory updates, management systems and sustainability topics.

To become an email subscriber to this blog and receive immediate notification when a new post has been made, look to the right and enter your email address in the “Email Subscription” box.  All the latest regulatory and industrial news will now be sent directly to your inbox.

For further information on our blog posts or if you need more information about our services, please contact Lucy Servidio  at 508.970.0033 extension 114 or lservidio@capaccio.com.

How could this cute little creature impact your stormwater NOI? Reply

LONG EARED BATAccording to the Natural Heritage & Endangered Species Program, the Northern Long-eared Bat is listed as Endangered and protected under the Massachusetts Endangered Species Act. This population of bat has been devastated by the spread of White-nose Syndrome, a type of fungus found in caves that grows over the bat during hibernation, causing them to periodically wake from hibernation, lose valuable stored fat, and fail to survive the winter.

While the delineation of most endangered species’ habitats are limited to certain areas like low lands, marshes, fields, etc, the critical habitat for the Northern Long-eared Bat is the entire state. As a result, when using the US Fish and Wildlife Service’s (FWS) “Information, Planning, and Consultation” (IPaC) mapping system to delineate your stormwater action area, the Northern Long-eared Bat will show up.  According to the instructions in Appendix E of the Multi-Sector General Permit (MSGP), “if you have determined that there are, or may be listed, species and/or designated critical habitat in your action area, you are not eligible under Criterion A and must complete the Criterion C Eligibility Form 30 days prior to submitting your NOI for permit coverage.” Therefore, all Massachusetts Notice Of Intent (NOI) filers under the MSGP would need to submit the Criterion C Eligibility Form by August 3, 2015.

In conversations with the EPA, this is not what they had intended.  According to the EPA, they are working with FWS to develop additional guidance for filers to use when making a Criterion A or Criterion C determination. Stay tuned. As soon as CAPACCIO has more information on this guidance, we will be sure to share it.

For more information about the MSGP, check the home page of our website www.capaccio.com where we have a Stormwater Information page which includes numerous resources like recorded webinars, presentation slides, and frequently asked questions regarding the MSGP. Feel free to submit a question through our Ask The Experts button on the home page of our website if you have any further questions.

More information about the Northern Long-Eared Bat is available at this link; http://www.mass.gov/eea/docs/dfg/nhesp/species-and-conservation/nhfacts/myotis-septentrionalis.pdf

CAPACCIO Places 7th in Zweig Group’s Best Firms To Work For Award Contest  Reply

BFTWF_2015CAPACCIO is proud to announce it achieved 7th place – out of approximately 500 A/E/C firms who entered across the US and Canada – in the Zweig Group Best Firms To Work For Awards contest, environmental engineering category. CAPACCIO, and this year’s other winners, will receive special awards during a black tie celebration dinner at the Hot Firm and A/E Industry Awards Conference taking place September 3-4 in Boston.

“CAPACCIO’s vision includes being a great place to work with a talented, energetic, and passionately engaged staff committed to the success of our clients and to each other,” said CEO and President Lisa F. Wilk, PE. “Toward this end, we strive to foster an atmosphere for professional growth, innovation, teamwork, open-communication, and feeling valued. We are very excited to be recognized for the second year in a row with our efforts toward this goal.”

View the 2015 award winners at this link:
https://zweiggroup.com/awards/best-firms-to-work-for/2015_winners.php

Zweig Group is the nation’s leader in enhancing business performance for architecture, engineering, planning, and environmental consulting firms.  An independent research firm reviewed company practices and the results of anonymous employee surveys to select and recognize the top firms.  The results are based on assessments of workplace practices, benefits, compensation, retention rates, employee engagement, and more.

Starting August 1, 2015: MassDEP’s New Online UST Data Management System Goes Into Effect Reply

The Massachusetts Department of Environmental Protection (MassDEP) is rolling out a new on-line data management system for Underground Storage Tank (UST) Registrations and Third-Party Inspections. Beginning August 1, 2015, MassDEP will no longer accept paper UST forms. With the roll-out of this electronic system, MassDEP will also be initiating its Owner Compliance Certification program. In addition to ensuring that third-party inspections are completed, owners will be required to certify compliance through the online system. The letter from Tom DeNormandie, Branch Chief at MassDEP, is copied below, for your convenience.

If you require assistance with third-party inspections or compliance certifications, please contact Christopher Walton at 508.970.0033 ext. 139 or cwalton@capaccio.com.

*******

Dear Class A, A/B and B Operators and Third-Party Inspectors:

Beginning in July, MassDEP is transitioning from the current paper based Underground Storage Tank (UST) Program registration and reporting forms (FP-290, FP-290R and FP-289), to a new online data management system that provides UST system owners and operators a more convenient, electronic way to update facility registration information and submit applicable reporting documents.

The new data management system will be available for user registration by mid-July.  MassDEP will notify all Class A, A/B and B operators and third-party inspectors when the data management system is ready for use.

UST Program Reporting Transition Schedule

  1. Effective July 31, 2015, MassDEP will no longer accept FP-290, FP-290R and FP-289 documents for purposes of compliance with UST registration and third-party inspection reporting requirements under 310 CMR 80.00.
  2. Effective August 1, 2015:
    1. All new and updated UST registration submittals shall be made electronically through MassDEP’s new online UST data management system.  Registration information may be submitted as a paper document, if accompanied by a hardship request.
    2. All third-party inspection results shall be reported electronically by third-party inspectors using the new Third-Party Inspection (TPI) Report provided through the new online data management system.  The third-party inspector will then electronically forward the TPI Report to the UST system owner or operator for signature and submittal to MassDEP.

Compliance with Third-Party Inspection Reporting Requirements
To provide UST system owners, operators and third-party inspectors time to register as users in the data management system and become familiar with the system and new Program requirements, TPI Reports due between August 1, 2015 and October 31, 2015 will be allowed up to October 31, 2015 to submit their required TPI Report using the new online data management system.

All TPI Reports for this period received after October 31, 2015 may be subject to enforcement.

Compliance Certification Submittals
The Compliance Certification submittal requirement goes into effect November 1, 2015. MassDEP will issue 90-Day Reminder notifications in July to UST system owners and operators with  Compliance Certifications due in November 2015.

Data Management System Training for UST Owners, Operators, and Third-Party Inspectors

  1. Third-Party Inspector Online Webinar Training
    Data management system overview:
  • Registering as a user
  • Data management system navigation
  • Initiating a TPI and “sharing” a TPI Report with a UST system owner or operator.

Webinar Training Dates
No pre-registration is required to participate. Further information on webinar call-in number and conferencing service will be emailed to all TPIs prior to date of scheduled training and posted on MassDEP’s UST webpage.

  • July 15, 1 – 3pm
  • July 22, 1 – 3pm
  • July 30, 1 – 3pm
  • Aug 27, 1 – 3pm
  1. UST System Owners and Operators Training

This is “hands on” training for UST systems owners, operators and staff responsible for preparing and/or submitting UST registration documents, TPI Reports and Compliance Certifications.

Space is limited and available on a first come, first serve basis (system owners and operators with most imminent submittal due dates will receive priority). Additional sessions will be added as demand requires.

To reserve space, please submit your name, company, and preferred date and session to: dep.ust@state.ma.us.

Date July 17, 2015 July 21, 2015 July 27, 2015 July 28, 2015
Facility Bristol CC Holyoke CC Worcester State University North Shore CC
City/Town Fall River, MA Holyoke, MA Worcester, MA Danvers, MA
Room Capacity 28 23 25 18
Session #1 10am – Noon 10am – Noon 10am – Noon 10am – Noon
Session #2 1pm – 3pm 1pm – 3pm 1pm – 3pm 1pm – 3pm

Data Management System Training Materials on MassDEP’s Webpage
The following materials will be posted on MassDEP’s UST webpage (http://www.mass.gov/eea/agencies/massdep/toxics/ust/) at the time the UST Data Management System goes “live”.

  1. Data Management System User Guide
  2. “What Do You Want To Do” Guide
  3. Required Data Elements of Data Management System
  4. Audio Power Point Presentations
  5. DEP Hotline #

If you have any questions concerning the introduction of the new UST online Data Management System, please email the Program at: dep.ust@state.ma.us, or call the MassDEP UST Program Hotline at (617) 556-1035 Ext. 2.

Tom DeNormandie, Branch Chief
Massachusetts Department of Environmental Protection
Underground Storage Tank/Stage I & II Vapor Recovery Programs
One Winter Street – 7th floor
Boston, MA  02108
Phone: 617-292-5763
Fax: 617-556-1063

Are you ready to comply with the new MSGP? Reply

The US Environmental Protection Agency’s (EPA) new 2015 Stormwater Multi-Sector General Permit (MSGP) has a September 2, 2015 deadline. Are you ready? Perhaps you attended our webinar and have started your groundwork, or maybe you are just beginning to explore the permit and your eligibility; either way the deadline will be coming up quickly and if you have endangered species or historic properties to contend with, there are items you will need to complete at least 30 days prior to filing your NOI, moving the deadline up even sooner.

Whether you have all the resources you need and simply would like a peer review, or require more in-depth help like filing your Notice of Intent (NOI) or creating a Stormwater Pollution Prevention Plan (SWPPP), CAPACCIO can help companies that:

-Never had coverage under MSGP and have not determined eligibility

CAPACCIO can evaluate whether your facility will meet the requirements of a No Exposure Certification; if not, we can help file the Notice of Intent (NOI) and create a Stormwater Pollution Prevention Plan (SWPPP).

-Are covered under the MSGP and have filed a No Exposure Certification in the past

CAPACCIO can conduct a No Exposure evaluation to determine whether the No Exposure Certification remains valid.

-Are covered under the MSGP, have filed a NOI in the past, and have an existing SWPPP

CAPACCIO can conduct a MSGP Gap Analysis to determine which elements of your existing programs meet the compliance requirements under the updated MSGP and which elements may need to be improved prior to the September 2, 2015 deadline.

-Are covered under the MSGP, and have the resources to update the SWPPP and submit the NOI

CAPACCIO can conduct a peer review of your SWPPP along with your NOI application and supporting documentation to determine if you have meet the MSGP requirements prior to submittal.

During our recent webinar with David Gray, PE, Environmental Engineer U.S. Environmental Protection Agency, Region 1 , we compiled an extensive list of questions and answers from more than 100 companies that are trying to determine their eligibility and best course of action. CAPACCIO can be your trusted advisor on these matters, large or small, and has the experience to provide these services quickly and cost-effectively.

To receive guidance, please contact one of our technical experts today.

Lucy Servidio, CHMM, TURP
508-970-0033 ext. 114
lservidio@capaccio.com

or

Wayne Bates, PhD, PE, ENV SP
508-970-0033 ext. 121
wbates@capaccio.com