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.

Capaccio Environmental Engineering, Inc. Places #1 in Zweig Group’s Best Places to Work Reply

PrintCapaccio Environmental Engineering, Inc. (CAPACCIO) is proud to announce that it has been named #1 in Zweig Group’s Best Places to Work ranking of environmental engineering & consulting firms.  ZweigGroup provides specialized management information and expertise for architecture, engineering, planning, and environmental consulting firms.

Companies located throughout the United States and Canada were ranked by an independent research firm based on a review of company practices and the results of anonymous employee surveys. Areas evaluated included workplace practices, benefits, compensation, retention rates, employee engagement, firm performance, and more. Having placed in the top ten in the past two years, CAPACCIO is thrilled to have risen to the top spot this year.

“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 each other,” said President and CEO Lisa Wilk. “Toward this end, we strive to foster an atmosphere for professional growth, innovation; teamwork, open-communication, feeling valued, and delivering top quality results. We are very excited to be recognized for our efforts toward this goal.”

CAPACCIO is a women-owned, 30-person environmental, health and safety consulting and engineering firm based in Marlborough, MA whose mission is “Helping Industry and the Environment Prosper.” CAPACCIO, and this year’s other top firms, will be recognized at ZweigGroup’s Awards Conference on September 22-23, 2016 in Phoenix, Arizona.  To learn more about CAPACCIO, please visit us at www.capaccio.com.

TRI FACILITIES – IMPORTANT INFORMATION ON CDX SHUT DOWN Reply

The important update pasted below was sent by the EPA to inform TRI filers that the Central Data Exchange (CDX) system will be shutting down for upgrades and maintenance starting at 6 a.m. on July 2. As you will not be able to submit your TRI information once the system goes offline, TRI facilities are being urged to submit their information early as it is a violation to submit or certify your forms late. Penalties can be significant. There are only 2 weeks to go before this shut-down occurs, so if you are in need of any TRI reporting assistance, please contact Colleen Walsh, CHMM, at CAPACCIO at 508-970-0033 ext. 129 or cwalsh@capaccio.com.

A certifying official must have an approved Electronic Signature Agreement (ESA) form in place before certifying and submitting TRI forms. If a new certifying official will certify TRI reporting forms for your facility, EPA recommends that the certifying official register with CDX and complete an ESA at least a couple of weeks before the July 1 deadline.

Email sent by the US EPA:

  • EPA’s Central Data Exchange (CDX) (where you submit your TRI information) will be shut down for upgrades and maintenance starting 6:00am July 2. So please submit and certify your TRI information as soon as possible. DO not wait until the last week to fill out and submit your forms or call the help line.  It is a violation to submit your forms late, and it is a violation to certify your forms late. Penalties can be significant.  Call the Central Data Exchange (CDX) helpline (888-890-1995) to confirm your electronic data transfer went through and the forms have been properly certified.

Here is the website for general TRI-ME web information:

http://www2.epa.gov/toxics-release-inventory-tri-program/tri-meweb-resources

Specific guidance on TRI-ME web reporting process is here:

http://www2.epa.gov/toxics-release-inventory-tri-program/tri-meweb-reporting-process

Additional guidance on TRI reporting can be found here:

http://www2.epa.gov/toxics-release-inventory-tri-program/reporting-tri-facilities

  • The process to electronically certify your forms is not straight forward. Please remember the electronic submission of your form must be finished by certification by your certifying official. If it has not been certified –  the data you just submitted electronically does not enter the system.  It may be a good idea to check your submission in eFDP

https://tri-epa.zendesk.com/hc/en-us/articles/212345657-Viewing-an-electronic-Facility-Data-Profile-in-TRI-MEweb

  • or call the CDX hotline to confirm the certification has gone through and everything has been correctly received.
  • Notification of no longer reporting – You can learn how to report that your facility is not reporting to TRI by viewing this tutorial. The TRI-MEweb application can now be used to report on your facility status with having to submit a Form R. All you need to have is a CDX user account and your access key to access your facility’s account.

https://www.epa.gov/sites/production/files/2016-04/entering_optional_facility_level_information-april22.swf

A facility can provide this information in TRI-MEweb or by emailing the TRI Data Processing Center (tridpc@epacdx.net). In TRI-MEweb the user would click the “My Facilities” tab and then click the “Provide Additional Info” button in the last column for the facility that wants to indicate it is not reporting for a particular reason (e.g., <10 FTE, activity fell below reporting threshold, etc.). For emailing the Data Processing Center, we recommend the person provide the name of the facility, ID for the facility (TRIFID), and a brief rationale.  We recommend facilities use the TRI-MEweb option, though either option works.

EPA contact for more information: Chris Rascher Environmental Engineer U. S. Environmental Protection Agency Region 1, OES 05-1 Boston, MA  02109 (617) 918-1834.

 

Proposed Revisions to the Risk Management Program Regulations Reply

On March 14, 2016, EPA published its proposed amendments to the Risk Management Program regulations in response to Executive Order 13650. The proposed revisions include several changes to the accident prevention program requirements including more extensive Process Hazard Analysis requirements, third party audits and root cause analysis during accident investigations, enhancements of the emergency preparedness requirements, increased public availability of chemical information and related streamlining of risk management plans.

Several proposed revisions are only applicable in the event that an accident, or near miss, occurs at the facility that meets the definitions in the regulation for reportable accidents. However, the proposed changes to the emergency preparedness requirements will affect all Program 2 and Program 3 facilities.

Under the proposed revisions, all Program 2 and Program 3 facilities will be required to conduct annual emergency response coordination in which the owner or operator must work with local emergency planning and response organizations to ensure resources and capabilities are in place to respond to an accidental release. All Program 2 and Program 3 facilities will also be required to conduct an annual notification exercise in which the mechanisms for notifying first responders will be executed and verified. Additional emergency response preparedness provisions are proposed for facilities that are “self-responders”. Along with the required coordination and notification described above, these facilities must also conduct annual tabletop exercises and a field exercise once every five years. The exercises must be coordinated with local emergency response officials.

These revisions are in response to repeated findings during accident investigations that indicated coordination of emergency response actions was inadequate and contributed to the severity of the accident. EPA believes that the proposed revisions will enhance and improve coordination between regulated sources and first responders such that the effects of accidents will be reduced.

For more information about the proposed rule, refer to https://www.epa.gov/rmp/proposed-changes-risk-management-program-rmp-rule .

If you have questions about the Risk Management Program or Risk Management Plans, please contact Chris Walton at 508-970-0033 ext. 139  or  cwalton@capaccio.com  or Christine Silverman at 508-970-0033 ext. 127 or csilverman@capaccio.com

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EPA Releases the 2016 Massachusetts Small MS4 General Permit Reply

The  2016 Massachusetts Small MS4 General Permit was signed April 4, 2016 and was published in the Federal Register on April 13, 2016. The small MS4 general permit will become effective July 1, 2017. The final permit replaces the 2003 small MS4 general permit for MS4 operators within the Commonwealth of Massachusetts.

In order for a small MS4 operator to obtain authorization to discharge, it must submit a complete and accurate Notice of Intent (NOI) containing the information in Appendix E of the 2016 general permit. The NOI must be submitted on or before September 29, 2017 (90 days from the effective date of the final permit). A small MS4 operator must meet the eligibility requirements of the general permit found in Part 1.2 and Part 1.9 prior to submission of its NOI.

EPA will be holding a number of public meetings for informational purposes. See the link below to see a schedule of the meetings which are currently planned:

https://www3.epa.gov/region1/npdes/stormwater/MS4_MA.html
CAPACCIO has assisted state college campuses with compliance planning and implementation of the current MS4 permit and has been tracking this new permit.

For more information about how CAPACCIO can help, please contact Christopher Walton at (508) 970-0033 x139 or cwalton@capaccio.com .