Did you receive an AST form from the DFS? Reply

If your organization uses an aboveground storage tank (AST) with capacity greater than 10,000 gallons, you may have received a letter and an “AST Approved Standard Declaration Form” from the Department of Fire Services (DFS) and you may wonder why.

The form is not a cause for alarm, but DFS requires AST permit-holders to complete one form for each permitted tank and return the form to DFS.

To refresh memories, in 2016 the DFS standards were changed and now each permitted AST must be inspected and maintained in accordance with an “Approved Standard” – a standard proposed by the permit-holder and approved by the DFS.  The Approved Standard you propose specifies the nature and frequency of the inspections you will perform for each tank.

As a holder of an AST Use Permit, organizations are responsible for ensuring the tank is inspected in accordance with an Approved Standard and that they maintain the records of inspections and maintenance performed in between renewals (Use Permits for ASTs renew every five years).  As part of the renewal process, a Qualified Inspector (as defined in 502 CMR 5.03) must inspect the tank and review the tank inspection and maintenance records to ensure that the tank has been inspected and maintained in accordance with its Approved Standard.  The findings of the tank inspection and documentation review are submitted to the DFS for review before the DFS will issue another Use Permit.

If you are an AST permit-holder, you may self-perform the inspections if you have a Qualified Inspector on staff. Otherwise you can retain an outside firm (e.g. an engineering firm, a tank supplier, or a chemical or industrial gas supplier) to provide the inspections and maintenance.  CAPACCIO recommends that if you utilize an outside firm, make sure to obtain documentation after each inspection and confirm that maintenance action is performed to ensure employee safety and regulatory compliance.

Ensuring your organization’s AST tanks are being maintained in accordance with the Approved Standard is an important aspect in avoiding and mitigating risks and ensuring business continuity for your organization.

If you received one of these letters from DFS, make sure to pay attention to the due date at the bottom of the letter as some we have seen are due as soon as August 30, 2019.

If you have any questions, please contact Chris Bannon, EIT or Art Cunningham, PE, or utilize our chat feature on our website.

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At CAPACCIO, we live our mission of “Helping Industry and the Environment Prosper”. We align EHS with your overall business objectives to strategically position you for success.  Our unique approach combines our extensive EHS experience with innovative tools, such as our EHS DashboardTM, to effectively address your challenges.  Our comprehensive solutions have resulted in award-winning EHS and overall business performance for our clients. We are certified WBENC, WBE. To learn more visit us at www.capaccio.com.

MassDEP Announces 2017 and 2018 Source Registration Information Reply

The MassDEP announced some much awaited information regarding forms and filing dates for Source Registration (SR) filers.

SR web forms for 2017 – including those for Greenhouse Gas (GHG) emissions reporting – are now available for certain Operating Permit facilities ONLY. These facilities have been notified that the deadline for filing their reports is June 21, 2019.

Filing of 2017 reports for other annual and 3-year filers is postponed until later this summer. MassDEP will notify these facilities directly of their due dates when eDEP is ready for them to file.

Filing for 2018 is postponed. MassDEP will notify filers directly when the 2018 forms are ready.

CAPACCIO can help you navigate the reporting system and deadlines and ensure you are including everything needed in this new process. We provide a full range of reporting services to meet your needs, from peer review to full submission. CAPACCIO’s EHS-DashboardTM can help you track your facility’s data collection and reporting so it is that much easier. Learn more about the dashboard at www.ehsdashboard.com.

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At CAPACCIO, we live our mission of “Helping Industry and the Environment Prosper”. We align EH&S with your overall business objectives to strategically position you for success.  Our unique approach combines our extensive EH&S experience with cutting edge technologies, such as our EHS DashboardTM, to effectively address your challenges.  Our comprehensive solutions have resulted in award-winning EH&S and overall business performance for our clients. We are certified WBENC, WBE. To learn more visit us at http://www.capaccio.com.

 

MassDEP Issues Updated List of TURA Chemicals for 2019 Reply

Each company subject to the Toxics Use Reduction Act (TURA) needs to file annual reports by July 1st of each year, for chemicals manufactured, processed, or otherwise used during the previous calendar year. TURA reports are required for toxic substances listed in two federal laws: Section 313 of the Emergency Planning and Community Right to Know Act (EPCRA) and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or “Superfund”).
A new complete list of chemicals subject to TURA reporting, along with reporting thresholds, is now available on the MassDEP website:
Here is a run down on what is new:
Nonylphenols category – DEP Code 1220
Nonylphenols are reportable for this year. The Nonylphenols category has been reportable under TURA since RY 2017 and under TRI since RY 2015.  The nonylphenols category includes these substances: 4-Nonylphenol, Isononylphenol, Nonylphenol, 4-Isononylphenol, 4-Nonylphenol, branched, Nonylphenol, branched. More about this chemical category can be found at: https://www.epa.gov/toxics-release-inventory-tri-program/addition-nonylphenol-category#additional-resources
Hexabromocyclododecane (HBCD) category – DEP Code 1240
HBCD category chemicals are reportable for this year (RY2018) and was reportable under TRI for RY 2017. The HBCD category includes hexabromocyclododecane and 1,2,5,6,9,10 hexabromocyclododecane. More information about this chemical category can be found at: https://www.epa.gov/toxics-release-inventory-tri-program/addition-hexabromocyclododecane-hbcd-category-tri-list-final
Nonylphenol Ethoxylates (NPEs) category – DEP Code 1046
NPEs will be reportable next year under TRI for RY 2019, and to TURA for RY 2020. Start keeping records for 2019. More information about this chemical category can be found at: https://www.epa.gov/toxics-release-inventory-tri-program/addition-npes-category-tri-list-final-rule and https://www.mass.gov/files/documents/2019/04/04/turachanges.pdf
The C1-C4 halogenated hydrocarbons/halocarbons not otherwise listed (C1-C4 NOL) category – DEP Code 1047
The C1-C4 NOL category will be reportable under TURA for RY 2019. Begin keeping records in 2019. C1-C4 NOL includes any chemical substance that has four or fewer carbons, at least one halogen, and only hydrogen as the other constituent, that are not already individually listed. This includes fully halogenated chemicals that contain no hydrogen. More information about this chemical category can be found at: https://www.mass.gov/files/documents/2019/04/04/turachanges.pdf

Please also be aware:
Many chemicals on the TURA reportable chemicals list are designated as PBT (persistent, bioaccumulative, toxic) or HHS (higher hazard substance). These chemicals have lower reporting thresholds, which are indicated in the TURA list.

If you have questions or need assistance with your TURA reporting, CAPACCIO has several TURPs on staff. Please contact Jill Vernes at jvernes@capaccio.com for more information.
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At CAPACCIO, we live our mission of “Helping Industry and the Environment Prosper”. We align EH&S with your overall business objectives to strategically position you for success. Our unique approach combines our extensive EH&S experience with innovative tools, such as our EHS DashboardTM, to effectively address your challenges. Our comprehensive solutions have resulted in award-winning EH&S and overall business performance for our clients. We are certified WBENC, WBE. To learn more visit us at www.capaccio.com.

 

Join us for MassDEP’s Multi-Media Inspection: What to Expect Reply

Join us as the Central Massachusetts Business Environmental Network (CMBEN) in partnership with the Worcester Regional Chamber of Commerce present:

MassDEP’s Multi-Media Inspection: What to Expect

Print the flyer for this meeting

Where:  MassDEP, CERO, 8 New Bond Street, Worcester, MA 01606

Workshop topic and speaker: 

Giles Steel-Perkins of the MassDEP will discuss MassDEP’s Multi-Media inspection process and will be available to answer any questions you may have.

Register: 
Email Isabelle Lavigne from Irwin Engineers or call her at 508.653.8007 ext. 10.
Although there is no cost for this meeting, seating is limited so please register soon, and no later than May 10, 2019.
 
What is CMBEN?
The Central Massachusetts Business Environmental Network (CMBEN) is a network of EHS Managers and other EHS professionals serving industry in Central Massachusetts. We represent some of the region’s largest businesses with years of experience in EHS management. To join CMBEN, e-mail Isabelle Lavigne from Irwin Engineers at ilavigne@irwinengineers.com or call her at (508) 653-8007 ext. 10, or any of the
CMBEN 
Board Members:

Lucille Servidio (508) 970-0033 x114
Donald Alger (508) 854-5560, thealgers@gmail.com
Brian Postale (508) 767-2888, brian.postale@state.ma.us
Marina Gayl (617) 626-1077, marina.gayl@state.ma.us
Lindsay Chhon (508) 688-3097, lindsay.chhon@abbvie.com
Andy Irwin (508) 653-8007, airwin@irwinengineers.com
Dona Neely (978)-772-8831, donaneely@ecostardevens.com
Paul Watson (413)-822-7257, pcwatson@cfsoptics.com

CMBEN    Worc Chamber of Commerce

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At CAPACCIO, we live our mission of “Helping Industry and the Environment Prosper”. We align EH&S with your overall business objectives to strategically position you for success. Our unique approach combines our extensive EH&S experience with innovative tools, such as our EHS DashboardTM, to effectively address your challenges. Our comprehensive solutions have resulted in award-winning EH&S and overall business performance for our clients. We are certified WBENC, WBE. To learn more visit us at www.capaccio.com.