UST Owners and Operators – Check Your Financials Reply

Per Massachusetts Underground Storage Tank (UST) regulations found at 310 CMR 80.52: All Owners or Operators of UST systems shall maintain and demonstrate financial responsibility for taking corrective action and for compensating third parties for bodily injury and property damage caused by accidental releases arising from the operation of UST systems.

Many Owners and Operators use commercial insurance. However, the regulation requires the coverage to be in the form of a separate policy or an endorsement to an existing policy. Any endorsement must include very specific language included in the regulation.

Why does this matter?

In accordance with 310 CMR 80.49(7), third party inspectors are required to verify that financial responsibility is current and documented. However, the date of the third party inspection is not the best time to be seeking the proper documentation; a better time is now! A few phone calls this week will save many headaches when it is time for the next third party inspection.

If you need a third party inspection, or if you have other UST questions, please contact Christopher Walton, PE, at cwalton@capaccio.com or (508) 970-0033 ext. 139.

 

Changes to EPCRA Sections 311 and 312 hazardous chemical reporting forms (Tier I and Tier II) will become effective January 1, 2018 1

Summary of Changes:
The Environmental Protection Agency (EPA) has decided to revise existing hazard categories currently used for hazardous chemical inventory reporting under EPCRA Section 311 (Tier I) and Section 312 (Tier II) to conform to the hazard classes now used in the Occupational Safety and Health Administration (OSHA) revised Hazard Communication Standard (HCS). EPA has decided to replace the existing five hazard categories:

  • Fire
  • Sudden Release of Pressure
  • Reactive
  • Immediate (Acute)
  • Delayed (Chronic)

with the specific hazard classes listed in the revised OSHA Hazard Communication Standard:

Physical Hazard Health Hazard
Flammable (gases, aerosols, liquids, or solids) Carcinogenicity
Gas under pressure Acute toxicity (any route of exposure)
Explosive Reproductive toxicity
Self-heating Skin Corrosion or Irritation
Pyrophoric (liquid or solid) Respiratory or Skin Sensitization
Pyrophoric Gas Serious eye damage or eye irritation
Corrosive to metal Specific target organ toxicity (single or repeated exposure)
Oxidizer (liquid, solid or gas) Aspiration Hazard
Organic peroxide Germ cell mutagenicity
Self-reactive Simple Asphyxiant
In contact with water emits flammable gas Hazard Not Otherwise Classified (HNOC)
Combustible Dust
Hazard Not Otherwise Classified (HNOC)

EPA will be modifying the Tier2 Submit software developed for reporting under section 312 to include the new physical and health hazards. For states that have their own reporting software for section 312, EPA is providing flexibility to allow states to modify their software by January 1, 2018. Facilities are required to comply with reporting the new physical and health hazards on their Tier II inventory form for reporting year 2017, by March 1, 2018.

Dates:

Effective Date: This final rule was effective June 13, 2016.

Compliance Date: The compliance date is January 1, 2018.

Note: These changes will not affect reporting for the current year 2016 and existing forms and software will be used for completing Tier II reports which must be completed by March 1, 2017.

For more information, please contact Bob King, CIH, CSP, at 508-970-0033 ext. 113 or bking@capaccio.com.

EPA to evaluate national wastewater standards for electronics manufacturers Reply

CAPACCIO is tracking a new Environmental Protection Agency (EPA) initiative that may ultimately affect any semiconductor or electronic component manufacturer that generates process wastewater. Every two years, the EPA publishes its plan to revise national wastewater discharge standards (also known as Effluent Limitation Guidelines or “categorical standards”). The 2016 plan, published in the Federal Register on June 27, 2016 (www.epa.gov/eg) discloses that EPA will evaluate the Electronic and Electronic Components Category, which includes manufacturers of a wide variety of products including semiconductors, crystals, wafers, photovoltaics, and others as defined by EPA (see current EPA regulation at 40 CFR 469). EPA has not changed this regulation since 1983 and EPA acknowledges there have been many developments in the category since 1983. EPA will review current wastewater discharges, wastewater treatment, pollution prevention and management technologies and may establish new baseline metrics (discharge standards, water use limits, best management practices) that would apply to all members of the category.

If you have questions about how this may impact you, please call Art Cunningham, Director of Engineering at CAPACCIO, (508) 970-0033 ext. 141 or acunningham@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.