Federal NPDES Stormwater Annual Site Inspections Due September 29 Reply

Have you conducted your Stormwater Annual Site Inspection?  Companies with coverage under the National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit for stormwater discharges associated with industrial activity must conduct an Annual Comprehensive Site Inspection by September 29, 2012.  The period for the inspection is September 29, 2011- September 29, 2012.  The annual comprehensive site inspection includes an inspection of the areas where industrial activity may be exposed to stormwater, and a review of corrective actions taken during the reporting period.  The Annual Reporting Form (Appendix I of the MSGP) must be mailed to the EPA within 45 days after completion of the inspection.

Companies covered under the 2008 MSGP must continue quarterly visual assessments, routine facility inspections, and required effluent or benchmark monitoring.  Results for quarterly benchmark monitoring must be submitted to the EPA within 30 days of receiving the results from the laboratory.

“No Exposure” Certifications obtained under NPDES regulations for stormwater permitting in 2007 are valid for five years and will expire in 2012. Companies should reassess whether the “No Exposure” conditions still apply and renew if applicable. Companies that have never filed a “No Exposure” Certification should consider whether their facility can meet the conditions of the certification, therefore precluding the need for coverage under the MSGP.

If you have any questions or need assistance, please call Lucy Servidio at (508) 970-0033 extension 114 or lservidio@capaccio.com.

EPA Updates to EPCRA Section 312 (Tier I and II Reporting) Requirements Reply

The US Environmental Protection Agency (EPA) has modified its Emergency Planning and Community Right-to-Know Act (EPCRA) Section 312 Emergency and Hazardous Chemical Inventory Forms (Tier I and Tier II forms) with both new mandatory and optional data elements and updates to the Tier II form structure.

The following data is now mandatory on Tier I and II forms:

  • Reporting facility’s latitude and longitude
  • Identification numbers assigned under EPA’s Toxic Release Inventory (Form R reporting) program and Risk Management Program (if applicable)
  • Whether the facility is manned or unmanned and the maximum number of occupants present at any one time
  • Whether the facility is subject to EPCRA Section 302 (Emergency Planning Notification) and the Clean Air
    Act Section 112 (r) (Risk Management Program)
  • Contact information for the individual responsible for completing the forms and emergency coordinator for facilities subject to EPCRA Section 302
  • Owner/Operator and emergency contact email addresses

In addition to the above, the rule also revised the range codes for the maximum and average daily amount of the hazardous chemical at the facility and added optional data elements for facility phone number and parent company contact information.

EPA also made revisions specific to the Tier II form:

  • Added separate data fields for reporting pure chemicals and mixtures
  • Facilities must provide a description for storage types and conditions rather than reporting codes
  • Revisions to allow for reporting of additional state or local reporting requirements or to voluntarily report hazardous chemicals below the reporting thresholds

These changes are effective January 1, 2014 for reporting year 2013.  Forms for reporting year 2013 are due March 1, 2014.

Please contact Linda Swift at (508) 970-0033 extension 119 or via email at lswift@capaccio.com with any questions you may have regarding these changes.

Reminder – 2012 CDP Reporting Deadlines are Approaching Reply

The Carbon Disclosure Project (CDP) reporting deadlines for 2012 are rapidly approaching.  As a reminder, below are the upcoming deadlines. The CDP rankings are widely used to evaluate the performance and transparency of publically traded companies (even Google Finance prominently lists CDP rankings as part of company key stats and ratios).   Guidance on CDP reporting and information on the scoring methodology is available on the CDP website.

The timeline for Carbon Reporting for Investor CDP:

  • Feb 1:  CDP sends out its annual information request to companies worldwide
  • May 31:  Deadline for corporations to submit their responses
  • Sept –  Publically disclosed information is published on the CDP website

 The timeline for Carbon Reporting for Supply Chain CDP:

  • April 1:  CDP sends out its annual information request to companies worldwide
  • July 31:  Deadline for suppliers to submit their responses
  • Jan – Publically disclosed information is published on the CDP website

The timeline for CDP Water Reporting:

  • Feb 1 – CDP Water Disclosure Information Request to targeted companies
  • June 30 – Deadline for companies to respond to the questionnaire
  • Oct-Nov – Public response data is published on CDP website

Capaccio Environmental Engineering, Inc. has assisted our clients with sustainability strategic plans, benchmarking, gap analysis, carbon and water footprinting, program implementation, data management, and reporting to help improve rankings as well as address other important sustainability performance objectives.   We are proud of the fact that our clients consistently appear at the top of both environmental and business performance lists, which is consistent with our mission of “helping industry and the environment prosper.”

For additional information or assistance in completing or reviewing reports, please contact us at information@capaccio.com.

When in doubt, wear a cape! Reply

On  May 3, 2012, I had the honor to present “20 Years of  Making the Toxics Use Reduction Act (TURA) work for business’ in Massachusetts” at the Cancer Council Autralia’s (CCA) Cancer in the Workplace – A forum on practical solutions for prevention. I was amazed at the feedback I received and of the hope my presentation gave to the attendees. I was even more amazed at the great research and presentations that I was asked to be part of. The presentations opened my eyes to Australia’s biggest occupational health issues of mesothelioma (working with/mining asbestos) and melanoma (sun exposure).

New Friends-Cancer Coucil Australia

I was able to attend a strategic planning meeting with the CCA. When I was about to leave they asked me to give my two cents of advice on how to get a TURA-like law rolling. I reminded CCA that TURA was first ignited by Ken Geiser (then at Tufts) and Mike Ellenbecker (then at U Mass Lowell) who were from acadamia…not the legislature. Maybe the Royal Melbourne Institute of Technology could be the starting point. Also, that starting off with Victoria, one state, rather than going country-wide would have a greater chance of success. Lastly, I said don’t forget TURA’s secret sauce…mandatory reporting/planning…voluntary implementation based on a viable business case.

Lucy Servidio The Cape Crusader

When saying good byes and giving hugs Terry Slevin, CCA said to me that they weren’t sure what they were going to get when we they asked me to come down to speak, but one minute into my speech they knew we had asked the right person…I remarked, “Did the cape frighten you?” He replied, “Not at all.” His only fear was that Dr. Tim Driscoll, Professor at University of Sidney, would start wearing one.

For those of you who have never wore a cape when making a presention, I would highly recommend it…it did make me feel like I could do or say anything!