Reminder: 2012 is a planning year under the Toxics Use Reduction Act (TURA) Reply

The letter was sent by Suzi Peck,  Director of the Toxics Use Reduction Program, Bureau of Waste Prevention, for the MassDEP

Facility Manager and/or Toxics Use Reduction Planners: 2012 is a planning year under the Toxics Use Reduction Act (TURA) and facilities covered by TURA are required to complete their TURA planning for this planning cycle by July 1, 2012. Last December, MassDEP sent a postcard alerting that notice to employees regarding the planning process was to be completed by January 1, 2011. Facilities that are required to submit a Form S for at least one chemical by July 1, 2012, and who have submitted a Form S for that chemical on a prior year, are required to complete one of three types of planning for the 2012 planning year:

Toxics Use Reduction (TUR) Planning
Resource Conservation (RC) Planning
Environmental Management Systems (EMS)

Toxics Use Reduction (TUR) Planning
If a facility has completed only one TUR plan and one TUR plan update, then the facility is required to develop a toxics use reduction plan or plan update, and to submit a TUR Plan Summary to MassDEP by July 1, 2012. In addition, if a facility prepared a Resource Conservation Plan in 2010, it must return to TUR planning for the 2012 planning cycle or integrate TUR planning into an Environmental Management System. Facilities that completed aResource Conservation Plan in 2010 are also required to submit a Resource Conservation Progress Report to MassDEP by July 1, 2012.

Resource Conservation Planning
If a facility has completed a TUR plan and two plan updates (i.e., completed TUR plans for three planning cycles), it may elect to prepare a Resource Conservation Plan for the 2012 planning year. Resource conservation planning is aimed at reducing energy, water, materials, or non-reportable chemicals. This option may be attractive to facilities that have succeeded in reducing toxics use and are looking for other opportunities to further environmental improvement and facility efficiency. If you choose this option, submit a Resource Conservation Plan Summary (instead of a TUR Plan Summary) to MassDEP by July 1, 2012, documenting your planning effort. In addition,if your facility did a Resource Conservation plan in planning year 2008, and completed a TUR plan and a Resource Conservation Progress Report in 2010, then you may return to Resource Conservation planning in 2012.

Environmental Management Systems
If a facility has completed a TUR plan and two plan updates (i.e., completed six years of TUR planning), it may integrate TUR into its Environmental Management System (EMS). This option allows companies that already have an EMS to integrate TUR into this more comprehensive system, thereby reducing duplication of effort. If you choose this option, then submit an EMS Progress Report to MassDEP by July 1, 2012 documenting that your EMS addresses toxics use reduction.

Plan Submittals due by July 1, 2012
Depending on which option you choose, a TUR Plan Summary, RC Plan Summary, or EMS Progress Report must be submitted to MassDEP by July 1, 2012. This means that all required planning must be completed before this date. MassDEP encourages facilities to file Plan Summaries online through eDEP, available at: www.mass.gov/dep/service/compliance/edeponlf.htm

Plan Certifications
TUR Plans must be certified by a MassDEP approved Toxics Use Reduction Planner. RC Plans must be certified by a
TUR Planner that also has specific training in resource conservation (see 310 CMR 50.63) and has been approved by
MassDEP to certify RC Plans. EMS Progress Reports must be certified by either a TUR Planner with training in EMS and approved by MassDEP to certify EMS plans, or by an EMS professional with training in TUR.

For more guidance on certification requirements, please consult the MassDEP web site at:
http://www.mass.gov/dep/toxics/approvals/turforms.htm#cert

If you do not have a certified in-house TUR Planner, you should consider hiring a general practice TUR Planner to guide you through the planning process. An updated list of certified Planners (as of February 2012) is available on MassDEP’s web site at:www.mass.gov/dep/toxics/tura/planners.htm

Guidance, Training, and Technical Assistance
Helpful web links for further guidance, training, and technical assistance resources include:

Regulations, Fact Sheets and Guidance: MassDEP
www.mass.gov/dep/toxics/laws/policies.htm

Continuing education training sessions on TUR planning, RC planning and EMS: MassDEP
 http://www.mass.gov/dep/toxics/tura/training.htm

This site includes links to training and workshops provided by the Toxics Use Reduction Institute, Office of Technical Assistance and Technology and MassDEP.

For questions or more information on TURA planning requirements please contact the MassDEP staff listed below:

Toxics Use Reduction Planning, Lynn Cain, lynn.cain@state.ma.us, 617-292-5711
Resource Conservation Planning, Lynn Cain, lynn.cain@state.ma.us, 617-292-5711
Environmental Management Systems, Cynthia Chaves, cynthia.chaves@state.ma.us, 617-292-5848

US EPA TRI/TURA RY-2011 Compliance Assistance Workshops Reply

Owners/Operators/Consultants/Engineers

US EPA, Region 1, in conjunction with the Massachusetts Department of Environmental Protection, and the Massachusetts Office of Technical Assistance, are providing a series of Toxic Release Inventory/Toxic Use Reduction Act Compliance Assistance Workshops in locations throughout Massachusetts. These workshops are designed for the experienced TRI reporter and are free but require registration via email.

New TRI reporters should complete the TRI training modules before attending the workshops:

http://www.epa.gov/tri/training/2011/index.htm

TRI/TURA Compliance Assistance Workshop Locations:

Thursday April 26, 2012…North Central Massachusetts Chamber of Commerce, 860 South Street, Fitchburg

Tuesday May 8, 2012…Mass. Mutual Ins. Learning & Training Center, 350 Memorial Drive, Chicopee

Tuesday May 15, 2012…ATMC Conference Center, 151 Martine Drive, Fall River

Wednesday May 23, 2012…Parker River Wildlife Refuge, Headquarters Building, 6 Plum Island Turnpike, Newburyport

6 CEU units will be provided by the Massachusetts Department of Environmental Protection.
TRI & TURA Agenda:

8:30-9:00             sign in
9:00-10:30           TRI Reporting-2011/Forms R&A Changes, Updates & Common Errors (US EPA)
10:30-10:45         break
10:45-11:00         MassDEP TURA Enforcement overview (MA DEP)
11:00-12:00         Planning Process – TURA & RC Planning (MA OTA)
12-1:00                Lunch (on your own)
1:00-1:30             Planning Case Studies (MA OTA)
1:30-2:30             TURA Implemented by facilities during the 2008 & 2010 planning cycles (MA DEP)
2:30-2:45             Break
2:45-4:00             eDEP TURA Reporting & Planning (MA DEP)

Dwight Peavey, US EPA TRI Program Coordinator, will present the EPA portion of the workshops. Walter Hope and Suzi Peck from MA DEP and Scott Fortier from MA OTA will be presenting the TURA portion of the workshops.

To register… e-mail Nicholas Leonardi at <leonardi.nicholas@epa.gov> …please indicate the date and location of the workshop that you will attend.  Check the time and locations carefully.  Also, include your name, company and address. You may also fax your registration to 617-918-0636.

YOU WILL NOT RECEIVE A CONFIRMATION… if you need additional assistance for the workshops, please contact Nicholas Leonardi via e-mail at <leonardi.nicholas@epa.gov>.

EHS Roundtable covering 527 CMR 33 scheduled for Friday, March 30 1

The Devens EcoEfficiency Center is holding an EHS Roundtable on Friday, March 30 to provide an overview of the new Massachusetts Department of Fire Services (DFS) Hazardous Materials Processing regulation (527 CMR 33) and discuss its development. Presenters will be Tim Rodrique, Director of the Division of Fire Safety within the State Fire Marshal’s Office and a focal driver of the regulation within the MA Board of Fire Prevention Regulations (BFPR), and practitioners with experience reviewing and facilitating process hazard analyses (PHAs) and Process Safety Reviews (PSRs) for clients in industrial plants and high technology academic research institutions.

The presenters will explain the differences from the process safety management (PSM) standard from OSHA and USEPA risk management plan (RMP) requirements. Presenters will also discuss some of the most important requirements and responsibilities contained within the Hazardous Material Process regulation and describe the current schedule for its implementation in the Commonwealth. After the presentation there will be time to respond to questions.  

On February 3, 2012 the new 527 CMR 33 came into effect.  DFS developed this regulation to help prevent the occurrence of incidents like the explosion in Leominster in 2005, the fire and explosion in Danvers in 2006, and the fire and explosion in Middleton in 2011 – all involving processes using hazardous materials.

Capaccio Environmental Engineering’s Linda Swift and Geoff Gilbert have been closely tracking the development of this new regulation and will be in attendance.   If you are unable to attend, but have questions or concerns about this regulation and how it might impact your operations, please post  your question in the comment section of this blog, or e-mail Linda or Geoff directly at lswift@capaccio.com or ggilbert@capaccio.com.

The meeting will be at:
33 Andrews Parkway, Devens, Conference Room 1
Registration fee is $15. Coffee and bagels will be available
RSVP donaneely@ecostardevens.com or 978-772-8831 x3304

Template for Construction Stormwater Pollution Prevention Plans Available Online Reply

The  EPA has posted a new template for construction operators to use in developing stormwater pollution prevention plans, which are site-specific documents required as part of EPA’s new 2012 Construction General Permit. The template is designed to help construction operators develop a stormwater pollution prevention plan that is compliant with the minimum requirements of the new permit. The template allows operators to customize the document to the needs of the site, and includes tables and other fields that are easy to fill out.

For questions about the template, or the permit in general, please send inquiries to CGP@epa.gov. For additional information on stormwater pollution prevention plans for construction activities and to view a copy of the template visit:

http://cfpub.epa.gov/npdes/stormwater/swppp.cfm.

For additional information on EPA’s 2012 CGP visit:

http://cfpub.epa.gov/npdes/stormwater/cgp.cfm.

This notice is courtesy of Water Headlines, a weekly on-line publication that announces publications, policies, and activities of the U.S. Environmental Protection Agency’s Office of Water.

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