Annual Rideshare Reports Due December 31, 2016 Reply

The Massachusetts Department of Environmental Protection’s (MassDEP’s) Rideshare Regulation (310 CMR 7.16) requires facilities that meet certain criteria to complete and submit an annual Rideshare Report summarizing its rideshare program.

The criteria that must be met to be applicable to these requirements includes:

  • Businesses with 250 or more applicable commuters that are subject to the MassDEP Air Operating Permit Program (310 CMR 7.00, Appendix C) or
  • Businesses with 1,000 or more applicable commuters
  • Educational institutions with 1,000 or more applicable students or applicable commuters combined

“Applicable commuters” are employees that work 17 hours or more per week for 20 or more weeks per year; that commute to work between the hours of 6:00 a.m. and 8:00 p.m.; and use their vehicle for work purposes during work hours less than 5 times per month.

“Applicable students” are students that are full-time commuting students and live off campus; are scheduled to begin and complete classes between 6 a.m. and 8 p.m.; and need their vehicle for class assignments or for after-school work less than five times per month.

For further details, please visit:

http://www.mass.gov/eea/agencies/massdep/air/programs/the-massachusetts-rideshare-program.html

If you meet the rideshare requirements, your annual report is due December 31, 2016.

What must you do if your business/educational facility meets the requirements?

  • Collect data by surveying your employees/students current commuting patterns*
  • Identify available commuting options
  • Set goals and develop a plan for reducing drive-alone commute trips by 25 percent
  • Offer options and incentives to reduce drive-alone commute trips
  • Review how commuting patterns will change as a result

*For the majority of businesses and educational institutions this year is a long form year and a survey may be required.  Many companies choose to conduct a survey each year.

Many facilities find collecting rideshare data and surveying employees and students a challenge. CAPACCIO has been helping clients for years by making this process easier and more efficient. Using web-based forms we have developed, CAPACCIO can host your custom commuter survey online and collect data in a database for easy analysis. The findings can be shared with employees online and also be tailored to report commuter trends for your environmental management system (EMS) objectives and targets and help facilitate the completion of your rideshare report. The tool may also be tailored to your facility’s internal programs where employee transportation has been identified as a significant environmental aspect in your EMS goals and targets.

For more information, please contact Dan Forsythe at 508-970-0033 ext. 135 or dforsythe@capaccio.com

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

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.

 

Environmental Protection Agency (EPA) Refrigerant Management Changes On The Way Reply

Section 608 of the Clean Air Act requires EPA to develop programs that protect the stratospheric ozone layer and prohibits the knowing release of ozone-depleting substances (ODS) and substitute refrigerants during the course of maintaining, servicing, repairing, or disposing of appliances or industrial process refrigeration. On November 9, 2015, EPA published a proposed rule to amend these refrigerant management program regulations.

Here is a brief summary of the changes EPA has proposed.

  • Extend the regulations to cover substitute refrigerants to non-ozone-depleting substitute refrigerants, including but not limited to hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs).
  • Strengthen the requirements to repair leaking appliances containing 50 or more pounds of refrigerant by lowering applicable leak rates for
    • industrial process and commercial refrigeration appliances from 35 percent to 20 percent, and
    • comfort cooling appliances from 15 percent 10 percent
  • Require regular leak inspections or continuous monitoring of refrigeration and air conditioning systems including:
    • annual inspections for systems normally containing 50 pounds or more of refrigerant
    • quarterly inspections for commercial refrigeration and industrial systems normally containing 500 pounds or more of refrigerant
  •  Extend the current sales restriction on ODS refrigerants to substitute refrigerants with the exception of small cans (two pounds or less) of motor vehicle air conditioning (MVAC) refrigerant
  • Prohibit operation of systems normally containing 50 pounds or more of refrigerant that have leaked 75% or more of their full charge for two consecutive years.
  • Extend current recordkeeping requirements for appliances with less than 5 pounds and more than 50 pounds of refrigerant to appliances containing between 5 and 50 pounds of ODS and non-ODS substitute refrigerants. The change will require all technicians to keep records of the amount of ODS and substitute refrigerant recovered when disposing of all appliances.
  • Update the Technician Certification Program to require certification for servicing appliances containing non-exempt substitutes and also require certifying organizations to publish lists or online databases of technicians that have been certified.

EPA is proposing that most of the final rule become effective on January 1, 2017 but recognizes that for certain requirements, stakeholders will need additional time to comply. Therefore, EPA is proposing compliance dates from one year to 18 months after publication of the final rule for appliance maintenance and leak repair requirements.

If you own, operate, or use refrigeration contractors to service your industrial refrigeration or comfort cooling equipment, be aware that these changes may impact you, your facility, your equipment, and your regulatory reporting obligations.

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