August 7, 2017 – UST Deadline Reply

The August 7, 2017 deadline for closure of single-walled steel underground storage tanks (USTs) is rapidly approaching per the Massachusetts Department of Environmental Protection (MassDEP) UST Systems regulation 310 CMR 80.15. This regulation applies to all in-service and temporarily out-of-service USTs, with the exception of consumptive use tanks and tanks that were relined prior to August 8, 2007 in accordance with API 1631, 1983 Edition providing that the owner has a permit and approval from the Fire Department and a current, legally valid warranty for the relining.

At this juncture, if you are the owner of an UST that is not exempt from this regulation, the UST should have been or should be scheduled to be properly closed in accordance with MassDEP requirements. If not, you still have time to avoid MassDEP enforcement activity.  The MassDEP is granting extensions of the August 2017 deadline until July 1, 2018 to those who:

  • Take the UST out of service by August 7, 2017
  • File a Single-Walled Steel Tank Out-of-Service Notification to MassDEP within 30 days of the out-of-service date
  • Submit to MassDEP no later than August 7, 2017 a fully executed and signed contract for removing or closing the UST(s) on or before July 1, 2018

Remember that as part of the UST closure regulations, an assessment for contamination is required to be conducted upon in-place closure or, for removed USTs, within 24 hours after the UST is removed and prior to excavation backfill. The results of this assessment need to be reported in an UST Closure Report. Although the assessment is not required to be completed by a Licensed Site Professional (LSP), the UST removal contractor must be knowledgeable in the MassDEP release reporting criteria under the Massachusetts Contingency Plan (MCP). In all cases, if a reportable release condition is identified, an LSP must be involved in conducting remedial actions.

CAPACCIO’s EHS-Dashboard™ software solution can help you track regulatory deadlines associated with UST compliance as well as record monthly inspection data so that you can be ready to demonstrate compliance in real time. Please visit http://www.ehsdashboard.com to schedule a demo of our dashboard or contact Chris or Dawn whose contact information is listed below.

CAPACCIO is available to assist you in determining whether this regulation applies to you, assist you in meeting the August 7, 2017 deadline, and/or providing LSP services and assistance in the UST closure assessment process. Please contact Chris Walton, PE, PCEE at 508-970-0033 ext. 139 or cwalton@capaccio.com or Dawn Horter, PG, LSP at 508-970-0033 ext. 118 or dhorter@capaccio.com for additional information.

 

EPA Haz Waste Generator Rule Updates Reply

The Environmental Protection Agency’s (EPA) Resource Conservation and Recovery Act’s (RCRA) hazardous waste generator regulatory program was originally promulgated in 1980. Since that time, the EPA has become aware of the need for more clarity, consistency, and flexibility within the program. EPA’s final rule, which was promulgated on May 30, 2017, revises the hazardous waste generator regulations making them easier to understand, and providing greater flexibility in how hazardous waste is managed.

Some key provisions where EPA is finalizing flexibility are:

  1. Allowing a hazardous waste generator to avoid increased burden of a higher generator status when generating episodic waste provided the episodic waste is properly managed, and
  2. Allowing a very small quantity generator (VSQG) (previously called conditionally exempt small quantity generators) to send its hazardous waste to a large quantity generator under control of the same person.

This program update is also implementing some Improvements to environmental protection and, therefore, several of the revisions to the hazardous waste generator regulations are more stringent than those in the previous version. One such revision requires Small Quantity Generators (SQGs) to periodically re-notify the EPA regarding their generator status every four years (SQGs needed to only notify once under the previous system).

You may Click Here for additional information on the RCRA Program Updates.  Please note that though the Federal regulations are currently in effect, the Massachusetts Department of Environmental Protection (MassDEP) has indicated they will not be adopting these updates until 2018.

We can help! Capaccio has RCRA experts that can assist you with the reporting and planning challenges associated with Federal and state hazardous waste programs.  If you have any questions about these programs and updates, please contact Alexis Dallaportas at 508-970-0033 ext. 142 or adallaportas@capaccio.com.

 

 

New OHS Standard ISO 45001: Progress Towards Finalization Reply

Each year, nearly 2.2 million workers die as a result of an occupational injury or illness. This statistic is burdensome to organizations and society as a whole. To encourage a strong occupational health and safety program, the International Organization for Standardization (ISO) has been working on the development of a new Occupational Health and Safety (OHS) Standard; ISO 45001. This standard aims to provide organizations with the framework to manage the prevention of work related injuries, illnesses, and deaths.

ISO 45001 has been drafted to include many of the same concepts set forth in OHSAS 18001. The main differences between the two standards is that ISO 45001 has a much stronger focus on the context of an organization and requires top management to provide leadership in the development, management, and tracking of their company’s OHS Management System. It is expected that OHSAS 18001 will be withdrawn once the new ISO 45001 standard is published. Organizations certified to OHSAS 18001 will need to transition to ISO 45001 within three years of its publication.

Currently the new OHS Standard is in its second draft. A preview of this version is currently available for review.  For the next four months, the OHS Standard will be undergoing the translation and ballot phase of the review process. If a Final Draft International Standard (FDIS) is not required, the new ISO 45001 standard could be published as early as November 2017. If a FDIS is required, publication could be pushed back to the second quarter of 2018.

For more information please contact Bob King at 508-970-0033 ext. 113 or bking@capaccio.com or Katie Grasso at 508-970-0033 ext. 134 or kgrasso@capaccio.com.

Source Registration and Greenhouse Gas Reporting Update Reply

Recently, many facilities received an email from the Massachusetts Department of Environmental Protection (MassDEP) regarding the upcoming Source Registration (SR) and Greenhouse Gas (GHG) reporting deadlines and requirements. This e-mail states that the MassDEP is suspending the April 15, 2017 deadline for both SR and GHG reporting while they continue to work on combining these two reports into one web based platform.  During this process, the current reporting platforms will not be available.  It is currently not known when the system will be up and reports will be due.  When the reporting platform is ready, the MassDEP will be sending out letters with reporting deadlines to facilities. In the meantime, CAPACCIO recommends that facilities continue to compile their 2016 data and complete required calculations.
Let us know if you need assistance.

If you have any questions, please contact Lynn Sheridan at (508) 970-0033 ext. 122 or lsheridan@capaccio.com.