Hazardous Waste Manifests Are Going Electronic Reply

A hazardous waste manifest is an important set of paper forms that track hazardous waste shipments to their final destination.  As of June 30, 2018, those paper forms will become electronic, and must be entered into the EPA’s e-Manifest system!

The goal for going electronic is to have a more stream-lined, efficient, and automated system. The new electronic system will allow you to create, sign, and track hazardous waste manifests, all through the RCRAInfo system on the EPA’s Central Data Exchange (CDX) platform.  The new system is expected to go live on June 30, 2018.

It is important to note, if you do not already have an EPA identification number, you will need to obtain one and can do so through the RCRAInfo system. Also, for generators located in Massachusetts that currently have a Massachusetts ID number that starts with MV, you will need to obtain a new EPA ID number that is in the Federal format through the system.

There are a number of ways you can accomplish getting manifests into the e-Manifest system.  If you haven’t already become familiar with this new system, CAPACCIO recommends that you work closely with your waste hauler to help get your manifests into the e-Manifest system.

Going forward, the EPA will be imposing fees for manifests submitted which will be dependent upon the form in which they are remitted.  The fees are to recoup the costs of developing, operating, maintaining and upgrading the e-Manifest system, and will be levied as follows:

  • A paper manifest submitted to EPA = $20.00 per manifest
  • A PDF image of a manifest submitted electronically to EPA = $13.00 per manifest
  • A data file and PDF of a manifest submitted together to EPA = $7.00 per manifest
  • A manifest submitted via the EPA e-manifest system = $4.00 per manifest

There is a learning curve for understanding how to set up an account, how to get your electronic signature approval, and so on within the new system.  CAPACCIO can help you through this initial process and also know that your waste hauler is a reliable resource for advice on this as they are going through this process as well.  By contacting and working with them sooner rather than later, you can ensure a smooth transition for both parties as this new e-Manifest system is implemented.

For more information on the new e-Manifest system, you can visit the EPA e-Manifest webpage at: https://www.epa.gov/e-manifest

Or, the MassDEP webpage at https://www.mass.gov/guides/hazardous-waste-generation-generators under “Important News & Updates.”

If you have any questions, please feel free to contact Linda Swift at 978-621-6433 or lswift@capaccio.com, or the MassDEP at 617-292-5898 or baw.edep@state.ma.us.

At CAPACCIO, we live our mission of “Helping Industry and the Environment Prosper”. We align EH&S with your overall business objectives to strategically position you for success.  Our unique approach combines our extensive EH&S experience with cutting edge technologies, such as our EHS DashboardTM, to effectively address your challenges.  Our comprehensive solutions have resulted in award-winning EH&S and overall business performance for our clients.  We are certified WBENC, WBE. To learn more visit us at www.capaccio.com.

MassDEP Announces RY2019 Source Registration Deadlines Reply

The August 2017 proposed modifications to the MassDEP air regulations have been finalized and the air source registration reporting deadlines have been changed!  Going forward for RY2019, the new reporting deadlines are as follows:

  • April 1st
    • Triennial filers
  • May 1st
    • Facilities that are subject to 310 CMR 7.0: Appendix C in the prior year (Operating Permit)
  • June 1st
    • Facilities that have a Restricted Emissions Status (RES)
    • Facilities that had ACTUAL emissions of lead equal to or greater than 0.5 tons, or ACTUAL emissions of NOx or VOC equal to or greater than 25.0 tons in the previous year

In addition, MassDEP has changed the fuel utilization thresholds.  A facility will now be required to file a source registration if its facility-wide maximum energy input from all fuels is equal to or greater than 40 MMBTU/hr.  In addition, if the facility operates an emission unit that combusts natural gas, propane, butane, or distillate oil with a maximum energy input equal to or greater than 10 MMBTU/hr the facility will be required to file a source registration.

Facilities will also be required to file a source registration if their actual emissions in the previous calendar year were equal to or greater than any of the following:

  • Lead:  0.5 tons
  • NOx: 25.0 tons
  • VOC: 25.0 tons

The question remains as to when source registrations will be due this year as the new reporting system and forms are not yet available.  Once the system and forms are up, CAPACCIO will be conducting a webinar to walk through the new forms and answer any questions which may arise regarding the reporting deadlines, which are expected to be released at the same time.

If you have any questions or require assistance, please contact Lynn Sheridan, EIT, at 774-249-2565 or lsheridan@capaccio.com.

 

Just released, CAPACCIO’s 2018 Compliance Calendar! Reply

Capaccio Environmental Engineering, Inc.’s most popular and anticipated download, the annual Compliance Calendar, is here and ready for download! Our free calendar highlights this year’s regulatory deadlines required by the MassDEP, the EPA and OSHA. Each item is explained in detail for better understanding of what the requirement might entail.
In addition to these requirements, there are also pages which outline non-date specific requirements which occur throughout the year including:
* Initial training and annual or periodic retraining or refresher training required by
   OSHA or other regulatory agencies for affected employees
* Inspections, testing, monitoring, and/or certification of equipment and systems
* Payment of compliance assurance, renewal, or usage fees
* Permit, certificate, and license renewals
* Internal or external program audits and reviews
* Documentation and recordkeeping
There are two options of downloads: an Adobe pdf version which includes the compliance calendar front page with the regulatory dates circled as well as the backup information pages. An additional version of the calendar, compatible with Microsoft Outlook, is also available for download.
For more information on any of the technical information contained in the calendar, please contact Linda Swift at 508-970-0033 ext. 119, by cell at 978-621-6433, or email at lswift@capaccio.com. For sales, please contact Lucy Servidio at 508-970-0033 ext. 114, by cell at 508-380-9217, or email at lservidio@capaccio.com.

Changes to the Hazardous Waste Biennial Report Reply

Large Quantity Generators are required to report hazardous waste (HW) activity by March 1st of each even numbered year (every two years) for the preceding calendar year.  Reports are to be sent to the facility’s state authority (in Massachusetts, MassDEP).

Previously, there was an independent software used to prepare these reports. This year (reports to be submitted in March 2018) HW Biennial Reports have to be prepared and submitted using the EPA RCRAInfo Industry Application (RIA) software.

Here’s what’s new:

    • The Biennial Reporting software is a part of the EPA RCRAInfo Industry Application (RIA) which is also a part of the EPA CDX system – so everyone who prepares and submits a HW biennial report needs a CDX account and to register in the RIA system.
    • MassDEP noted to be sure you understand that there are a number of roles for RIA and whoever signs up as the Site Management Role will have control not only of the HW Biennial Report roles and content but also any roles related to the eManifest (expected this summer), and Generator Notification form (expected in the near future), etc.  (Basically anyone with a waste role on CDX related to the client’s facility). So CAPACCIO is advising clients to be careful who they assign to that role.  Once roles are assigned, you need to make sure that those people have CDX accounts.  If they don’t have accounts, one of the first things you need to do is set a up CDX account and then register on RCRAInfo. 
Having trouble submitting your Hazardous Waste Biennial Report?
  • That’s because EPA has not loaded the SI form template (form with your site information) into the RCRAInfo Biennial Report site and you cannot submit the report without completing an SI form.  The form will likely be available in mid-January.
If you have questions regarding the Hazardous Waste Biennial report, contact Linda Swift at lswift@capaccio.com or Alexis Dallaportas at adallaportas@capaccio.com.