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.
- 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.
In our continuing series about auditing and how it can be similar to an annual physical, we will discuss an often overlooked area; a deep dive into air permitting. Just as an annual physical may gloss over some of the more specific parts of the body, air permits can also sometimes be overlooked but doing so can lead to a potential problem in the long run.
Every year, the Doctor asks a list of questions, such as, “Has anything changed in your immediate family’s health (diagnosed with diabetes, heart disease, ADHD)? Who lives at your home? Do you have any pets? Do you have any concerns at the moment? In a similar fashion, prior to an air audit, the auditor will send you a list of questions. Do you have an air plan approval? Do you have air emissions tracking sheets? Do you have a control device? All of these questions help the Doctor/Auditor get an overview of your health/facility and any specific areas that may be of concern.
Your responses become the roadmap for the auditor. If you stated you do not have an air plan approval, the auditor may request a listing of how much solvents are used onsite to determine if the facility needs to further evaluate/justify whether a plan approval is needed or if there is an exemption that excludes a facility from obtaining an air plan approval. The auditor will check if you are maintaining documentation that states how you are complying with the regulation or why your facility meets the listed criteria exemption.
As with your annual checkup, the more symptoms/details you can provide to the Doctor increases their ability to provide you with advice on what you need to do to maintain a healthy lifestyle. Are there warning signs that you may not have noticed with your air permits?
- Your volatile organic compound (VOC) emissions from a small process is approaching permitting level
- The state updated their Regulated Toxic Air Pollutant (RTAP) list and you missed the notice
- EPA has finalized a regulation that applies to you
- An emergency generator was installed at your facility and was not self-certified
- Emission statements were not submitted
These are some of the most common findings found during an air audit. What happens if you don’t see the warning signs or you ignore them for too long? The small warning signs can compound each other to create one larger issue. Just like your health, it is good to go through the annual checkup to help catch the small warnings before it becomes a larger issue and is too late to be fixed.
Just like there are apps to track your health on your phone, computer, or other electronic device, CAPACCIO’s EHS DashboardTM can help you track your facility’s data making an audit by the state or federal inspectors that much easier. Learn more about the dashboard at www.ehsdashboard.com.
For more information on air permits or other air compliance related questions, please contact Lynn Sheridan, EIT, at 508-970-0033 ext. 122 or by cell at 774-249-2565 or email firstname.lastname@example.org.
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 email@example.com or Dawn Horter, PG, LSP at 508-970-0033 ext. 118 or firstname.lastname@example.org for additional information.