Risk Management Program (RMP) Inspection Checklists Reply

Below, please find links to the United States Environmental Protection Agency’s (US EPA’s) RMP Program Level 2 and RMP Program Level 3 Inspection Checklists.

 

http://www.capaccio.com/assets/handouts/events/ModifiedRMP Program Level 2 Process Checklist.pdf

http://www.capaccio.com/assets/handouts/events/ModfiiedRMP Program Level 3 Process Checklist.pdf

Facilities that are covered by the RMP regulations are required to implement an RMP and submit a description of the program to EPA. Additionally, RMP audits covering the items in these checklists are required every three years.

For more information or assistance with your RMP program, please contact Christine Silverman at csilverman@capaccio.com or by calling 508-970-0033 ext. 127.

TRI and TURA—what’s new for RY 2015 Reply

There are several updates to US Environmental Protection Agency’s (US EPA) Toxic Release Inventory (TRI), also known as Emergency Planning and Community Right to Know Act (EPCRA) Section 313 and the Massachusetts Department of Environmental Protection’s (MassDEP) Toxics Use Reduction Act (TURA), both reports due July 1, 2016.

TRI updates:

New Reportable Chemicals – the Nonylphenol category has been added to the TRI list of reportable chemicals. If chemical thresholds are met, reporting forms for nonylphenol are due on the reporting deadline of July 1, 2016. Nonylphenol is highly toxic to aquatic organisms and has been found in natural waters. Nonylphenol is used in a variety of industrial applications and consumer products like detergents, emulsifiers, wetting agents, and defoaming agents. This chemical category includes the following chemicals:

4-Nonylphenol – CAS 104–40–5

Isononylphenol – CAS 11066–49–2

Nonylphenol – CAS 25154–52–3

4-Isononylphenol – CAS 26543–97–5

4-Nonylphenol, branched – CAS 84852–15–3

Nonylphenol, branched – CAS 90481–04–2

Publically Owned Treatment Works (POTW) improved search function – TRI-MEweb provides users the ability to search and add close proximity POTWs using a map-based interface, located in Section 6.1 of the reporting forms. The search criterion has been expanded to include and National Pollutant Discharge Elimination System (NPDES) IDs.

Withdrawal Comment Option – TRI-MEweb now provides the option to enter a comment when withdrawing a Reporting Form R, once a withdrawal reason code has been selected. This comment is located in Section 9.1 of the reporting form.  Facilities may request a withdrawal for one or several reasons, such as:

  • WT1 – Did not meet the reporting threshold for manufacturing, processing, or otherwise use
  • WT2 – Did not meet the reporting threshold for number of employees
  • WT3 – Not in a covered NAICS Code
  • WO1 – Other reason(s)

Multi-Part Reporting and Facility Management – TRI-MEweb in 2015 automatically creates parts for your facility, if your facility reported as a multi-part in the previous reporting year. It is also easier to manage you facility’s information by having the option to create, edit or delete facility information right from the My List of Facilities page.

TURA Updates:

NEW FORMS! The eDEP system is moving to a new easier-to-use web based forms that will be available in April. MassDEP will be releasing guidance on using the new forms, once they are available. Because of the new eDEP system, it is important to attend the TURA/TRI workshops. This year’s TURA/TRI workshops:

  • Thursday May 5, 2016… ATMC Conference Center, 151 Martine Drive, Fall River
  • Tuesday May 10, 2016… North Central Massachusetts Chamber of Commerce, 860 South Street, Fitchburg
  • Thursday May 26, 2016…  Mass. Mutual Ins. Learning & Training Center, 350 Memorial Drive, Chicopee
  • Thursday June 2, 2016… Parker River Wildlife Refuge, Headquarters Building, 6 Plum Island Turnpike, Newburyport

New Reportable Chemical – the Nonylphenol category has been added to the TRI list of reportable chemicals and thus, if reportable under TURA. If chemical thresholds are met, reporting forms for nonylphenol are due on the reporting deadline of July 1, 2016. See the TRI updates section above and here, https://www.epa.gov/toxics-release-inventory-tri-program/addition-nonylphenol-category for more information.

Start your tracking now – The following chemicals have been designated as higher hazard substances, effective calendar year 2016, for reports due July 1, 2017. The reporting threshold will be 1,000 pounds for any of the reporting categories including otherwise use, processed and manufactured. Therefore, it is important to begin tracking use, beginning in 2016 for filing your 2016 TURA report, due July 1, 2017:

  • n-Propyl Bromide (nPB), (1-Bromopropane) – CAS 106-94-5
  • Hydrogen fluoride – CAS 7664-39-3
  • Cyanide compounds – MassDEP Code 1016
  • Dimethylformamide (DMF) – CAS 68-12-2

Reporting under the Amnesty Policy– Applies to companies that are subject to the reporting and planning requirements of TURA that are not aware of the requirements, or those companies that have been reporting under TURA, but have unintentionally missed one or more  reportable chemicals. MassDEP is holding enforcement amnesty through June 30, 2016, which allows for companies to voluntary disclose past failure to file one or more TURA reports. During amnesty, companies must voluntarily report one or more previously owed TURA report(s) not earlier than calendar year 2011, and will be required to pay one year of past owed chemical use and administrative late fees. Companies who will be reporting for the first time under the Amnesty Policy will be required to prepare TUR plans and submit plan summaries/plan certifications by July 1, 2018.

If you require assistance, or for more information, please contact Chelsea Regan at cregan@capaccio.com.

 

SPCC Compliance Update – Integrity Testing of Aboveground Storage Tanks Reply

In accordance with the US Environmental Protection Agency (US EPA) Oil Spill Prevention regulations found at 40 CFR 112.8(c) owners and operators subject to the Spill Prevention, Control, and Countermeasure (SPCC) rule are required to test or inspect each aboveground container for integrity on a regular schedule. Examples of these integrity tests include, but are not limited to: visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of non-destructive testing.

The type of inspection to be performed is generally determined by the registered Professional Engineer certifying the SPCC Plan. Many SPCC plans reference the Steel Tank Institute Standard for Inspection of Aboveground Storage Tanks (SP001) as the accepted industry standard that the tanks will be inspected against. SP001 stipulates the recommended inspection frequency for various tank configurations.

While SP001 allows qualified facility personnel to perform the inspections and this is appropriate for monthly visual checks of the tank integrity, CAPACCIO recommends that tanks be inspected by a certified STI inspector at least once per year. A certified STI inspector will often uncover issues of non-compliance that are missed by facility personnel.

If you need assistance with AST integrity testing or SPCC compliance, or have general questions, please contact Jeff Briggs, certified STI inspector, at jbriggs@capaccio.com or 508-970-0033 ext.  120.

Reminder – Source Registration Deadlines Approaching Reply

Just a reminder that deadlines for air source registration filing are fast approaching. Prevent last minute scrambling and begin to assemble your air permits and approvals, fuel usage data, and hours of operation for fuel combustion equipment.

Each owner/operator of a facility required to file this year should have been informed of their filing schedule via a letter from the Massachusetts Department of Environmental Protection (MassDEP). If you did not receive a letter, the MassDEP has posted a list of filers with their due dates which can be found at the link below:

http://www.mass.gov/eea/agencies/massdep/service/online/filing-schedules-and-deadlines.html

The due dates for this year are listed below.

  • April 15 – Operating Permit facilities due
  • May 16 – Non-OP annual filers due
  • June 1 – Deadline for a portion of the facilities filing every 3 years (see List of All Facilities for facility-specific deadlines)
  • July 15 – Deadline for a portion of facilities filing every 3 years (see List of All Facilities for facility-specific deadlines)

NOTE:  If you were an Operating Permit facility during any portion of 2015, you will need to file a 2015 Source Registration, even if your classification changed or the facility closed.

EXCEPTIONS: Please note that some air permits require the facility to file annually.  If this is the case, then your facility is required to file by May 16, regardless of what the MassDEP list states.

Based on your current level of record keeping and available data, a peer review of your filing, or assistance with the MassDEP online filing system (eDEP) may be all you need. If interested, we would be happy to discuss where you are in the process and what is needed to ensure your deadlines are met.  For more information, please contact Linda Swift at 508-970-0033 ext. 119 or lswift@capaccio.com.