New Regulatory Vapor Intrusion Guidance Reply

ThroughoutMassachusetts, releases of materials containing volatile organic compounds (e.g., petroleum products, dry cleaning fluids, industrial solvents) have impacted soil and/or groundwater.  When these releases occur near buildings, volatilization of contaminants in the subsurface can result in the intrusion of vapor-phase contaminants into indoor air spaces and can pose a risk to workers and other building occupants.

In June 2010, the American Society for Testing and Materials (ASTM) updated its Standard Practice for Assessment of Vapor Intrusion into Structures on Property Involved in Real Estate Transactions (E2600-10).  This guide defines a procedure to identify, during a Phase I property assessment, whether a vapor intrusion condition exists, likely exists, cannot be ruled out, or can be ruled out because a vapor intrusion condition does not or is not likely to exist.

In response to the regulated community’s questions and concerns, in December 2010, the Massachusetts Department of Environmental Protection (MassDEP) issued an Interim Draft Vapor Intrusion Guidance document to provide regulatory guidance on assessing and mitigating vapor intrusion pathways at sites regulated by the Massachusetts Contingency Plan (MCP). This document addresses approaches to the assessment and remediation of vapor intrusion in order to maintain compliance and eventual site closure within the MCP.

Both the ASTM guide and the MassDEP guidance documents can be applied to property with existing structures, property with structures that will be substantially rehabilitated, property without existing structures but having planned structures (e.g.,, property in development), or property without existing structures and with no planned structures (e.g.,, undeveloped property with no planned development).

Following receipt of public comments, due by March 1, 2011, the MassDEP will finalize the Vapor Intrusion Guidance document.  If you have a concern about the potential for your existing or planned property to have a vapor intrusion impact, call Dawn Horter at 508.970.0033 ext. 118.

Guidance on Spill Prevention Control and Countermeasure (SPCC) Plans Reply

There’s a hole in my bucket, dear Liza, dear Liza,
There’s a hole in my bucket, dear Liza, a hole.
Then fix it, dear Henry, dear Henry, dear Henry…

Well you can look up the rest of the poem, but what if that bucket is a tank and it’s leaking oil…now what do you do?  Hopefully, this won’t happen to you, as it did in Dorchester, Massachusetts recently, but you may be asking yourself a few questions right now:

  • Is there something I should be doing to prevent a leak?
  • Is there a plan I should have in the event of a leak?
  • What should I do if my tank is actually leaking?

CAPACCIO can help you answer these questions.  Our staff of engineers has prepared numerous Spill Prevention Control and Countermeasure (SPCC) Plans which are required for sites with over 1,320 gallons of aboveground oil storage. For smaller facilities, we can conduct inspections of oil storage tanks to determine their risk of failure.  In the unfortunate event of a spill, our on-call Licensed Site Professional (LSP) is available 24/7 to answer your questions and assist with reporting and clean-up requirements.   

If you would like more information on SPCC Plans and whether your facility is required to have one, click here. For general information regarding SPCC Plans and tank inspections call Josh Fawson at 508.970.0033 ext. 120.  For LSP services, call Dawn Horter at 508.970.0033 ext. 118.

ISO 26000:2010 (Social Responsibility Guidance) Released Reply

The ISO 26000:2010 social responsibility guidelines have been finalized and published.  It is now possible to add social responsibility “core subjects” from these new guidelines to an ISO 14001:2004 or ISO 9001:2008 program.  This would create an integrated sustainability management system. The ISO 26000:2010 guidelines cannot be used alone as a sustainability management system.

CAPACCIO thinks ISO 26000:2010 will facilitate the development of effective sustainability programs since it clearly articulates a wide range of social responsibility issues that sustainable companies need to watch closely; e.g., community involvement, human rights, labor issues, and consumer/customer issues.  Incorporating conformance to social issues within a management system will help coordinate those who manage the environmental responsibilities with those that manage the social responsibilities.

A recent survey (found here) found that 86% of employees are not engaged by their employers on sustainability even though the same amount – 86% – said that their organization promotes employee sustainability.  It is possible to engage employees more effectively using a management system rather than relying only on training and awareness.  A properly implemented management system can make sustainability part of what every employee does every day by including it in the work instructions and every aspect of their involvement with the organization.  CAPACCIO is already seeing this make a difference with our clients that are integrating their sustainability efforts directly with their management system efforts.  The new ISO 26000:2010 standard will make this effort easier and more effective.

CAPACCIO is preparing a “white paper” on how to use ISO 26000:2010 with your management systems.  Please reserve a copy by contacting Bob Pojasek at rpojasek@capaccio.com or calling him at 508-970-0033 extension 137.

Energy Management System Standards Reply

For those of you who are still eagerly awaiting the release of  the ISO 50001 energy management system standard (due to be released early next year), there is a British Standard, BS EN 16001, that can be used now.  This British energy management system standard has been a key priority for European delegates contributing to the development of the ISO standard in the much slower international standards setting arena.  These delegates are working closely with ISO to make sure there will be no disincentive for the early adopters of EN 16001 when ISO 50001 is released.  The use of this standard is also providing some information to those writing the ISO 50001 standard. 

The aim of this European standard is to help organizations establish the systems and processes necessary to improve energy performance and make reductions in both cost and emissions of greenhouse gases.  Launched in July 2009, this standard effectively presents a business with a roadmap of the various steps to be taken to ensure it is viewed as being serious about energy management.  The promotion of the standard notes that the combination of energy reduction and risk management is more financially advantageous than merely buying additional carbon credits or offsets to lower the carbon emissions that are reported to the public. 

The standard helps businesses ask the right questions of themselves and adjust their internal processes and decision-making accordingly.  These businesses use the plan-do-check-act (PDCA) framework to establish objectives and processes, implement some changes, monitor their results and finally act again to deliver incremental improvements in performance over time.  Some companies in the UK are required to certify to this standard because of the “Carbon Reduction Commitment Energy Efficiency Scheme” that was launched in April 2010 to support attempts to reduce the greenhouse gas emissions in accordance with the Climate Change Act of 2008.  There are similar requirements in the European Union.

To keep up to the demand in the United States, the US Department of Energy is making draft copies of ISO 50001 available to certain technical assistance providers to use for their own energy conservation programs.  However, no climate change legislation has been enacted in the United States.  A company can purchase a draft of ISO 50001 and use it while the final standard is being subject to its final international ballot.  You do not need to be involved in these Department of Energy projects to do so.

It is important to note that the “aspects” determination in ISO 14001 was designed for looking at all resources:  water, energy and materials.  Energy is very important to all companies and their stakeholders.  Unless you find that you need to certify to an energy management standard, you may be better off looking at both the BS EN 16001 and the draft ISO 50001 and using the information to strengthen your existing ISO 14001 program.