MassDEP Releases Interim Guidance on Management of Evaporator Systems Reply

The Massachusetts Department of Environmental Protection (MassDEP) recently published interim guidance for operators of evaporator units that employ a tank or tank system that is used to reduce the volume of (i.e. ,treat ) hazardous industrial wastewater by heating it until it evaporates.

“Evaporator systems,” as used in the interim guidance, are systems that include a wastewater treatment unit (WWTU), an evaporator unit, and all piping ancillary to operation of that system. These systems treat the influent hazardous wastewater to render it non-hazardous, and then evaporate the non-hazardous wastewater in an evaporator unit.

The interim guidance does not apply to:

  • Systems that evaporate only non-hazardous wastewater (generated off-site or on-site)
  • Units that separate non-hazardous wastewater from oil at the site of generation (310 CMR 20.252(4)
  • Units that evaporate non-hazardous wastewater transferred from an elementary neutralization unit at the site of generation (310 CMR 30.1103)
  • Closed –loop vacuum evaporators  that have no air emissions (these are exempt from 310 CMR 30.000)
  • Evaporator systems treating hazardous wastes received from off-site. These require a MassDEP HW facility license (310 CMR 30.801)
  • Sludge dryers associated with WWT systems approved by MassDEP (314 CMR 12.00)
  • Containers or treatment units (other than evaporator systems) subject to MGL 21C and 310 CMR 30.000

Evaporator systems may be exempt from licensing requirements for hazardous waste treatment provided they meet the definition of “treatment which is an integral part of the manufacturing process”. The interim guidelines provide clarification of what is required to maintain the exemption and are intended to give industry an opportunity to evaluate their systems and make necessary adjustments prior to promulgation of the new regulations (anticipated in 2012).

To qualify for the exemption, evaporator systems must:

  • Include a WWTU that is directly connected via permanent piping to the evaporator unit
  • Receive and treat wastewater in the WWTU containing only hazardous constituents in dissolved form (i.e., no multi-phase liquid hazardous waste)
  • Receive and treat wastewaters directly from their dedicated WWTU only
  • Treat the hazardous industrial wastewater in the WWTU so that it is rendered non-hazardous BEFORE it is evaporated
  • Prevent air emissions of hazardous constituents from both the untreated hazardous wastewater and the treated non-hazardous wastewater to the maximum extent practical

In certain cases, operators of evaporator systems that do not meet these requirements may need to obtain a waiver from MassDEP. Here’s the link to the Interim Guidance on Management of Evaporator Systems fact sheet: http://www.mass.gov/dep/recycle/laws/evapguid.pdf

If you have any questions, please contact Lucy Servidio at 508.970.0033 ext. 114 or lservidio@capaccio.com.

TURA 2009 Information Release Reply

Please be advised, the TURA 2009 Information Release is now available on line at the following site:

 http://www.mass.gov/dep/toxics/tura/turadata.htm

The data show that even after accounting for changes in production levels,Massachusetts is continuing to make progress in Toxics Use Reduction!

Please remember that the final step in TURA filing is submitting your payment to the Massachusetts Department of Environmental Protection (MassDEP).  Toxics Use Fees are due to MassDEP by September 1st.  This is different from the information on the Toxics Use Fee Worksheet.  No bills will be sent out this year.  If payment is not received by September 1st , a bill will be send out with a $1,000 late fee. For more information please contact Travis Wheeler at 508.970.0033 ext. 115 or twheeler@capaccio.com.

“RoHS Recast” New Directive Reply

On July 1st 2011, an updated version of the Restriction of Hazardous Substances (RoHS) Directive was published in the Official Journal of the European Union.  EU member states have 18 months to enact the new directive into local law.  DIRECTIVE 2011/65/EU termed the “RoHS Recast” has a number of changes that could affect manufacturing in the United States.  The most impactful change is that the updated version of RoHS now includes electrical and electronic equipment (EEE) that was previously outside the scope of the directive.  The RoHS Directive will now include Medical Devices and Monitoring and Control Instruments. 

Manufacturers of these types of EEE will have 3 years to come into compliance with the changes to the directive.   The RoHS recast will also require manufacturers to draw up a declaration of conformity and affix the CE mark to their products in order to demonstrate compliance.  There has also been a number of changes regarding exemptions.  There is now a process for applying for an exemption to the directive.  All exemptions will expire and the manufacturer will need to reapply for the exemptions 18 months prior to expiration. 

The recast did not add additional substances to the banned list, although the recast requires a review of the substances within three years.  The current banned substances are; Lead, Mercury, Cadmium, Hexavalent Chromium, Polybrominated Biphenyls, and Polybrominated Diphenyl Ethers.  It is important for companies to start thinking about how these changes are going affect the importation of EEE into the EU.  Companies will also need to be able to demonstrate that they are in compliance with the directive at the member state level. If you have any questions about the RoHS Recast please contact Travis Wheeler at 508.970.0033 ext. 115 or twheeler@capaccio.com.

 

U.S. Environmental Protection Agency Greenhouse Gas Reporting Deadline Approaching Reply

The Mandatory Reporting of Greenhouse Gases Rule (40 CFR Part 98) requires reporting of greenhouse gas (GHG) data and other relevant information from large emission sources across a range of industry sectors, and from suppliers of materials whose products emit GHGs if released or combusted. In general, if your facility emits 25,000 metric tons or more per year of GHGs, you may be required to submit annual reports to the U.S. Environmental Protection Agency (EPA).

If you have determined your facility is required to report calendar year 2010 greenhouse gas (GHG) emissions to the EPA, then you should make note of the following dates: 

  • August 1, 2011: Certificate of representation must submitted to the EPA for the facility’s designated representative (i.e., 60 days before the deadline for report submission)
  • August 1, 2011: Reporters must be registered to use EPA’s electronic greenhouse gas reporting tool (e-GGRT)
  • September 30, 2011: GHG reports must be entered on e-GRRT and submitted to EPA

If you have any questions about whether your facility is required to report or need assistance with compiling or reporting your data, please contact Lynn Sheridan at 508.970.0033 x122 or lsheridan@capaccio.com.