August 7, 2017 – UST Deadline Reply

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 cwalton@capaccio.com or Dawn Horter, PG, LSP at 508-970-0033 ext. 118 or dhorter@capaccio.com for additional information.

 

Why your wastewater treatment system may need a check-up Reply

Industrial wastewater treatment systems serve a key purpose by treating pollutants not capable of being handled by the local municipal treatment system. This helps to reduce pollution and cost to taxpayers to operate and maintain municipal collection and treatment systems.

Why would your wastewater treatment system need an Annual Checkup?

When you receive an annual physical, the doctor checks you for basic vitals…heart rate, blood pressure, body temperature, height and weight. A typical wastewater treatment system audit will perform the same function, ensuring that:

  • Permits are current
  • Facility is complying with the key portion of the permit
    • Sampling has been performed
    • Reports have been submitted
  • Regulations are met
    • 257 CMR 2 – Wastewater Grading/Staffing/Operator Certifications
    • 314 CMR 7 – Sewer System Extension and Connection (Permits)
    • 314 CMR 12 – Operation and Maintenance of the IWPS
    • 360 CMR 10 – MWRA Specific Requirements (if applicable)
    • Local regulations
  • System functioning as expected
    • Have alarms been triggered? If so, how frequently?
    • Have there been any discharge violations? Were they reported?

Provided there are not any obvious issues, the doctor (or the auditor) will generally give you the okay and send you on your way. But what happens when the issues are not so clear?  What happens when you complain of some neck and back pain?  Well, you get sent to a specialist where they perform more testing and review more specific symptoms.  The same can be true for a focused review of your industrial wastewater treatment system and programs…take it a step or two beyond the typical audit.

A more effective audit/review should include evaluating the treatment system periodically.

Many treatment systems are designed, installed, and rarely revisited during the lifespan of a facility. This can lead to a variety of lingering problems.  You can treat the symptoms (adjusting the existing treatment system) or you can rid yourself of the disease by addressing the problem causing those symptoms (updating the system itself).  Some problematic areas to review include:

  • Process changes affecting the system’s treatment ability
  • Out-dated controls
  • Alarm notifications when operator is not nearby
  • Lack of secondary containment around chemical addition equipment
  • Limited automation of the system– increasing operator difficulty
  • Manual log maintenance by the operator

Performing an engineering evaluation of your treatment system and identifying/prioritizing areas for improvement can help increase the ease of operation of the system, increase safety to the operators, proactively provide flexibility for future process/manufacturing expansions and improve compliance of the system. Consider the cost in lost production, if the wastewater treatment function was no longer operating.

Just like you need to take care of yourself with an annual check-up, your wastewater treatment system also needs TLC to keep it functioning properly.

As part of our 25th Anniversary, CAPACCIO is offering a free one-hour industrial wastewater treatment system review to ensure it is still performing as it should. These evaluations also provide TCHs for your operators.

To schedule your free evaluation, please contact Matt Melvin, PE, at mmelvin@capaccio.com or 508-970-0033 ext. 143.

Additionally, 2017 is also a TCH renewal year for wastewater treatment operators. Please visit our website at http://www.capaccio.com/services/training/wwt_index.html or contact Matt if you would like to enroll in any of our courses or obtain your TCHs through the free evaluation.

 

Source Registration and Greenhouse Gas Reporting Update Reply

Recently, many facilities received an email from the Massachusetts Department of Environmental Protection (MassDEP) regarding the upcoming Source Registration (SR) and Greenhouse Gas (GHG) reporting deadlines and requirements. This e-mail states that the MassDEP is suspending the April 15, 2017 deadline for both SR and GHG reporting while they continue to work on combining these two reports into one web based platform.  During this process, the current reporting platforms will not be available.  It is currently not known when the system will be up and reports will be due.  When the reporting platform is ready, the MassDEP will be sending out letters with reporting deadlines to facilities. In the meantime, CAPACCIO recommends that facilities continue to compile their 2016 data and complete required calculations.
Let us know if you need assistance.

If you have any questions, please contact Lynn Sheridan at (508) 970-0033 ext. 122 or lsheridan@capaccio.com.

Special Offer – FREE One hour of wastewater optimization and One TCH per operator! Reply

For a limited time, CAPACCIO is offering a free one-hour consultation combined with wastewater treatment plant operator training. We will meet with you and your operators at your facility to review your existing wastewater treatment operations and develop ideas for system optimization or improvement.

At the conclusion of the consultation, CAPACCIO is authorized by MassDEP to issue Training Contact Hours (TCHs) to each attendee. A win-win as you receive a professional engineer’s review of your system as well as a TCH credit. There is no obligation to engage in any services with CAPACCIO at the conclusion of the consultation.

For more information, please contact Matt Melvin, PE, at 508-970-0033 ext. 143 or mmelvin@capaccio.com.