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.
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 email@example.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.