MassDEP Sewer Connection Permit Renewals Reply

The Massachusetts Department of Environmental Protection (MassDEP) promulgated new sewer system extension and connection regulations (314 CMR 7.00) in 2007.  These regulations required industrial facilities with wastewater discharges above certain thresholds to apply for a permit, submit a self-certification, or be considered “Permit by Rule” which does not require a submittal. The following thresholds determine what actions must be taken:

  • You discharge to an EPA approved industrial pretreatment program (IPP) and your combined discharge (industrial and sanitary) is greater than 50,000 gallons per day (gpd) – Apply for Permit
  • You discharge to an EPA approved IPP and your combined discharge (industrial and sanitary) is less than 50,000 gpd – Permit by Rule
  • You discharge to a non approved IPP and your combined discharge (industrial and sanitary) is greater than 25,000 gpd – Apply for Permit
  • You discharge to a non approved IPP and your combined discharge (industrial and sanitary) is less than 25,000 gpd – Submit a Compliance Certification

Both the permit and the self-certification are valid for 5 years.  With the majority of the final permits and certifications being issued and approved in early 2008 many industries will be required to renew their permits or certifications towards the end of this year.

The permit renewal process is the same as the process completed to obtain the original permit. Permit renewal applications (BWP IW 38 or 39) must be submitted 90 days prior to the expiration of the existing permit and companies will again be required to complete the public notification process. Self-certifications must be submitted before the existing certification expires and do not require any public notification.

If you have any questions about the MassDEP Sewer Connection regulations or the renewal process contact Bill Potochniak at wpotochniak@capaccio.com or 508.970.0033 ext. 134.

Massachusetts UST Operator Certification Exams Now Available Online Reply

By August 8, 2012, each underground storage tank (UST) system operated in the Commonwealth of Massachusetts must have at least one MassDEP- certified Class A, B and C Operator.

UST Operator certification exams are now available online and you must pass to qualify as a Class A, B or A/B UST Operator (there is no exam required to qualify for Class C Operator certification).

The exam, as well as links to reference materials which can be referenced while taking the exam (i.e. open book examination), are available at the MassDEP website. The fee to take the exam is $75.

For access to the exam and additional information, please visit: http://www.mass.gov/dep/toxics/ust/operator.htm

Questions?  Contact Christopher Walton at 508.970.0033 ext. 139 or cwalton@capaccio.com.

Changes to Aboveground Storage Tank Annual Inspection Program Reply

The Commonwealth of Massachusetts’ Office of the State Fire Marshal (OSFM) recently announced some proposed changes to the program for annual inspections of aboveground storage tanks (ASTs) greater than 10,000 gallons containing fluids other than water (502 CMR 5). The changes are part of the Commonwealth’s effort to move to electronic permitting and licensing programs.

In one significant change to the program, OSFM will be mailing renewal notices three months prior to the expiration date of each AST use permit to the person in charge of the tanks. These renewal notices must be submitted along with the completed inspection forms, so remember to give them to the inspector. In another program change, the completed inspection forms must now be submitted to the OSFM at least 30 days prior to the use permit expiration date. These and other changes are designed to streamline the inspection process prior to the move to electronic filing.

Finally, remember the OSFM considers tanks containing any fluid (including gases, such as propane or nitrogen) subject to the annual inspection program.

If you have any questions about the Commonwealth’s program for annual inspection of ASTs, please contact Christopher Walton at cwalton@capaccio.com or 508.970.0033 ext. 139.

Oh Snow, Where Art Thou? SPCC Winter Update Reply

While the local cross country ski enthusiasts and snowshoers may be a little disappointed at the lack of white stuff this year, I’ll bet the majority of us are wiping our brows in relief.  As I type, I can see the sun’s rays bouncing off the cars in the parking lot giving a glimmer of hope that spring is soon on its way.  But, being a New Englander all my life, I know that winter is likely to rear its ugly head a few times before we see the crocuses make their first appearance. 

During these winter storms, the top priority should be getting walkways and parking areas clean to ensure the safety of employees and visitors. This often puts other important areas like secondary containment for oil tanks at the back of the list, but, in accordance with the Oil Spill Prevention Control and Countermeasures (SPCC) regulations (40 CFR 112), structures used for secondary containment of oil must be kept clean and free of debris including snow and ice.  On several occasions, we have inspected secondary containment structures only to find them full of ice and snow. To prevent this from happening at your facility, secondary containment areas should be cleaned of snow before it has the chance to ice up and become a “drain freeze” during an oil spill.

For more information on SPCC Plans and SPCC compliance, contact Josh Fawson at 508-970-0033 ext. 120 or jfawson@capaccio.com.