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.

ISO 50001 Standard Published Reply

You can now manage your energy conservation program or lower your greenhouse gas emissions by using a new international standard, ISO 50001.  This new ISO Management System Standard for Energy has all of the same “plan-do-check-act” provisions of the ISO 14001 Environmental Management System. 

To save on the cost required to implement and certify a new management system, some companies are choosing to instead integrate the key energy management features of the ISO 50001 standard into their existing ISO 14001 or ISO 9001 management systems. Also, if a customer is not requiring certification to this standard, companies can use the integration option to achieve certification to ISO 14001 while seeking “verification” of the use of the energy management components.  It is also possible to self-certify to the ISO 50001 standard through this integration option. 

Should you choose to implement or integrate the new ISO 50001 Energy Management System Standard, CAPACCIO can help you make decisions on the options you have regarding the use of this new international energy management standard and guide you through the process.

For more information, contact Wayne Bates at 508.970-0033 ext. 121 or wbates@capaccio.com.

First Aid and CPR WWT Operator TCH Credits Reply

CAPACCIO has had a few inquiries from our clients asking if First Aid Classes and CPR classes can be used toward the 20 Training Contact Hours (TCH’s) that WWT operators are required to obtain in order to maintain their licenses.  We spoke with the MassDEP who confirmed that they are approved. When operators submit their license renewal forms, they are to include a copy of the card (both sides) issued to them upon completion. First Aid Courses (regardless of actual length in hours) are approved for 3 TCH’s, similarly, CPR courses are also worth 3 TCH’s.  Some companies are now offering combined classes where First Aid and CPR are covered in the same course and the participants are issued one certification card for both.  If the class is combined the operators can only obtain 3 TCH’s and not 6 as they would if they were to take the classes separately. If you have any questions, contact Josh Fawson at 508-970-0033 ext. 120 or jfawson@capaccio.com.

 

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.