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.

2012 Compliance Calendar Updated Reply

CAPACCIO provides a free annual compliance calendar to highlight the year’s deadlines for meeting regulatory requirements required by the MassDEP, the EPA and OSHA. Each item is explained in full detail and provides backup information to better understand what the requirement might entail.

The calendar was updated in February with the following changes:

  • Carbon Disclosure Project
    Three new reporting dates have been added to the compliance calendar. These dates are for the Carbon Disclosure Project’s (CDP) carbon, water, and supply chain reporting. If your company participates in the CDP, you may want to re-download the calendar to have these dates on your calendar.
  • Massachusetts Mandatory Greenhouse Gas Reporting
    The language related to Massachusetts Mandatory Greenhouse Gas Reporting has been modified. The original language stated that “If reporting year 2012 CO2e emissions were 10,000 pounds or greater, then reporting year 2011 emissions must be verified by December 31, 2012.” We have changed this language to: “If reporting year 2012 CO2e emissions were greater than 10,000 tons, then reporting year 2011 emissions must be verified by December 31, 2012.” Please re-download the calendar to capture this change or make a note of it.

CAPACCIO’s comprehensive compliance calendar is available in a Adobe PDF format which includes brief summaries of the various health and safety requirements mandated by OSHA in their General Industry Standards and any corresponding timelines. Or in a Microsoft Outlook (PST) format that can be imported into your existing Outlook calendar.

Download the Calendar Today:
http://www.capaccio.com/Resources/DLoads/AnnCal/dload_anncal.html

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.

MassDEP News – Important Time Sensitive Notice/TUR Regulations Reply

Dear Facility Manager or Toxics Use Reduction Planner:

I am writing to remind you that 2012 is a planning year under the Toxics Use Reduction Act (TURA) and that facilities covered by TURA are required to complete their TURA plan (or in some cases an Environmental Management System or Resource Conservation plan) for this planning cycle by July 1, 2012

Employee Notification
Please note the TUR regulations1 require that notice to employees regarding the upcoming planning process must be completed by January 1, 2012.  If a facility is unsure of which type of plan it will develop, it should notify its employees that the facility will be developing either a Toxics Use Reduction (TUR), Resource Conservation (RC) or Environmental Management Systems (EMS) Plan.

For further information:  http://www.mass.gov/dep/toxics/tura/planning.htm .  Because there have been no changes to the planning requirements, the guidance on the web is still valid.  However an updated version containing minor changes to the reporting form will be posted in the coming months.

[1] [310 CMR 50.42(5) and 310 CMR 50.92(6), respectively]

Paul Walsh
MassDEP, BWP, Business Reporting and Fiscal Operations
One Winter Street
Boston Ma 02108
Office 617-556-1011