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Phase II Reports >> Pretreatment Manual
Facilities Loadings
| Pretreatment Manual |
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Hg Management Guidebook | Mercury Products
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For more
information, contact David Eppstein by email at
deppstein@masco.harvard.edu,
or by calling 617-632-2860.
13.0 PERMITTING, LICENSING, AND REGULATORY COMPLIANCE ISSUES
Some or
all of the permits listed in Appendix A may be required for the
installation and operation of a wastewater pretreatment system.
Other permits may be required as well. An experienced consulting
engineering firm can advise you further in this area.
Most
permit submittals require certain supporting materials to
accompany the basic permit application. Often, the supporting
materials may be the major portion of the permit application
submittal. Care should be exercised in the preparation of the
applications and supporting materials because many rules and
regulations may apply that are not readily apparent from the
application form itself. For example, an extensive Federal
regulation (40 CFR 136) exists on the procedures that must be
followed in performing an analytical characterization of
wastewater.
Additionally,
for all permitting or compliance monitoring purposes, the MWRA
requires that only Massachusetts DEP-certified analytical
laboratories be used for the analytical testing of wastewater.
Analytical test reports will not be accepted if an analytical
laboratory has only a provisional DEP certification. Extensive
project delays could result if submittals are filed with
supporting data that later is deemed invalid for regulatory
reasons.
A
successful permitting effort will rely on the sensible and
effective timing of all the various required submittals. For
project scheduling purposes, using the longest times allowed by
law is generally advisable for estimating regulatory review
periods (such as for DEP permits issued under the provisions of
the timely action and fee schedule, 310 CMR 4.00). It is also
advisable to plan for meetings and to include contingencies in
the schedule such as time for preparing responses to possible
agency requests for further information.
Additional
requirements apply to, and submittals are required for,
wastewater discharges from "categorical" industrial
processes covered by federal regulations (Title 40, Chapter I,
Subchapter N, or 40 CFR 405 to 474). On the other hand, some
permit applications to the Massachusetts DEP are no longer
required within the MWRA Sewer Service Area because of a
Memorandum of Understanding adopted by the MWRA and DEP
concerning Sewer Connection Permits and wastewater pretreatment
Plan Approvals. Applicants should keep in mind that many permit
conditions can be appealed (typically within 30 days after
receipt) and that a careful analysis of all permit requirements
should be undertaken immediately upon receipt.
If
wastewater discharge standards are not being met, the
noncompliance should first be reported to the pertinent
regulatory agency in a timely manner. The situation should be
discussed at a meeting with the regulatory agency so that all
parties understand the full magnitude of the problem. All facts
and requirements should be documented in writing, if possible.
The facility management should be completely informed of the
situation and give full commitment to resolving the issue on a
timely basis.
If
pretreatment is ultimately selected to achieve compliance, the
goal should be to achieve the lowest installed cost for a
pretreatment system, with the lowest operating cost, while
meeting all discharge requirements. The Pretreatment Guidance
Subgroup hopes that this Manual can help many facilities to
address and achieve this goal.
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