Wastewater Operator Status Change
Download this PDF to change your operator status.

Wastewater Operator Status Change Form

Collection, Recycling, Labeling and Sales Ban of Mercury-added Products; and Disposal Prohibition of Mercury-added Products in Solid Waste–310 CMR 19.00 (amended), 74.00 (amended), 75.00 (amended), 76.00 (added).

Brief Explanation and Rationale for Changes

Signed into law in July 2006, the “Massachusetts Mercury Management Act” is designed to keep mercury out of our trash and wastewater, where it is released into the environment. MassDEP is implementing this law in two phases. The Phase 1 regulations (promulgated on December 28, 2007) banned the sale of mercury-added products in Massachusetts unless the manufacturer registers the product with an interstate clearinghouse and establishes a collection program for the end-of-life products, banned schools from buying mercury-containing products, required auto manufacturers to collect and recycle mercury switches from “end of life” vehicles, required manufacturers of mercury containing lamps to educate consumers about mercury hazards and the requirement to recycle discarded lamps and to report on lamp recycling to MassDEP.

The Phase 2 regulations (promulgated on August 21, 2009) ban the sale in Massachusetts of specific mercury-added products, establish a procedure for manufacturers to apply for an exemption from the sales ban, and establish labeling requirements for mercury-added products that are sold in Massachusetts. The regulations also prohibit disposal of any mercury-added product in solid waste.

View the final regulations here: http://www.mass.gov/dep/public/reglist.htm or contact Practical Applications with any questions.

MA DEP

Information will be collected through an electronic survey. 1900 chemicals and approximately 3500 individual businesses will be targeted. The survey will be conducted in three phases with the first phase beginning in July.

The first phase targets all 1200 large quantity generators within the state. Notification postcards will go out in July and reporting will begin in August.

The second and third phases include a statistical representation of different business categories within the state. Approximately 2500 businesses have been chosen as part of the statistical sample. These
businesses will be split into Phases two and three, with about 1200 businesses participating in each phase. Notification will be via postcard in August for Phase II and December for Phase III. Phase II reporting begins in
mid-October and Phase III in the beginning of February.

All phases will receive a postcard about 45 days before reporting begins and a reporting package about two weeks before reporting begins. Every company will have 60 days in which to complete the report. Non-respondents will
receive a notice of non-compliance(NON). If the NON is ignored, the DEP will implement fines.

The survey is similar to other e-DEP forms. You will receive a toxic discharger id in your reporting packet. The form asks for general facility identification, toxics information, and a standard DEP certification
statement. You will be asked if you discharge wastewater to the sewer, what pretreatment you use, if you are solely or party research, and if you are a health care facility. You are then asked to compare the list of 1900
chemicals to the MSD sheets in your facility for chemicals that are discharged or have a reasonable potential to be discharged to the sewer. You are required to list all of these chemicals on the form and give a very
generalized frequency of discharge. If your company has an electronic file for the MSDSs, you will have the opportunity to upload the file to the DEP system and it will compare your MSDS with their chemical list. Their
chemical list is presented as a database searchable by name and CAS number.

Note: Research and development facilities will not have to fill out the toxics section at this time. If you are solely R&D, you must check off the box stating so and then sign the certification statement. The DEP will look
into R&D facilities further down the road.

The DEP will have training available through their website.

The DEP is looking for volunteers to come in and test the new electronic system during the first week in July. They were working on getting TCH credits for this testing. If you are interested, you can contact John
Reinhardt at: john.reinhardt@state.ma.us

We wanted to send out a notification for those who did not attend the MWRA Significant Industrial User (SIU) meetings this week.  As many of you know, the EPA audited the MWRA and its Industrial Pretreatment Program(IPP) back in December 2007.  The MWRA just received the report back and one of the requirements in the report was to change/streamline their

MWRA Rate Increase - Regulation 310 CMR 10.00

regulations.  The MWRA changed some of the terminology surrounding the adjudicatory proceedings(310 CMR 1.00) and clarified the language and provisions surrounding enforcement actions (310 CMR 2.00).  Changes to 310 CMR 10.00 included adding definitions for Best Management Practices(BMP) and New Sources, clarifying the definitions for an SIU, adding a prohibition against BOD and COD that could interfere with the POTW function, and proposing a fee increase over the next three years.  You can view the proposed regulations by visiting http://www.mwra.com/trac/proposedamendments-2009.htm.  The underlined text means an addition, a strike means a deletion.

This fee increase affects ALL industrial users.  If you have a permit, whether it is a low-flow general permit or your are a SIU, your fees will be going up.  The proposed increase is 4.5% each year for three years.  They have not raised their fees since fiscal year 2005 and are looking for feedback regarding the increase.  The informal comment period on the fee increase ends April 24th!  If you have comments regarding the fee increase (or the other regulations changes), please email Carolyn Fiore at cfiore@mwra.state.ma.us by April 24th.

MIT Brain and Cognitive Center Greywater System

Click here to download our PDF brochure of this article at our documents location.

Follow these basic to complete your next successful Greywater System Installation

Successful Greywater projects include the following elements:

1. The project has a favorable Return on Investment (ROI),
2. A wastewater stream characterization was completed,
3. Based on item two, suitable recover and storage equipment was chosen,
4. Based on item two, suitable treatment equipment and piping was chosen, and
5. The system design integrated Plumbing Code & Environmental Regulations including protection, monitoring and regulatory reporting.

Return On Investment
All Greywater projects should have a Return on investment that has a payback of less than two years.  Currently the MWRA Water and Sewer Rates Average  $9.80/HCF (updated Nov 2008, Boston MA Commercial).  A typical Greywater system costs between $50,000.00 and $100,000.00. Based on Boston commercial water and sewer rates, owners need to recycle at least 5,228 gallons of water per day for the system to have a favorable ROI.

Wastewater Stream Characterization
Typical Greywater systems recover water from sources that contain a variety of contaminants that need to be measured to ensure that downstream systems and equipment are not damaged and to prevent exposure of harmful pollutants to the end users.  At a minimum the following measurements are made from a representative stream:

a. Suspended Solids
b. Dissolved Solids
c. Organics (synthetic)
d. pH (Acidity & Alkalinity)
e. Bacteria

Once a baseline analysis is performed further sampling and analysis may be necessary to address site specific contaminants.

Recovery and Storage
Cisterns and Day Tanks need to be configured to minimize contaminant loading and to prevent code violations.  For example, cisterns can be configured to bypass the first portion of rainwater during a rain event to reduce the organic loading on the system caused by bird waste and other debris which may accumulate on the roof.  Second, mixed recovered wastewater streams cannot be discharged to the storm drain and vice versa.  It is illegal to discharge rain water to the sewer system and it is illegal to discharge industrial wastewater to the storm system.

The cistern and day tanks need to be sized appropriately to recover the maximum water amount yet minimize the tank’s footprint. Cisterns should be sized large enough to capture typical rain events and oversized to maximize a rain events’ capture.

Sample Calculation
Cistern volumes can be determined by calculating the roof top water yield for any given rainfall, shown in Equation 1 below.
Day tanks are sized based on the process feeding the Greywater System.  A day tank used to recover Reverse Osmosis Reject (RO Reject) is sized to capture the entire reject cycle.

Equation 1 : V = A2 x R x 0.90 x 7.5 gals./ ft.3
where:

V= volume of cistern (gallons)
A2= surface area roof (square feet)
R= rainfall (feet)
0.90= losses to system (no units)
7.5= conversion factor (gallons per cubic foot)

Example: one 600-gallon Cistern would provide runoff storage from a rooftop area of approximately 2150 square feet for a 0.5 inch (0.042 ft.) of rainfall.

600 gallons = 2150 ft.2 x 0.042 ft. x 0.90 x 7.5 gallons/ft.3

Treatment Equipment & Piping
Based on the wastewater stream characterization study, the Greywater may require some treatment prior to use.  Most systems employ mechanical filtration to remove the suspended dirt to protect downstream equipment such as flush valves.  The type of mechanical filtration equipment will depend on the flow rate.

Typical equipment according for flow rates is:

Multimedia Filtration Systems (flows 50gpm and higher)
Bag Filtration (flows 10gpm to 100gpm)
Cartridge Filtration (flows less than 15gpm)

If needed, treatment to remove or protect the Greywater may include; Bleach, Ozone, or UV Light. The choice is site/wastestream dependent.

Piping planned and installed in new construction projects is critical to meeting the ROI budget as it is almost impossible to retrofit an existing building with separate Greywater Systems.

Regulations require that mixed wastewater is discharged to the appropriate drain system (i.e., storm drains, sanitary drains). Therefore, attention is needed to determine if the cistern overflow piping is directed to storm drainage and if the day tank overflow is directed to sanitary drainage. A regulatory review is needed to ensure that the piping is correct.

Plumbing Code and Environmental Regulations
Currently the Massachusetts Plumbing code requires a State issued special permit for Greywater Systems. All permits are issues by the Board of State Examiners of Plumbers and Gasfitters via the “Special Permission Plumbing Request Application Form.” The Massachusetts Department of Environmental Protection (MADEP) regulates Greywater systems under state regulations 314CMR20.00. The MADEP requires that the water not harm the public who come in contact with the Greywater. Therefore, some Greywater systems may need to add chemicals to kill harmful microorganisms or may need special treatment to remove harmful toxins.

The local Board of Health may also require permitting and monitoring.

An excursion is an instance in which there was wastewater discharged to the sewer system outside the acceptable pH range, 5.5-12 s.u. for MWRA customers. Usually an excursion is found when it is recorded on an effluent chart recorder. Before panicking, here’s what you need to know and do to fix the problem.

1. Is the system still in excursion? If the system has recovered, review steps 2 and 3. If the system has not recovered, skip to 4.

2. Determine if there was flow during the time in which the pH was outside the acceptable range. Effluent chart recorders that chart both pH and flow are a great source for this information. If there was no flow, there was no excursion. During no flow periods, bacterial growth can result in low pH readings. This condition will clear once flow resumes.

3. Was there an exceptionally high flow during the excursion? Active, gravity flowing pH systems have a maximum flow above which they cannot neutralize the wastewater. Find out why there was such a high discharge flow rate. It’s possible that something failed upstream (ie leaking valve, broken pipe, etc.).

4. If there was flow consistent with what is usually recorded, start looking into the pH system components. The key components to look at are listed below.

a. Are the pH sensors clean and calibrated? Remove the sensors from service, clean, and calibrate them.

b. Is the mixer running and agitating the tank appropriately? A non-mixed tank will not efficiently neutralize wastewater. Possible reasons for mixer failure are a blown fuse, mixer motor failure, gearbox failure, mixer shaft or prop failure.

c. Is the chemical delivery system working as required? First, check the chemical level and ensure there is plenty of acid and base. Then, check the metering pumps by actuating them. This will show if the pumps are energized and primed. Make sure after checking pump prime that the pump is put back into the auto mode for treatment.

5. If nothing significant has been detected yet, start looking into the pH setpoints established in the pH analyzer/controller. Are the setpoints aggressive enough to treat the wastewater at the flow rates recorded? Have there been any changes in upstream processes that are making the wastewater more difficult to neutralize?

An excursion isn’t catastrophic, but it needs to be addressed and put in the Operators Daily Log. The list above should help you determine the problem so it can be addressed. Isolating the problem is the most difficult part of getting to the final repair.

Make sure all of your logs include the following information in an easy to read format:

• Permit Number
• Discharge Location
• Total Daily Flow. Not just the totalizer reading, do the math and find the daily flow. Simply yesterday’s totalizer reading minus today’s reading gives you the daily flow.

Save your company some fines, and save yourself a headache by jotting down the following due dates for 2007!

• Self-monitoring Quarterly Reports
    First Quarter: April 1
    Second Quarter: July 31
    Third Quarter: October 31
    Fourth Quarter: January 31 (2008)

• Self-monitoring Semi-Annual Reports
    First Half: July 1
    Second Half: January 31 (2008)

• Discharge Renewal
    Company specific

• TURA Reports
    Annual: July 15

• TIER I/II
    Annual: March 1