Wastewater discharge from your facility’s lab sinks, glass washers, autoclaves, and other equipment is considered industrial process wastewater. Discharging wastewater generally requires a permit with the local agency such as the Massachusetts Water Resources Authority (MWRA) or local publicly owned treatment works (POTW). In addition, pretreating the wastewater is often needed to ensure the pH is in an acceptable range prior to discharge. This may be accomplished using various means, most commonly through the use of a pH neutralization system.
The Massachusetts Department of Environmental Protection’s (MassDEP) regulation on industrial wastewater pretreatment systems [314 CMR 12.00], including those for pH neutralization, requires that there be oversight by a certified wastewater operator (WWO). The MassDEP regulation on WWO certification [257 CMR 2.00] outlines the conditions for the evaluation and certification of operators of wastewater treatment facilities.
Wastewater Operator Certification Requirements
To become a certified WWO, candidates must gain experience, pass an exam approved by the local authority, and then submit a licensing application. In Massachusetts, the test is administered by the New England Interstate Water Pollution Control Commission (NEIWPCC), and the license application must be approved by MassDEP.
To maintain their certification, WWOs are required to renew their licenses on a regular basis and attend continuing education courses to maintain their competency and keep up with innovations in their field. For example, Massachusetts WWOs must renew every two years, due by December 31 of odd-numbered years. They must also accumulate 20 training contact hours (TCHs) during that period and provide documentation of course completions with their operator license renewal application.
A link to a summary of the State Operator Certification Programs can be found on the About Operator Certification page hosted by the U.S. Environmental Protection Agency (EPA).
Once a WWO is certified, they can assume responsibility for ensuring that the wastewater pretreatment system is operating properly. This includes performing daily documented checks to monitor flow and pH and identify pH readings outside of the allowable range. Companies can choose to have one or more internal employees become certified, or they can contract with a vendor for daily on-site visits to monitor the system and complete the required pH and flow logs.
Certified Wastewater Operator Exemptions
There are exemptions listed in 257 CMR 2.00 for pretreatment systems that are not required to be maintained by a certified wastewater operator because they are not considered to be industrial wastewater pretreatment systems (IWPS). Included in this list are limestone chip neutralization units, commonly known as chip tanks. An additional, and often overlooked exemption, is the one for pH neutralization systems treating less than 100 gallons per day.
If your facility qualifies for this exemption because flow is consistently below the 100 gallons per day threshold, it’s necessary to formally request a determination from MassDEP, including providing flow logs for the previous 6-12 months. For facilities that think they will qualify for this exemption, but have not yet begun discharging, calculated flow estimates may be acceptable.
If a facility is approved for the exemption, a letter will be issued by MassDEP confirming its exempt status. In this case, a certified WWO is not necessary. However, they must continue to check the system daily to verify proper operation and monitor flow and pH. In addition, a Staffing Plan must still be submitted to MassDEP that documents how the pH neutralization system will be monitored, including information about the non-certified individuals that will be checking the system.
If you believe your organization may qualify for the exemption, in most circumstances it’s advantageous to apply. If granted, it can help facilitate regulatory compliance and can result in significant cost savings. Time and resources won’t need to be allocated for internal staff to obtain and maintain WWO certifications. For facilities that have been contracting with a vendor to perform the daily checks of the system, that will no longer be needed as they can be done by in-house by non-certified staff.
For additional information on wastewater operator requirements, for help applying for the WWO exemption, or for assistance with training to pass the exam, please contact us. If your facility doesn’t qualify for the exemption and has internal certified WWOs who need to maintain TCHs for their licenses, check out our TCH-approved training options by following this link.
This Blog was written by Beth Graham, Safety Partners’ Director of Quality, Research, and Training.
