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Exempt pH Neutralization Systems Still Need Monitoring

257 CMR 2.00, Certification of Operators of Wastewater Treatment Facilities, establishes the requirements for evaluation and certification of operators of wastewater treatment facilities. Facilities that discharge industrial wastewater through a pH neutralization system may fall under this regulation, which is enforced by the MA Department of Environmental Protection.

One of the exemptions listed in 257 CMR 2.04 exempts treatment systems that are neutralizing less than 100 gallons per day from certified operator requirements. If your facility falls under this exemption, it is important to remember to check your pH neutralization system even though a certified wastewater operator may not be necessary. Daily discharge parameters and flow should be monitored by someone familiar with the system to ensure that effluent requirements are met.

It is also important to keep an eye on the daily discharge volume over time. As facilities grow; the daily effluent flow will increase with time, and it is possible for facilities to cross the 100 gallon per day threshold without realizing it if no one is tasked with tracking this.

Remember that a grading report and staffing plan still need to be completed and maintained even for exempt systems. The staffing plan should accurately reflect how the pH neutralization system will be monitored, including checks by individuals that are not certified wastewater operators when the exemption applies.

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