Going through any permitting process may seem to be a great deal like picking berries from a thorny branch. BWSC permits do not have to be that scary. Listed below are a few common mistakes that if avoided will lead you down an easy permit path.
Double check your math before submitting the NRS!
Disposal Site Definition
Consider the definition of the Disposal Site throughout the scoring process, and note that the disposal site boundary is not limited to the boundaries of the property where the release has occurred.
Rationale for Scoring
The rationale for scoring must either be on the scoresheet or clearly referenced in the Phase I and/or other applicable reports being submitted along with the Tier Classification.
Tier I Inclusionary Criteria
Regardless of the NRS score, any disposal site where there is groundwater contamination equal to or greater than RCGW-1 values, and such groundwater is located within an Interim Wellhead Protection Area (IWPA) or Zone II, must be categorically classified as Tier I. In addition, any site where an Imminent Hazard is present at the time of Tier Classification is also categorically a Tier I site.
Submittal of an Adequate Phase I
Many permit submittals have an inadequate Phase I. The Phase I must have, at a minimum, all the requirements as laid out in 310 CMR 40.0483. A good Phase I can save many headaches down the line.
Note that this section must be used judiciously and only for a maximum adjustment of 50 points.
Legal Notice/Notification of Local Officials
Don't forgot the legal notices and required notification of local officials! See the Public Involvement Fact Sheet in the BWSC Public Involvement page for additional details.
Be reminded that the permit review does not start until the application fee has been received by the Department!