If your facility discharges industrial wastewater to the sewer system, then you more than likely have your sewer use permit. If you have successfully gone through the process of applying for and receiving your permit then you are one step closer to keeping your facility in compliance with EPA, DEP, and MWRA regulations. The process doesn’t stop at simply applying for and receiving your permit. The day-to-day maintenance and upkeep of your permit requirements is extremely important to make sure you stay in compliance. Read on to understand the big picture requirements within your permit.
The big picture – why you need a discharge permit in the first place.
As an EHS director, wastewater is a small part of your job. However, what your facility discharges to the sewer system is a big deal. The process of having and maintaining a MWRA Discharge Permit is important for the prevention of pollution and keeping the public safe. When wastewater leaves your facility it then travels to the headworks (a publicly owned treatment facility) and is combined with the sewage of over 5,500 other industries as well as sewage from the 43 communities that discharge to the MWRA. Meeting your discharge limitations is vital to preventing public health issues within the sewage system and keeping the receiving bodies of water (such as Boston Harbor) free from pollutants.
Meeting your requirements – Discharge Limits
The first few pages of your permit list out the potential pollutants that you need to sample for to ensure that your facility is staying within MWRA compliance. The table will show the sampling location (listed as a number – this number correlates to a specific system or sampling spigot that a certified Massachusetts DEP laboratory employee will use to take a sample of wastewater from) as well as the pollutant name and the frequency of how often a sample must be taken from that location (for example, this could be monthly, quarterly, semi-annual, annual, etc.)
A good rule of thumb is to sample early and sample often! Meeting your requirements is not only taking a representative sample and discharging within the allotted limits, it is also submitting your paperwork within the correct timeframe to the MWRA.
Getting the right people involved on your team
If you do not have a licensed operator on your team (or do not hold your own license), you can sign up for one of our training courses to start the process.
Keep in mind that your wastewater (effluent) will also need to be sampled by a Massachusetts DEP certified lab that uses the required EPA analysis method per each pollutant listed. Check to see that the sampling company you are working with is a Massachusetts DEP certified lab to meet your MWRA sewer user permit regulations.
The paperwork needed to stay in compliance
If you thought that the paperwork stopped with your permit application, think again! A big part of staying in compliance with the MWRA is making sure that you properly record each sampling event that takes place as well as filing the paperwork on time. Some of the paperwork that your sampling company should help you handle and deliver to the MWRA include:
- MWRA Smart Chains (field forms / chain of custody forms)
- Sample Analyses / testing results
- Reporting certification forms
- Reviewing your daily flow log
- Reviewing your pH report (log)
- Staffing plans to the Mass DEP
- Facility Grading Report (Mass DEP)
Depending on the specific needs of your permit, there may be other paperwork involved including (but not limited to) slug control plans, hazardous waste plans, notifications of any non-compliance, and 90-day Baseline Sampling.
Adhering to Important Dates and Deadlines
Half of the battle of staying in compliance is adhering to important dates and deadlines listed in your permit. Write out any deadlines on a separate sheet of paper and review these dates with your sampling company. The frequency of sampling events listed are the bare minimum requirement for analyzing the wastewater coming out of your facility. A seasoned EHS professional knows the rule of thumb – sample early, sample often! Doing so can keep your facility within limits especially if you are a designated Significant Industrial User (SIU). Half of the violations administered to SIU’s in SNC (significant non-compliance) are due to poor reporting practices.
A final note on MWRA compliance:
If you are overwhelmed with the requirements listed in your MWRA Sewer User Permit, worry not! Practical Applications Inc is Boston’s leading provider of compliance services to EHS professionals like you. Reach out to our team of compliance specialists and certified operators by calling us at 617-423-5639 or fill out our contact form.