Fifty-seven municipalities located in Massachusetts fall under the jurisdiction of the Massachusetts Water Resources Authority (MWRA) for industrial wastewater discharge. If your facility is in a location covered by the MWRA, depending on the type of permit held, MWRA sampling may be required by the end of the year.
Per the requirements for Category 2 MWRA permit holders, wastewater samples for the second half of the year must be collected by December 31, 2024. The sample analysis must be performed by an independent laboratory with either Department of Environmental Protection (DEP) certification or accreditation from the Environmental Protection Agency’s (EPA) National Environmental Laboratory Accreditation Program (NELAP).
Sampling and analysis must be conducted according to applicable EPA approved procedures in 40 CFR Part 136, unless otherwise authorized or required by the MWRA or EPA.
Both the permit holder and the laboratory have specific responsibilities, and the process must follow applicable EPA approved procedures, with chain of custody documentation showing submission to a certified laboratory.
The permit holder is required to:
- Provide a Sample Analysis and Reporting Certification Form to the laboratory authorizing the electronic data submittal. A copy of the form can be found in the facility’s MWRA permit.
- Review the results as soon as they are received and notify their local MWRA Industrial Coordinator (IC) of any issues of non-compliance.
The analytical testing laboratory must:
- Directly submit the results of the wastewater sampling via the MWRA’s electronic Pretreatment Information Management System Web Self-Monitoring Report (Web SMR).
- Provide the permittee with a copy of the results no later than the day the laboratory submits the electronic report to the MWRA.
The Sewer Use Regulations [360 CMR 10] include daily maximum discharge limitations for regulated pollutants including formaldehyde, cyanide, phenol, specific metals, and listed toxic organics for both the Metropolitan Sewerage Service Area and the Clinton Sewerage Service Area.
If the sampling results detect levels above those listed in the facility’s permit or the specific discharge limitations found in 360 CMR 10.024, the MWRA must be notified (at 617-242-6000) within 24 hours of becoming aware of the violation. The report that includes the non-compliant discharge must also be submitted.
The permit holder must repeat the sampling and analysis and submit the subsequent report to the MWRA within 30 days. Prior to resampling, the permit holder should investigate, determine the source of the non-compliant discharge, and take corrective measures to prevent recurrence.
In addition to conducting sampling, Category 2 MWRA permit holders are required to submit a semi-annual report by January 31, 2025 that includes pH and flow logs for July through December 2024. The report must be sent using an MWRA Submittal Form.
Companies holding an MWRA General Low Flow and Low Pollutant Permit (Category 10) do not have a December 31st deadline, as they are not required to perform semi-annual wastewater testing or submit pH and flow logs. However, General Permit holders are required to conduct sampling within 60 days of the permit issuance date for new and renewed permits.
General Permit holders are also responsible for reviewing the sampling results and notifying the MWRA of any issues of non-compliance and conducting resampling. It’s important to note that the sampling results are not submitted directly to the MWRA by the analytical lab; the General Permit holder must send them.
Regardless of the type of MWRA permit you hold, sampling analyses records must be maintained at your facility for at least 3 years. Discharge violation reports, along with investigation, corrective action, and other supporting documentation should be kept on file as well.
Safety Partners can help! We will reduce your regulatory compliance obligations by taking care of the following items:
- Scheduling your required sampling with an approved vendor
- Reviewing and interpreting the sampling results, and making any required notifications to the MWRA
- Investigating the reasons for any non-complying discharge and assisting with putting corrective measures into place
- Arranging for any resampling that may be required
- Reviewing your pH and flow logs for compliance
- Completing the semi-annual report and MWRA submittal form and sending them to MWRA’s Toxic Reduction and Control (TRAC) division
- Assisting with all MWRA record keeping requirements
Please contact us for additional information on MWRA-related requirements and the services we can provide.
This blog was written by Beth Graham, Director of Quality, Research, and Training