For Category 2 Massachusetts Water Resources Authority (MWRA) permit holders, semi-annual wastewater sampling for the January through June sampling period must be conducted by June 30th. Reports, including pH and flow logs, are due by July 31st. Even though the sampling results are sent directly to the MWRA by the analytical testing laboratory using the MWRA’s electronic reporting system, permit holders are responsible for reviewing the results and notifying the MWRA of any issues of non-compliance.
If the sampling results show that any regulated chemicals are detected above the discharge limits specified in the facility’s permit or the Sewer Use Regulations (360 CMR 10), the MWRA must be notified within 24 hours of becoming aware of the violation. 360 CMR 10.024 specifies the specific 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 a violation is identified, the permit holder is responsible for repeating the sampling and submitting the subsequent analysis to the MWRA within 30 days. Before conducting re-sampling, the permit holder should investigate the cause of any results above discharge limits. The source of the elevated discharge needs to be determined, and corrective measures put in place to prevent any reoccurrence of the non-complying discharge.
Companies holding an MWRA General Permit (Low Flow and Low Pollutant) are not required to conduct semi-annual sampling and therefore do not have a June 30th deadline to submit sampling results. However, General Permit holders are now required to conduct sampling within 60 days of the permit issuance date for new and renewed permits. It’s important to note that for General Permit holders, the sampling results are not submitted directly to the MWRA by the analytical lab and must be mailed to the MWRA by the permit holder. General Permit holders are also responsible for reviewing the sampling results and notifying the MWRA of any issues of non-compliance.
For both types of permits, copies of all sampling reports are required to be kept on file with the permit holder for at least 3 years.
For additional information on MWRA sampling requirements or for assistance with reviewing and interpreting your MWRA sampling results, please email us at firstname.lastname@example.org.
This blog was written by Beth Graham, Associate Director of Quality, Research, & Training at Safety Partners.