ECAR
Fact Sheet for Massachusetts
Wastewater
Discharges
Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources
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The
following fact sheet was prepared by the ECAR Center staff. Once
prepared, each ECAR Center fact sheet undergoes a review process
with the applicable state environmental agency(ies). You can check
on the status of the review process here.
Please read the disclaimer on the status page. While we have tried
to present a summary of the essential information on this topic,
you should be aware that other items, such as local regulations,
may apply to you.
What You Need to Know
Wastewater is often generated by operations such as the rinsing of
parts, and the washing down of engines or dirty tools. If water
becomes mixed with oil, antifreeze, solvents, or other liquids,
it is important that it be properly treated and contained prior
to discharge. If your wastewater is currently just
going down an unregulated drain, you've got a problem. Even
if your activities have gone unnoticed for years, there is an increasing
chance that you will be inspected. The federal EPA and the
states are starting to look much more carefully at sources of water
pollution that have so far remained unidentified, and they have
(rightly or wrongly) decided that auto recyclers are a significant
problem area.
You
will almost certainly need separate permits both for stormwater
runoff (see the ECAR Stormwater fact sheet) and for any industrial
wastewater that you generate. This page will give you an overview
of how to handle your industrial wastewater.
Regulations
Industrial
wastewater is regulated differently than sanitary wastewater. If
you combine sanitary and industrial wastewater, then the mixed wastewater
is regulated like industrial wastewater. All industrial wastewater
discharges are regulated by federal and state regulations and in
most cases, also by local regulations.
Industrial Wastewater. If a facility generates
industrial wastewater, there may be requirements it must meet in
order to ensure that the wastewater is properly managed. There are
two situations in which a facility might be required to obtain a
permit for wastewater generated by the facility, depending upon
how the wastewater is ultimately disposed. These two situations
are discharges to waters of Massachusetts and discharges to a publicly
owned treatment works (POTW).
Discharges
to waters of Massachusetts. If your facility
discharges industrial wastewater via a “point source” (such as a
pipe, etc.) directly to waters of Massachusetts, you will be required
to obtain a National Pollutant Discharge Elimination System (NPDES)
permit from DEP and from EPA Region 1. Waters of Massachusetts
include (but are not limited to) ground water, storm drains, rivers,
streams, lakes and ditches. NPDES permits can be either general
or individual permits. A general permit is a “one size fits all”
type of permit and is issued for specific types of discharges such
as storm water runoff, non-contact cooling water or stone quarry
discharges. An individual permit is site-specific and unique to
a facility. Stormwater permits are considered NPDES general permits.
Permits contain limits on the quantity, discharge rate and concentrations
of pollutants in the water that are discharged from a point source
into waters of the state. There are permit fees associated with
the state permit, but not the EPA permit.
Since
Massachusetts is one of the few states that does not have authority
to implement the federal NPDES permit program, EPA and DEP issue
joint permits. Applications for NPDES permits must be submitted
to and approved by EPA Region 1 and the Massachusetts DEP. For Massachusetts
NPDES permits, facility owners or operators must also mail an identical
copy of the EPA application forms to DEP.
Discharges
to a POTW. If your facility discharges industrial wastewater
into a municipal sewer connected to a POTW, you may need to obtain
a pretreatment permit. To meet the standards of your local sewer
authority, you may need to install treatment equipment such as an
oil/water separator to prevent oil and sludge from being discharged
to the sewer. This is referred to as "pretreatment.” Sludge
collected by pretreatment equipment will have to be periodically
removed and disposed of, possibly as a hazardous waste (you must make a hazardous waste
determination). In most instances, wastewater will require some form of pretreatment
prior to discharge into the sewer system.
If your facility disposes
of its wastewater in a manner other than sending it to a POTW, it
will need to determine whether it is a hazardous waste. If your wastewater is a hazardous
waste, you will need to ensure that the tank storing this wastewater
meets the requirements contained in the hazardous waste rules. In
addition, you must ensure that it properly manages its wastewater
upon removing it from the tank. See the ECAR Hazardous Waste Fact Sheet for more information.
Links
to the Regulations and Forms. Use the following links to view the regulations and permit forms pertaining
to wastewater.
Massachusetts Clean
Water Act – Located Under Water Pollution Control
Water Permit Application
Information
Notice of Intent (NOI) Form
Federal Safe Drinking Water
Act Requirements
Self-Audit
Checklist
When
an inspector comes to your facility, there are certain things he
or she checks to see if you are in compliance with environmental
regulations. It makes good sense for you to perform a "self-audit"
and catch and correct problems before they result in penalties.
Also, there are some compliance incentives associated with self-audits
(see Audit
Policy Page).
Use
the following list to audit your wastewater management activities.
- Does your facility discharge process wastewater?
Are the discharges authorized by a permit? Check all uses of water and
steam within the industrial areas of your facility. Determine
where wastewater is generated and discharged. You must have a
NPDES permit to discharge to surface waters and may need a permit
to discharge to your local sewer authority. Check with DEP and
EPA Region 1 to ensure you have the proper permits.
- Have you performed the necessary pretreatment? If you are discharging to a sewer system/treatment plant,
you likely will have to perform pretreatment of your waste. Check
with your local sewer authority.
- Is oil or solvent discharged to the sewer? Federal and state laws prohibit
the discharge of oil or flammable solvents to the sewer system.
These are regulated wastes that must be properly disposed of as
hazardous wastes.
Best
Management Practices (BMPs)
Most
regulations tell you what you have to do to be in compliance, but
they don’t explain how to do it. That’s where "best management
practices" come into play. BMPs are proven methods that
help you to get into compliance and stay there. The following BMPs
are recommended for wastewater management.
- Limit water use and the volume of water discharged
through conservation methods and by reusing water whenever possible.
- Train employees to use water efficiently.
- Don’t use water for cleaning floors and equipment
unless absolutely necessary. Use dry cleanup methods for spills.
- Post signs at all floor drains and sinks in industrial
areas of your facility to discourage employees from using the
drains to dispose of oil, other vehicle fluids, solvent, paint
or similar liquids. Review these rules with your employees.
- Use only non-toxic soaps to clean floors and
vehicles instead of hazardous materials.
- If you have floor drains at your facility that
are not in use, consider having them capped or plugged to prevent
misuse or accidental discharges.
- Prevent drips and spills from reaching the floor.
- Check your floor drains and make certain you
know where they discharge.
- Setup and use a maintenance schedule for inspection
and cleaning of floor drains, oil/water separators, traps, etc.
- Never have floor drains where hazardous materials
are stored.
- If your wastewater is nonhazardous, you may want
to purchase evaporating equipment to evaporate your wastewater.
It should be noted that evaporators may require an air permit
or registration, and evaporator bottoms may be considered a hazardous
waste.
- Don’t use degreaser solvents to clean engines.
Most engine degreasers are hazardous and should not be discharged
to a POTW. Even if you use nonhazardous degreasers, the oil and
grease concentration in the spent degreaser may exceed the limit
allowed by your sewer authority.
Contacts
- For more information, contact
the Massachusetts Department of Environmental Protection at 617-338-2255 or 800-462-0444, or contact
the DEP Regional Service Center
near you.
- EPA
Region 1 can be reached at (888) 372-7341.
- To report a spill or leak, call
the 24-Hour DEP Emergency Response hotline at 617-556-1133 or
888-304-1133.
- To report an environmental incident
or complaint, contact the Environmental
Strike Force at 617-556-1000 or 888-VIOLATE (1-888-846-5283).
Related
ECAR Fact Sheets
- Stormwater
- Septic Tanks and Disposal Wells
Other
Relevant Resources
- Massachusetts DEP
Fact Sheet – Regulation of Industrial Wastewater, Holding Tanks
and Containers
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