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

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.

1. 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.
2. 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.
3. 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

1. 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.
2. EPA Region 1 can be reached at (888) 372-7341.
3. To report a spill or leak, call the 24-Hour DEP Emergency Response hotline at 617-556-1133 or 888-304-1133.
4. 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

1. Stormwater
2. Septic Tanks and Disposal Wells