MWRA Online: Toxic Reduction and Control (TRAC)

Toxic substances from homes, industries and storm runoff can cause serious problems if allowed to enter our sewer system uncontrolled. Even the most advanced wastewater treatment systems are not designed to treat and remove metals, petroleum, chemicals, and many organics; these pollutants must be addressed at their source. Excessive levels of such chemicals can limit MWRA's use of wastewater sludge as fertilizer, threaten the marine environment or hinder the treatment process.

To reduce toxic discharges at their source, TRAC administers MWRA's Industrial Pretreatment Program under the Federal Clean Water Act. TRAC regulates industrial dischargers in accordance with its Sewer Rules and Regulations (360 CMR 10.00 ) and works with industries to encourage voluntary reductions in their toxic chemical use.

REGULATIONS

The following MWRA's regulations govern what can be discharged into the sewer system. The regulations must be approved by EPA, and published in the Massachusetts register. After the Secretary approves them, they become part of the "Code of Massachusetts Regulations" (CMR), which has the force of law.

360 CMR 1.00 - Adjudicatory Proceedings
360 CMR 2.00 - Enforcement and Administrative Penalties
360 CMR 10.00 - Sewer Use

PERMIT APPLICATIONS

TRAC permit applications and instructions are available for download on our TRAC Permits page.

HOUSEHOLD HAZARDOUS WASTE

Households are also an important source of toxic chemicals due to the careless dumping of toxic products down household drains. Using environmentally safe alternatives instead of many household chemical products is usually cheaper and as effective.

For information on where to take household hazardous wastes, contact your local Department of Public Works. MWRA's guide to household hazardous waste, A Healthy Environment Starts at Home, will help you identify products that could be a hazard and show you dozens of safe, nontoxic alternatives.

TRAC ORGANIZATION AND CONTACTS

The TRAC Department is comprised of the Director's Office, Technical Services section, Legal section and Compliance section.

COMPLIANCE COORDINATORS AND INDUSTRIAL COORDINATORS BY MUNICIPALITY

Each municipality is assigned an Industrial Coordinator and a Compliance Coordinator.

Congress passed the Clean Water Act in part to set water quality standards for water bodies that receive effluent from sewage treatment systems. The Boston Harbor cleanup came about from a lawsuit by the cities of Boston and Quincy against the Metropolitan District Commission (MWRA's predecessor) for failing to comply with the Clean Water Act. MWRA was formed to bring Boston's metropolitan sewer system and Boston Harbor into compliance with a court order, a result of this lawsuit. The Clean Water Act also requires that businesses and industries that discharge into the sewer system be regulated through an industrial pretreatment program. TRAC administers the Industrial Pretreatment Program for the MWRA service area.

MWRA's sewer service area is divided into three regions (North, Central, and South).

INDUSTRIAL COORDINATORS
Each community is assigned an Industrial Coordinator, who is the single point of contact for industrial users in that community. Each Industrial Coordinator serves on a team that is responsible for all of the permitted companies in its region. Industrial Coordinators review Sewer Use Discharge Permit applications, inspect facilities and develop a permit designed to ensure compliance with state and federal regulations. They also issue notices of violation to companies that violate their permits. List of Industrial Coordinators and contact information (PDF)

SAMPLING ASSOCIATES AND COMPLIANCE COORDINATORS
In addition to Industrial Coordinators, each team has Sampling Associates responsible for monitoring the discharge of industrial facilities in their region, a Compliance Coordinator responsible for handling more significant industry violations, and a Regional Inspector responsible for inspecting gas/oil separators and septage facilities located in their region. List of Compliance Coordinators and contact information (PDF)

TRAC issues Discharge Permits to over 1100 companies that discharge process industrial wastewater to the sewer system. There are several categories of permits issued depending upon the nature of a company's process and their potential to violate discharge regulations.

Category	Description
1	A sewer user whose process results in a discharge containing one or more substances in a concentration or quantity requiring pretreatment to meet MWRA discharge standards and who does not have a group permit for the discharge. Examples: Metal plater, printed circuit board manufacturer, industrial laundry.
2	A sewer user whose process results in a discharge containing one or more substances regulated by the MWRA at a concentration or quantity not requiring pretreatment to meet MWRA discharge standards and who does not have a group permit for the discharge. (Examples: Research & Development laboratory, plastic molding manufacturer.)
3	A sewer user whose process results in a discharge not containing a substance regulated by the MWRA and who does not qualify for a group or general permit. (Example: Laser manufacturer.)
4	A sewer user without an industrial waste discharge to the MWRA sewerage system or any tributary thereto. Example: Metal plater whose discharge is hauled outside the MWRA sewer district.
6	A septage pumper.
12	A temporary construction site dewatering permit.
G1	A sewer user with a Group Permit for Photo Processing and Printing Operations.
G2	A sewer user with a Group Permit for Food Processing.
LF/LP (General Permit)	A sewer user that has a relatively low volume of discharge to the sewer and no reasonable potential to violate an MWRA discharge limit. Facilities which are eligible for this permit include those with no regulated parameters and flows less than 25,000 gpd; and those whose discharge is 300 gpd or less with pollutant levels above background (but below MWRA discharge limits), without the need for pretreatment.

Significant Industrial Users (SIUs) are defined by EPA, and receive the greatest amount of oversight. Companies in categories 1-4 can be designated as SIUs if they meet the criteria.

How does MWRA determine the allowable discharge limits for industries in the service area?

MWRA develops local limits for each pollutant of concern. These local limits are generally a concentration-based limit (i.e. expressed in milligrams per liter) which are applied equally to all sewer users. Each of these limits are included as requirements in TRAC's industrial discharge permits. Local limits are required to ensure that industrial discharges do not result in the pass-through or interference of pollutants within a wastewater treatment plant. They are also developed to protect the infrastructure and workers within the treatment plant, and ensure that treatment plant effluent and biosolids do not exceed applicable federal and state water quality and biosolids criteria.

MWRA is required to reevaluate its local discharge limits whenever we receive a new discharge (NPDES) permit is issued for our treatment plants, or every five years. This review is needed to account for changes in the nature of the influent to the treatment plant as well as modifications and improvements in plant treatment processes. TRAC has recently completed review of MWRA local limits in conjunction with the issuance of a new NPDES permit for the Deer Island Treatment Plant. EPA will be holding public hearings on the proposed limits later in 2001. For more info contact Densie Breiteneicher at (617) 305-5618.

TRAC's incentive and other charges program is designed to provide a financial incentive to companies to reduce the types and amount of toxics in their discharge and to help MWRA recover the costs of the program. The two part charge consists of the following:

Pollutant	Reason for Concern	TRAC/MWRA Control Effort
Molybdenum	Molybdenum is a metal which is commonly used as a corrosion inhibitor in industrial, commercial, and residential cooling towers, and has been measured at elevated levels during the cooling season in MWRA fertilizer pellets. While these levels are well below current federal standards, they exceed the Mass. DEP highest-quality levels for unrestricted land application.	TRAC has been working on a voluntary program with suppliers of corrosion control chemicals to switch their corrosion control agents containing molybdenum to those that do not contain them. To date, this program has helped reduce molybdenum influent levels by approximately 40% since 1995.
Mercury	Mercury is a heavy metal which (in certain chemical forms) can be highly toxic and is known to bioaccumulate (build up) in fish and (potentially) humans and marine mammals who consume these fish. While mercury is found in very small amounts in a number of products, MWRA has identified hospitals, dental facilities (using dental amalgams) and several commercial and household products (cleaners and disinfectants) as key sources to our system. Mercury also is contributed in significant amounts by rain events, through atmospheric deposition of mercury which is released as a result of municipal incinerators and fossil fuel plants.	TRAC has been working with known mercury sources on a variety of programs, including extensive research with Boston- area hospitals on pretreatment options and control options for mercury disposal and control in hospital facilities. In addition, a pollution prevention outreach program to test systems that collect and recycle dental amalgam is being implemented. MWRA is also working nationally with other city wastewater treatment plants to address the mercury sources found in many commonly used industrial and commercial products, through education and outreach.
Copper	Copper levels in MWRA's fertilizer pellets have sometimes exceeded the most-stringent state standards for reuse. Because MWRA's water supply is somewhat corrosive to water pipes, copper is leached from residential and other service pipes, eventually ending up in MWRA's wastewater. Copper can also be contributed through improper treatment and discharge of vehicle washing and cleaning activities. It is also found in many commercial and industrial chemicals, such as root-killers and paint pigments.	MWRA has undertaken a multi-pronged effort to address copper. Current actions include: Increased sampling of industrial permittees for copper Optimized corrosion control of the water supply Testing of currently unregulated sources (e.g. car washes, boilers, cooling towers) to determine copper levels and (if necessary) additional regulatory controls
Lead	Lead is a heavy metal which has been found in MWRA pellets at concentrations which sometime exceed the Mass. DEP's most stringent standards for reuse. Lead, like copper, is commonly used in older residential and service pipes, and is thus susceptible to leaching into the water supply. Lead may also be contributed from storm water runoff as well as some types of metal processing operations.	TRAC decreased the allowable limit for industrial dischargers from 0.4 mg/l to 0.2 mg/l in 1992, and MWRA Waterworks Division installed an Interim Corrosion Control Facility in 1997. At this facility, Sodium Carbonate (Soda Ash) and CO2 (Carbon Dioxide) are added to increase the water's buffering capacity. MWRA has also adjusted the pH of the water. These changes are helping to reduce the lead levels found in tap water (and eventually discharged to Deer Island).
PCBs	EPA and the National Marine Fisheries Service (NMFS) have expressed concern that PCBs (polychlorinated biphenyls) can harm fisheries and marine mammals. Current levels of PCBs in Mass Bay exceed EPA human health criteria. As a result, PCBs are a key focus of the proposed new discharge permit for the Deer Island Treatment Plant, and TRAC has prepared a pollution prevention (P2) plan to control and reduce the amounts of PCBs discharged to the sewer. This plan is under review by EPA and DEP.	MWRA currently prohibits the discharge of PCBs, and these pollutants are not generally found in any current industrial processes. Although Deer Island influent sampling generally does not detect PCBs, they are assumed to be contributed through contaminated groundwater and storm water runoff. (EPA estimates that 85% of the PCB loading to Mass Bay comes from atmospheric deposition.) TRAC's P2 plan is expected to focus on cooperative efforts to find groundwater sources to the MWRA sewer and a sampling program to ensure that potential commercial and industrial sources are adequately controlled.

The MWRA/Hospital Mercury Workgroup is a cooperative effort between TRAC and area hospitals and medical facilities to reduce the discharge of mercury-containing products from hospitals to the sewer system. This workgroup identified mercury in many products which have commonly been used in hospitals and other medical facilities, such as blood test reagents and cleaning products. The workgroup has actively researched mercury-free alternatives to many of these products, and developed a mercury products database which is available to area hospitals and other interested parties. The workgroup also:

TRAC worked extensively with the Medical And Scientific Community Organization (MASCO), which represents the Longwood-area medical facilities, on these studies. Reports of the workgroups and database can be found on the MASCO Web Site (www.masco.org).To date, this cooperative effort has resulted in a significant decrease in mercury concentrations from these facilities. Average mercury discharge concentrations have decreased from approximately 22 ug/l (parts per billion) in 1994 to 2 ug/l during calendar year 1999. Mercury levels in MWRA sludge are currently at some of the lowest levels recorded, roughly 60% below the DEP's most stringent standard for beneficial reuse of biosolids (fertilizer pellets). MWRA will maintain its current mercury prohibition and implement an enforcement approach which considers discharge levels at or below 1 ppb to be in compliance with the mercury prohibition. TRAC will focus its enforcement efforts on facilities that significantly exceed the 1 ppb standard.

In view of these data, MWRA has been working with the Massachusetts Dental Society (MDS) to increase awareness among dentists of the environmental impacts of wastes from dental facilities. A guidance document, Dentistry and the Environment, details ways dentists can reduce their discharge of mercury and other metals of concern. This brochure is being distributed to dental facilities and other interested parties in the service area. In addition, TRAC is participating in a series of workshops to promote new approaches to dental practices which reduce discharges of toxic metals to the sewer system. TRAC is currently working with MDS and area dental schools on a pilot program to test promising amalgam collection and recycling systems in dental facilities.

TRAC has primarily used a individual, regulatory approach to address toxics through a combination of issuing permits, inspecting facilities, sampling their wastestreams, and taking any needed enforcement actions. These actions can range from informal notices of violation for initial violations, to penalty assessments and/or permit revocation for drastic and unlawful violation of MWRA discharge limits. This individual permit approach has been very effective in reducing the majority of industry's pollutant loads, and continues to be TRAC's primary mission.

However, there are some large groups of sewer users who discharge low volumes individually, but can contribute, as a group, considerable pollutant loadings. The sheer number of these facilities make it difficult and inefficient to permit individually. For example, research has shown that the majority of molybdenum in our system comes from a corrosion control agent used in air conditioning cooling towers in residential, commercial and industrial buildings. There are approximately 10,000 such facilities in operation in the MWRA district.

Rather than permit these facilities individually, TRAC is working with these facilities and the companies that supply the corrosion control agent to switch to an agent that does not contain molybdenum. TRAC is taking a similar voluntary approach to controlling the discharges from the estimated 800 dental facilities which discharge to our system, by encouraging the proper use and collection of dental amalgam materials. Other sources, such as households and urban runoff, will require education, outreach, and interagency cooperation, in order to achieve greater pollutant reductions.

TRAC is working on a variety of control strategies to reduce their contribution of toxics to the sewer system. TRAC is encouraged by the early efforts on the part of all these groups to cooperate in this effort. The benefit of this approach is that TRAC can provide a more comprehensive approach to toxics control (using both regulatory and non-regulatory methods) for a greater number of sewer users in the MWRA service area.