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.
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
TRAC permit applications and instructions are available for download on our TRAC Permits page.
Incentive and Other Program Charges
In MWRA’s Toxic Reduction and Control Department established permitting and monitoring charges for all Sewer Use Discharge Permits (SUDPs). The charges are explained in the Sewer Use Regulations (360 CMR 10.101-10.104).
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.
Reports and Studies
Dental Facilities Study - Study found that dental facilities are significant source of mercury in the MWRA waste stream.
TRAC Organization and Contacts
Thomas J. Coffey, Jr.
Compliance Coordinators and Industrial Coordinators by Municipality
Industrial Coordinators are responsible for inspecting and permitting to industrial users in that municipality. Contact List (PDF)
Compliance Coordinators are responsible for issuing Notices of Violation and overseeing escalated enforcement actions. Contact List (PDF)
Pretreatment Program and Federal Clean Water Act
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.
Frequently Asked Questions
How does TRAC oversee industries in MWRA's service area?
MWRA's sewer service area is divided into three regions (North, Central, and South).
SAMPLING ASSOCIATES AND COMPLIANCE COORDINATORS
How does TRAC regulate industry?
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.
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.
How are TRAC's costs recovered?
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:
A company can reduce its monitoring charge by reducing the volume of certain constituents of its discharge. SIUs require the greatest amount of oversight and have the highest potential to violate regulations, so their charges are high; group and general permits require a minimal level of staff effort to issue, and therefore have the lowest permit charges.
Which pollutants create the most concern for TRAC?
What is the MWRA/Hospital Mercury Workgroup?
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.
Why is TRAC working with area dentists?
MWRA sampling of area dental facilities indicate that these dischargers can contain high loads of mercury and other metals which result from the installation and removal of dental amalgam. MWRA's April 1997 report, Mercury in Dental Facilities, estimates that at least 13% (perhaps much more) of the mercury load coming to Deer Island results from dental facilities. This percentage is consistent with studies done at several other POTWs nationally, and is roughly equivalent to the amount contributed by all other MWRA permitted facilities.
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.
What methods does TRAC use to reduce discharges of toxics?
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.
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Updated March 11, 2021