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Massachusetts Water Resources Authority Industrial Waste Report

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Massachusetts Water Resources Authority Industrial Waste Report Massachusetts Water Resources Authority Industrial Waste Report October 2014 Industrial Waste Report # 30 Industrial Waste Report Number 30 October 2014 Frederick A. Laskey Executive Director Michael J. Hornbrook Chief Operating Officer Carolyn McAvoy Fiore Deputy Chief Operating Officer John Riccio Director, Toxic Reduction and Control Tracy McGrath Program Manager, Compliance MASSACHUSETTS WATER RESOURCES AUTHORITY NPDES Permit Number MA0103284 State Permit Number M-44 NPDES Permit Number MA0100404 State Permit Number M-139 FY 2014 Annual Report Table of Contents Executive Summary ..........................................................................................................1 I. Pretreatment Program Activities and Results ...................................................................3 Industrial Users .................................................................................................................3 Permitting ..........................................................................................................................4 Inspections ........................................................................................................................4 Monitoring ........................................................................................................................5 Enforcement ......................................................................................................................6 Information Systems .........................................................................................................6 Legal Support ....................................................................................................................6 Local Limits ......................................................................................................................7 Emergency Response ........................................................................................................7 Pass-Through and Interference .........................................................................................9 Pretreatment Program Resources ....................................................................................10 Budget .............................................................................................................................10 Program Cost Recovery ..................................................................................................10 II. Pollutant Analysis and Comparison to Environmental Standards ..................................11 Priority Pollutant Scans...................................................................................................11 Toxicity ...........................................................................................................................13 Residuals Quality ............................................................................................................14 FY 2011 Annual Report Table of Appendices A. SIU Data: Permit number and date issued Sample location descriptions Reasons for SIU status SNC Status Inspection and monitoring dates Enforcement actions Enforcement actions Deadline for compliance with schedules NOV dates Administrative order dates Filing dates for criminal/civil suits Dates and amounts of penalties assessed B. Non-SIU Permitted Industrial Sewer Users Permit category Sample location descriptions Sampling requirements Discharge violations Enforcement actions C. Significant Industrial Users in Significant Noncompliance D. Former Significant Industrial Users E. Gas/Oil Separator Warning Letters F. Penalties Assessed and Collected G. TRAC Staff H. Priority Pollutant Scan Results and Comparison of Influent and Effluent to Established standards Deer Island I. Priority Pollutant Scan Results and Comparison of Influent and Effluent to Established standards Clinton J. Effluent Toxicity Test Results K. Comparison of Sludge Quality to EPA and State Standards L. Summary of EPA program statistics and EPA industrial Pretreatment Program Summary Report Form - Metropolitan Boston Service Area, Clinton Service Area M. Local Limits - Metropolitan Boston Service Area, Clinton Service Area Executive Summary This Industrial Pretreatment Program Annual Report is provided pursuant to 40 CFR 403.12(i) and Massachusetts Water Resources Authority’s (MWRA’s) National Pollutant Discharge Elimination System Permit numbers MA0103284 and MA0100404. It covers the reporting period of July 1, 2014 through June 30, 2014 (FY14). Executive Summary and Program Highlights The FY14 report documents MWRA’s ongoing efforts to implement the requirements of 40 CFR Part 403, General Pretreatment Regulations. Some highlights from TRAC’s FY14 activities in the metropolitan Boston and Clinton sewer services areas include: Significant Industrial Users: The number of facilities designated as Significant Industrial Users (SIUs) in MWRA’s sewer service areas at any time during FY14 was 214, three of which discharged to the Clinton Wastewater Treatment Plant. At the end of the fiscal year, the number of SIUs was 204. TRAC staff inspected 214 SIUs. TRAC staff sampled 185 SIUs; 6 SIUs were not monitored because either they did not discharge during the year, or were re-categorized as non-SIUs before they could be sampled. The number of SIUs in Significant Noncompliance (SNC) in FY14 was 33, a decrease compared to FY13. At the end of the reporting period, however, there were only 5 SIUs in SNC. Permitting: TRAC issued or renewed a total of 376 industrial permits during FY14, including 97 to SIUs. 88% of the SIU permits were issued within 120 days of their application received dates or previous expiration dates, whichever was later, and 98% were issued within 180 days. Monitoring and Inspections: TRAC staff completed 1,498 sampling events at industrial/commercial facilities, and 1,690 non-industrial sampling events (e.g. Combined Sewer Overflow and other special projects events). TRAC staff also completed a total of 953 inspections of industrial facilities, 641 inspections of oil/water separators at vehicle maintenance facilities and other garages; and 248 inspections of septage haulers and septage receiving sites. Enforcement Program: TRAC issued a total of 217 early enforcement actions (Notices of Violations and Traps Warning Letters), and 29 higher-level enforcement actions (Notices of Noncompliance, Orders and Penalty Assessment Notices) to industrial and commercial facilities. 111 of the Notices of Violation were issued to SIUs, and 9 higher level actions were issue to SIUs. TRAC assessed a total of $ $64,250.00in penalties against permitted sewer users ($ 63,250.00 to SIUs), and collected a total of $120,450.00 in penalties during the fiscal year ($115,450.00 from SIUs). Staffing: Several personnel actions within TRAC led to turnover during FY14; as of mid-October, TRAC has completed filling all except one Sampling Associate position. This is in process currently and expected to be filled by the end of October, resulting in a full complement of staff. 1 This page left intentionally blank. 2 Section I. Pretreatment Program Activities and Results A detailed accounting of the pretreatment program activities and accomplishments for MWRA’s Industrial Users (including Significant Industrial Users), during FY14 is presented below. Appendix A contains information on MWRA’s SIUs, and provides, in its Key, criteria for SIU status and compliance status codes. The Appendix provides information about why the facility is a SIU and whether it is in compliance with reporting requirements, categorical standards and local limits, dates of MWRA inspections and monitoring events for each facility, and what, if any, enforcement actions were taken by MWRA against the facility. Appendix B details all permitted industrial users not classified as SIUs. The information includes a description of the sampling locations and sampling requirements for each industry, any discharge violations during the year, and all enforcement actions taken against them during the year. Each SIU is inspected at least once per fiscal year and each SIU with a discharge to the sewer system is sampled at least once per fiscal year. Statistics on MWRA’s Significant Industrial Users (SIUs) and the number of SIUs in Significant Noncompliance (SNC) for FY14 for the Clinton and the metropolitan Boston areas are summarized below. The list of SIUs in SNC can be found in Appendix C. Industrial Users in FY14 Total number of permitted industrial users = 1192 The number of SIUs = 214 (3 in Clinton) The number of SIUs on June 30, 2013 = 204 (3 in Clinton) The number of SIUs that were categorical industrial users (CIUs) = 79 (1 in Clinton) Industries categorized as SIUs because of process flows of at least 25,000 gpd = 59 Industries categorized as SIUs for potential to violate (PTV) = 108 The number of SIUs in SNC = 33 The number SIUs in SNC last fiscal year = 37 The number of industries in SNC for reporting violations only = 10 The number of industries in SNC for reporting violations only for last fiscal year = 6 Number of SIUs in SNC for discharge violations = 21 Number of SIUs in SNC for other violations = 2 MWRA continues to hold annual educational meetings with SIUs to review and reinforce methods for staying in compliance. The FY 14 meetings were held at MWRA’s Chelsea Facility in May 2014. Attendees heard seminars on topics of interest in toxic reduction and control from MWRA staff and from the Toxic Use Reduction Institute at UMASS Lowell.
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