Any company that discharges industrial waste into the Massachusetts Water Resources Authority (MWRA) Sewerage System, or whose operation within the MWRA Sewerage District is subject to a National Categorical Pretreatment Standard, is required to have a Sewer Use Discharge Permit issued by the MWRA and the municipality in which the sewer user’s discharge is located. A company that has a relatively low volume of discharge to the sewer and no reasonable potential to violate an MWRA discharge limit may qualify for a Low Flow Discharge Permit. Companies that are eligible for this permit include those with no regulated parameters and flows less than 25,000 gallons per day; and those whose discharge is 300 gallons per day or less with pollutant levels above background (but below MWRA discharge limits), without the need for pretreatment.

Because of the fee structure established by the Toxic Reduction and Control department (TRAC), companies can benefit financially by qualifying for a Low Flow/Low Pollutant Discharge General Permit. TRAC charges (1) a permitting charge, which covers the cost of inspecting a facility and issuing a permit and is determined by the company’s category, which in turn is determined by the volume of the company’s flow to the sewer, and its potential impact on the sewer system and (2) a monitoring charge. A company can reduce its monitoring charge by reducing the volume of toxins in its discharge. Under this fee structure, companies that require the greatest amount of oversight and pose the greatest
threat of violating regulations incur the highest charges. Companies that qualify for group and general permits require a minimal level of staff oversight and therefore have the lowest permit charges. As such, it is beneficial to the environment and to the applying company to qualify for a Low Flow/Low Pollutant Discharge General Permit, according to the following steps:

1) Complete and file a Sewer Use Discharge Permit Application and a Low Flow/Low Pollutant Discharge General Permit Application Addendum. The Application and the Addendum must be filed with the MWRA in Chelsea, MA and the City of Cambridge Commissioner of Public Works (if other than Cambridge, the municipality in which the sewer user’s discharge is located). Note: if your facility is either a treatment, storage or disposal facility or level III recycler under the Massachusetts hazardous waster regulations, a third copy must be sent to the Massachusetts Department of Environmental Protection (MADEP).

2) If your facility has a pretreatment system, submit to the MADEP Board of Certification in Milbury, MA a classification of your pretreatment system by completing a Pretreatment Facility Grading Report Form prior to or contemporaneously with the filing of the Application and the Addendum. Include a process flow diagram of the pretreatment system.

Cambridge Department of Public Works
Attn: Lisa Peterson, Commissioner of Public Works or
Owen O’Riordan, Assistant Commissioner of Engineering

147 Hampshire Street
Cambridge, MA 02139
Phone: (617) 349-4800

Massachusetts Department of environmental Protection
One Winter Street
Boston, MA 20108

Board of Certification
DEP Training Center
Route 20
Milbury, MA 01527

Carolyn Fiore, Director
Phone: (617) 305-5633
Email: carolyn.fiore@mwra.state.ma.us

Tracy McGrath, Enforcement Coordinator
Phone: (617) 305-5647
Email: tracy.mcgrath@mwra.state.ma.us

** Peter Yarossi, Regional Manager, Industrial Coordinators
Phone: (617) 305-5671
Email: peter.yarossi@mwra.state.ma.us
** Peter Yarossi is your primary contact person

Cambridge Department of Public Works
Lisa Peterson, Commissioner
Phone: (617) 349-4806

Contact the Toxic Reduction and Control Operations Division at 617-242-6000. The forms are not available online.

2) Who can sign the Sewer Use Discharge Permit Application?

An Authorized Representative. For a corporation, one of its officers (e.g., president, secretary, treasurer or vice-president), as long as he or she is in charge of a principal business function of the corporation. For a partnership or sole proprietorship, its general partner or proprietor respectively.

3) When must the Sewer Use Discharge Permit Application be submitted?

For a pre-existing permit, you must submit a completed application no later than sixty (60) days before your current permit expires in order for your current permit to remain in effect pending a decision on your new application. For a new permit, the application must be submitted and the permit issued prior to discharge.

4) What if a question on the Sewer Use Discharge Permit Application does not apply to my operations?

Simply write “N/A” in the space provided. Do not leave the question(s) blank as the application may be deemed incomplete and sent back to you for additional information.

5) Who may request a MWRA Low Flow /Low Pollutant Discharge General Permit?

In general, an applicant that discharges less than 300 gallons per day and has no reasonable potential to violate MWRA sewer use discharge limits OR an applicant that discharges less than 25,000 gallons containing no pollutants regulated by the MWRA. 360 CMR 10.062 contains the specific qualifications and/or disqualifications.

6) How can I obtain a Pretreatment Facility Grading Report Form from the MADEP?

Contact the MADEP Northeast Regional Office at 617-654-6500. The form is not available online.

7) Is there a cost to file either (i) the Sewer Use Discharge Permit Application and Low Flow/Low Pollutant Discharge General Permit Application Addendum, or (ii) the Pretreatment Facility Grading Report Form?

(i) There is no cost for filing the application. However, when and if a permit is drafted, a permit charge is sent to the applicant. Permit charges vary depending on the type of permit issued.
(ii) There is no cost for filing a Pretreatment Facility Grading Report Form.

8) How long should I expect to wait before getting a response from (i) the MWRA, (ii) the MADEP, and (iii) the City of Cambridge Commissioner of Public Works?

(i) Generally a permit is ready to be issued in about two (2) months (give or take 30 days depending upon the complexity of the facility).
(ii) Generally it takes between one (1) and two (2) months for the MADEP to respond.
(iii) You should expect a response from the Commissioner of Public Works Office within one (1) month.

2) 360 CMR 10.052: Requires every person seeking a Sewer Use Discharge Permit to file a complete application with the MWRA and the Municipality. If the application is incomplete or insufficient, the MWRA may deny the application or request additional information.

3) Pursuant to 360 CMR 10.062 a person is eligible for and must be covered by the General Permit for a facility that meets one of the following criteria:
(i) It discharges less than an average of 25,000 gallons per day of waste water to the sewer (excluding sanitary, non contact cooling, and boiler blowdown wastewater) and its processes would result in a sewer discharge of before pretreatment and dilution not containing a substance regulated by 360 CMR 10.022 through 10.024;
(ii) It discharges less than an average of 300 gallons per day of waste water to the sewer (excluding sanitary, noncontact cooling, boiler blowdown, and incoming water treatment reject stream waste water) and does not require an active pretreatment system to meet the requirements of 360 CMR 10.021 through 10.025, except it may adjust the pH discharge requirements if it: (a) has an automatic alarm and chart recorder or electronic memory on its pH adjustment system, or (b) discharges in batches, treats each batch if necessary to meet pH discharge requirements, and tests each batch to confirm that it meets pH requirements; and (c) does not otherwise have a reasonable potential to violate 360 CMR 10.021 through 10.025.

4) To determine the average daily discharge amount of a facility, the amount of waste water discharged on each calendar day in an ordinary week shall be totaled and then divided by the number of days in the week during which a discharge occurred. The preceding 12 months of a facility’s operations shall be used to determine a facility’s ordinary week, except a more current time period shall be used if the facility’s average amount of discharge changed within the past 12-months or began more recently. 360 CMR 10.062 (b) (3).

5) The only industrial waste that 360 CMR 10.062 and the General Permit authorize a facility to discharge to the MWRA sewer system is from the processes generating waste water as noted in the Permit Application submitted to request coverage by the General Permit. A facility covered by the General Permit shall not discharge wastewater that would make it ineligible for the General Permit.

6) 360 CMR 10.062 (5)-(7) imposes additional requirements on Photo Processing and Printing Operations, Laboratories, and Facilities required to have grease traps that are seeking a General Permit.

7) A person with a General Permit must notify the MWRA in writing at least 30 days before it closes or moves a facility covered by the General Permit, changes its facility’s operations such that the discharge will change so that the facility may no longer be eligible for the General Permit, or makes any other substantial change in the volume of character of its facility’s discharge. See 360 CMR 10.062 (8).

8) If a change in the volume or character of a facility’s discharge will make it ineligible for coverage by the General Permit, the person must obtain the applicable MWRA permit for the facility before beginning the change discharge. See 360 CMR 10.062 (9).

9) A person with a General Permit for a facility must keep for at least 5-years all hazardous waste manifests it has hauled from its facility and make a copy of the documents available to the MWRA upon request. See 360 CMR 10.062 (10).

MWRA

MWRA Toxic Reduction and Control Department

Massachusetts Department of Environmental Protection