Wastewater Practices: Organic Chemical Discharge
Introduction
The Massachusetts Water Resources Authority (MWRA) regulates the use and operation of the sewerage system for Harvard's Allston, Cambridge and Longwood campuses. Because the MWRA is charged with ensuring the improvement of water quality in Boston Harbor, discharge permit requirements are becoming increasingly stringent. Considerable emphasis is now being placed on the monitoring of industrial and institutional sources, including Harvard. MWRA permits issued to Harvard for wastewater discharge include stringent requirements for operation and maintenance of wastewater pretreatment systems, sampling and analysis of wastewater discharges, records keeping, routine reporting and notification of non-complying discharges.
Facilities having patterns of non-compliance with MWRA regulations are subject to significant enforcement action.
Laboratories may be significant users of toxic organics (e.g. solvents), which cannot be treated by conventional wastewater treatment systems. The discharge of many of these chemicals is regulated by the MWRA as well as by hazardous waste regulations. These toxic organics (also known as TTOs) must be prevented from sink disposal and must be disposed of as hazardous waste.
This fact sheet identifies only those key toxic organic chemicals whose disposal is specifically regulated by the MWRA. The fact sheet does not list all chemicals that are subject to MWRA disposal regulations; nor are all hazardous wastes included in this factsheet. Contact your local EH&S representative for assistance in determining hazardous waste disposal requirements.
Definitions:
Hazardous waste
includes solids, liquids and gases that possess a hazardous characteristic (e.g. toxic, corrosive, ignitable or reactive), or substances that are specifically listed as hazardous waste by the EPA or DEP on the basis of their usage or chemical constituents. DEP regulations include specific methodology for the identification of hazardous waste.
Total Toxic Organics
(TTO) include substances for which the MWRA discharge limit is generally one milligram per liter.
Applicable University Policy
Harvard University Environmental and Safety Management Policy
Applicable Regulation
310 CMR 30.000, "Hazardous Waste"
360 CMR 10.000, "Sewer Use"
Summary of Requirements
The MWRA specifically regulates the disposal of toxic organic chemicals (TTOs) to the sewer system. Harvard is required to routinely analyze its wastewater discharge for the presence of over 30 of these chemicals. TTO discharge is limited to a concentration limit of one milligram per liter (one part per million), effectively constituting a discharge prohibition on these listed substances. For this reason, TTOs should be disposed of as hazardous waste. Contact your local EH&S representative for assistance with disposal practices.
Training
It is recommended that laboratory and operations personnel be trained in the above discharge requirements.
Reporting
The Cambridge/Allston and Longwood campuses are each subject to quarterly sampling and analysis of wastewater effluent from several discharge locations.
Non-complying discharges must be reported to the MWRA and resampling must be performed to demonstrate compliance with wastewater discharge requirements. Preparation of discharge reports is the responsibility of EH&S.
Recordkeeping
Discharge reports must be maintained for a period of three years. Records are maintained by EH&S.
