Janice Markey- Compliance Manager
Wastewater Management Team

Completing your Sewer Use Discharge Permit Renewal Application provides an opportunity to check your compliance with DEP and MWRA hazardous waste regulations.

• The MWRA requires you list and estimate the liquids or sludge amounts removed from your facility each year. This information is easily gathered from a call to your local waste removal vendor(s) or by reviewing your hazardous waste manifests.
• The MWRA also requires that you submit recent hazardous waste manifests for each chemical you list. Be sure to double-check that you have not missed a chemical!
• Note discrepancies in your chemical inventory versus hazardous waste lists; e.g. purchasing large chemical quantities that are not removed from the facility or disposal of chemicals not on your chemical inventory list. These discrepancies can be perfectly legitimate, like your chemical reacted to form a product, but you should be aware of them.
• If you are a large quantity generator, you may submit an annual DEP Waste Summary report in place of the hazardous waste manifests.
• While reviewing your hazardous waste manifests, check you sent out copies to the proper authorities.
• Massachusetts has additional and specific rules you must abide by including:
  • The DEP requires you to maintain hazardous waste manifest for at least three years.
  • The MWRA will also ask you if you have spill plans, toxic organic management plan, source reduction plan, etc.
• Since you have already done much of the work, you may as well double-check your generator status. Did you generate more or less this year? Should you be in a different category? Be proactive and figure it out before the DEP does.

Tune in next month for a discussion on system Grading Reports and Staffing Plans as they pertain to your permit application…