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Quarter 2 - Massachusetts Water Resources Authority

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Toxic Reduction and Control2nd <strong>Quarter</strong> - FY13400Inspections, Monitoring Events, Permits Issued, Year to DateEPA Required SIU Monitoring Eventsfor FY13: 180YTD : 122350300372Required Non-SIU Monitoring Eventsfor FY13: 67YTD : 23250200150180203192SIU Connections to be SampledFor FY13: 372YTD: 284EPA Required SIU Inspectionsfor FY13: 203YTD: 92100506764SIU Permits due to ExpireIn FY13: 64YTD: 200Non-SIU Permits due to ExpireSIUs MonitoredNon-SIUsSIU ConnectionsSIUs Inspected SIU Permits Issued Non-SIU PermitsMonitoredSampledIssuedfor FY13: 192YTD: 81Significant Industrial Users (SIUs) are MWRA's highest priority industries due to their flow, type of industry, and/or their potential to violate limits. SIUsare defined by EPA and require a greater amount of oversight. EPA requires that all SIUs with flow be monitored at least once during the fiscal year.The “SIU Monitored” data above reflects the number of industries monitored in the month. However, many of these industries have more than onesampling point and the “SIU Connections Sampled” data reflect samples taken from multiple sampling locations at these industries.TRAC's annual monitoring and inspection goals are set at the beginning of each fiscal year but they can fluctuate due to the actual number of SIUs atany given time. During the course of the year, some SIUs do not discharge and cannot be monitored TRAC also monitors one-third of the non-SIUseach year.SIU and Non-SIU permits are issued with durations of two to five years, depending on the category of industry, varying the number of permits that expirein a given year.Number of Days to Issue a Permit0 to 120 121 to 180 181 or more Total Permits IssuedSIU Non-SIU SIU Non-SIU SIU Non-SIU SIU Non-SIUJul 2 8 0 0 0 0 2 8Aug* 1 9 1 0 0 0 2 9Sep 1 8 0 1 0 1 1 10Oct 4 25 0 2 0 1 4 28Nov 6 13 0 1 0 1 6 15Dec 4 9 1 0 0 2 5 11Jan 0 0Feb 0 0Mar 0 0Apr 0 0May 0 0Jun 0 010005000Copper Concentrations in Biosolids (mg/l)J F M A M J J A S O N DCopper DEP Type 1 Limit Previous 12 Months% YTD 90% 89% 10% 5% 0% 6% 20 81EPA requires MWRA 18 to 72 issue or renew 2 90% 4 of SIU permits 0 within 5 120 days 20 of 81receipt of the application or the permit expiration date - whichever is later. EPAalso requires the remaining 10% of SIU permits to be issued within 180 days.In Q2 of FY13, one SIU permit was issued more than 120 days but less than 180days after receipt of its application while staff reviewed issues related to itscompliance status. Seven non-SIU permits were issued more than 120 days afterreceipt of their applications: three issued in less than 180 days and four weredelayed for more than 180 days. Delays were attributable to issues related to i) thedetermination of their permit categories ii) the payment of permit charges and iii)other processing considerations.i350Lead Concentrations in Biosolids (mg/l)300250200150100500J F M A M J J A S O N DCopper, lead, and molybdenum are metals of concern for MWRA as theirconcentrations in its biosolids have, at times, exceeded regulatory standards forunrestricted use as fertilizer. Cooling tower usage typically causes a seasonalspike in molybdenum concentrations due to the blowdown on large AC systemsthat use corrosion inhibitors containing molybdenum. Levels drop again followingthe end of the cooling season, although this is delayed due to biosolidsprocessing time. The hotter the season, the higher the spike. TRAC has anongoing program to persuade cooling tower operators to switch to phosphatebasedcorrosion inhibitors.In Q2 of FY13, levels of molybdenum again exceeded the DEP type 1 Limit due toa warmer summer in 2012. MWRA and its contractor (NEFCO) do not distributeproduct in <strong>Massachusetts</strong> between July and January under its approval ofsuitability.80706050403020100Lead DEP Type 1 Limit Previous 12 MonthsMolybdenum Concentrations in Biosolids (mg/l)J F M A M J J A S O N DMolybdenumDEP Type 1 LimitEPA Interim LimitPrevious 12 Months11

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