MASSACHUSETTS WATER RESOURCES AUTHORITY

Chelsea Facility 2 Griffin Way

Chelsea, Massachusetts 02150 Telephone: (617) 242-6000 Facsimile: (617) 371-1604

ELECTRONIC MAIL

VA Boston Healthcare System c/o VA Healthcare System Brockton 940 Belmont Street Brockton, MA 02301

Subject: Permit #: 56005702 MWRA Category: 02 SIU Permit Expiration Date: 07/15/2027

Attention: Mr. John Hughes

Dear Mr. Hughes:

Enclosed please find a Massachusetts Water Resources Authority (MWRA) Discharge Permit for your facility located at 1400 VFW Parkway, West Roxbury, MA 02132. Your permit is based on our review of your MWRA Sewer Use Discharge Permit Application, results of any inspection and/or monitoring activities conducted at your facility, and any other information on file with the MWRA.

The permit is valid until its date of expiration unless revoked or suspended by MWRA. It is subject to renewal and modification as authorized by the MWRA's Sewer Use regulations, 360 C.M.R. § 10.000.

The permit authorizes you to discharge certain wastewaters to the sewer system and provides important information.

All of the requirements and conditions of the permit are effective immediately so please read the permit upon receiving it. A table of contents has been provided to help you locate information within your permit.

If you disagree with any of the terms and conditions of this permit, you may, pursuant to 360 C.M.R. §§ 2.21(1) and 10.007(8), appeal those terms and conditions by submitting a written request for reconsideration to the MWRA Toxic Reduction and Control Program within ten (10) working days from the issued date of this permit. The request shall set forth in detail the facts supporting it.

If you have any questions pertaining to the permit's terms and conditions or any information set forth in this letter, please contact Kenneth Cunningham, Industrial Coordinator, Toxic Reduction and Control, at (617) 305-5623.

Sincerely, Matthew J. Dam Director of Toxic Reduction and Control

Enclosures

ISSUED: 18-SEP-2023

MASSACHUSETTS WATER RESOURCES AUTHORITY

TOXIC REDUCTION AND CONTROL

2 Griffin Way Chelsea, Massachusetts 02150

Telephone: (617) 242-6000 Facsimile: (617) 371-1604

SEWER USE DISCHARGE PERMIT

ISSUED TO:

VA Boston Healthcare System 1400 VFW Parkway 138-S West Roxbury, MA 02132

Permit #: 56005702

Issuance Date:

Expiration Date: 07/15/2027

09/18/2023

Permit No: 56005702

Sewer Use Discharge Permit Table of Contents

Contents Self-Monitoring Requirements Summary ................................................................................................. ii

Discharge Limitations Summary .............................................................................................................. iv

Sample Location and Self-Monitoring Requirements

General Sampling and Analysis Requirements

Reporting Procedures for Self-Monitoring Requirements

Reports, Records and Devices You Must Maintain at Your Facility

Authorized Discharge

Sampling Records

When You Should Notify the MWRA

Mailing and Email Address for Reports and Notifications

Most Stringent Limitations

MWRA Discharge Limitations

Specific Prohibitions

Dilution Prohibition

Pretreatment

Bypass Prohibition

Right of Entry

Duty to Mitigate

Enforcement/Litigation Records

Posting Requirements

Confidentiality

Signatories

Disposal of Sludge and Hazardous Wastes

Severability

Penalty Provisions

Request for Reconsideration

Definitions of Sampling and Reporting Terms

SUMMARIES

ii

Self-Monitoring Requirements Summary

Sample Location Pollutant Frequency 0101 Copper (Total) Semi-Annual 0101 Cyanide (Total) Semi-Annual 0101 Flow Semi-Annual 0101 Formaldehyde Semi-Annual 0101 Mercury (Total) Semi-Annual 0101 Silver (Total) Semi-Annual 0101 TTO (Volatile Organic Fraction) Semi-Annual 0101 Zinc (Total) Semi-Annual 0101 pH Semi-Annual 0102 Copper (Total) Semi-Annual 0102 Cyanide (Total) Semi-Annual 0102 Flow Semi-Annual 0102 Formaldehyde Semi-Annual 0102 Mercury (Total) Semi-Annual 0102 Silver (Total) Semi-Annual 0102 TTO (Volatile Organic Fraction) Semi-Annual 0102 Zinc (Total) Semi-Annual 0102 pH Semi-Annual 0103 Chromium (Total) Semi-Annual 0103 Flow Semi-Annual 0103 Lead (Total) Semi-Annual 0103 Mercury (Total) Semi-Annual 0103 Nickel (Total) Semi-Annual 0103 pH Semi-Annual 0104 Chromium (Total) Semi-Annual 0104 Copper (Total) Semi-Annual 0104 Flow Semi-Annual 0104 Lead (Total) Semi-Annual 0104 Nickel (Total) Semi-Annual 0104 Zinc (Total) Semi-Annual 0104 pH Semi-Annual 0105 Chromium (Total) Semi-Annual 0105 Flow Semi-Annual 0105 Lead (Total) Semi-Annual 0105 Mercury (Total) Semi-Annual 0105 Nickel (Total) Semi-Annual 0105 pH Semi-Annual 0206 Chromium (Total) Semi-Annual 0206 Flow Semi-Annual 0206 Lead (Total) Semi-Annual

SUMMARIES

iii

Sample Location Pollutant Frequency 0206 Mercury (Total) Semi-Annual 0206 Nickel (Total) Semi-Annual 0206 pH Semi-Annual 0207 Copper (Total) Semi-Annual 0207 Flow Semi-Annual 0207 Lead (Total) Semi-Annual 0207 Mercury (Total) Semi-Annual 0207 Zinc (Total) Semi-Annual 0207 pH Semi-Annual

Semi-annual Schedule

Collect Your Samples During: Submit Your Report By:

January through June July 31 July through December January 31

SUMMARIES

iv

Discharge Limitations Summary

Listed below are many of the pollutants that are regulated by the MWRA. Your daily wastewater discharge to the sewer system from the following Sample Location(s) shall not violate the limits. Your complete set of discharge limitations, including those not listed below, is found in Part B of your Discharge Permit.

Sample Location: 0101

MWRA

Pollutant Daily Maximum Limit (mg/l)

1,1-Dichloroethylene 0.3 Acrolein 0.15 Antimony (Total) 10.0 Arsenic (Total) 0.5 Benzene 0.3 Cadmium (Total) 0.1 Chromium (+6) 0.5 Chromium (Total) 1.0 Copper (Total) 1.0 Cyanide (Total) 0.5 Each Toxic Organic (Unless Elsewhere Limited In 360 CMR 10.000) 1.0

Formaldehyde 9.0 Hexachlorobutadiene Prohibited Lead (Total) 0.2 Mercury (Total) Prohibited Nickel (Total) 1.0 PCB's Prohibited Pesticides Prohibited Phenol 5.0 Selenium (Total) 5.0 Silver (Total) 2.0

TTO 5.0

Vinyl Chloride (Chloroethylene) 0.02 Zinc (Total) 1.0

Sample Location: 0101

MWRA

Pollutant Instantaneous Limit (DEG C) Temperature 82

SUMMARIES

v

Sample Location: 0101

MWRA

Pollutant Instantaneous Limit (S.U.)

pH must remain between 5.5 - 12.0 standard units

Sample Location: 0101

MWRA

Pollutant Instantaneous Limit (mg/l) Oil and Grease 300

Sample Location: 0102

MWRA

Pollutant Daily Maximum Limit (mg/l) 1,1-Dichloroethylene 0.3 Acrolein 0.15 Antimony (Total) 10.0 Arsenic (Total) 0.5 Benzene 0.3 Cadmium (Total) 0.1 Chromium (+6) 0.5 Chromium (Total) 1.0 Copper (Total) 1.0 Cyanide (Total) 0.5 Each Toxic Organic (Unless Elsewhere Limited In 360 CMR 10.000) 1.0

Formaldehyde 9.0 Hexachlorobutadiene Prohibited Lead (Total) 0.2 Mercury (Total) Prohibited Nickel (Total) 1.0 PCB's Prohibited Pesticides Prohibited Phenol 5.0 Selenium (Total) 5.0 Silver (Total) 2.0

TTO 5.0

Vinyl Chloride (Chloroethylene) 0.02 Zinc (Total) 1.0

Sample Location: 0102

MWRA

SUMMARIES

vi

Sample Location: 0102

MWRA

Pollutant Instantaneous Limit (S.U.)

pH must remain between 5.5 - 12.0 standard units

Sample Location: 0102

MWRA

Pollutant Instantaneous Limit (mg/l) Oil and Grease 300

Sample Location: 0103

MWRA

Pollutant Daily Maximum Limit (mg/l) 1,1-Dichloroethylene 0.3 Acrolein 0.15 Antimony (Total) 10.0 Arsenic (Total) 0.5 Benzene 0.3 Cadmium (Total) 0.1 Chromium (+6) 0.5 Chromium (Total) 1.0 Copper (Total) 1.0 Cyanide (Total) 0.5 Each Toxic Organic (Unless Elsewhere Limited In 360 CMR 10.000) 1.0

Formaldehyde 9.0 Hexachlorobutadiene Prohibited Lead (Total) 0.2 Mercury (Total) Prohibited Nickel (Total) 1.0 PCB's Prohibited Pesticides Prohibited Phenol 5.0 Selenium (Total) 5.0 Silver (Total) 2.0

TTO 5.0

Vinyl Chloride (Chloroethylene) 0.02 Zinc (Total) 1.0

Sample Location: 0103

MWRA

SUMMARIES

vii

Sample Location: 0103

MWRA

Pollutant Instantaneous Limit (S.U.)

pH must remain between 5.5 - 12.0 standard units

Sample Location: 0103

MWRA

Pollutant Instantaneous Limit (mg/l)

Oil and Grease 300

Sample Location: 0104

MWRA

Pollutant Daily Maximum Limit (mg/l)

1,1-Dichloroethylene 0.3 Acrolein 0.15 Antimony (Total) 10.0 Arsenic (Total) 0.5 Benzene 0.3 Cadmium (Total) 0.1 Chromium (+6) 0.5 Chromium (Total) 1.0 Copper (Total) 1.0 Cyanide (Total) 0.5 Each Toxic Organic (Unless Elsewhere Limited In 360 CMR 10.000) 1.0

Formaldehyde 9.0 Hexachlorobutadiene Prohibited Lead (Total) 0.2 Mercury (Total) Prohibited Nickel (Total) 1.0 PCB's Prohibited Pesticides Prohibited Phenol 5.0 Selenium (Total) 5.0 Silver (Total) 2.0

TTO 5.0

Vinyl Chloride (Chloroethylene) 0.02 Zinc (Total) 1.0

Sample Location: 0104

MWRA

viii

Sample Location: 0104

MWRA

Pollutant Instantaneous Limit (S.U.)

pH must remain between 5.5 - 12.0 standard units

Sample Location: 0104

MWRA

Pollutant Instantaneous Limit (mg/l)

Oil and Grease 300

Sample Location: 0105

MWRA

Pollutant Daily Maximum Limit (mg/l)

1,1-Dichloroethylene 0.3 Acrolein 0.15 Antimony (Total) 10.0 Arsenic (Total) 0.5 Benzene 0.3 Cadmium (Total) 0.1 Chromium (+6) 0.5 Chromium (Total) 1.0 Copper (Total) 1.0 Cyanide (Total) 0.5 Each Toxic Organic (Unless Elsewhere Limited In 360 CMR 10.000) 1.0

Formaldehyde 9.0 Hexachlorobutadiene Prohibited Lead (Total) 0.2 Mercury (Total) Prohibited Nickel (Total) 1.0 PCB's Prohibited Pesticides Prohibited Phenol 5.0 Selenium (Total) 5.0 Silver (Total) 2.0

TTO 5.0

Vinyl Chloride (Chloroethylene) 0.02 Zinc (Total) 1.0

Sample Location: 0105

MWRA

ix

Sample Location: 0105

MWRA

Pollutant Instantaneous Limit (S.U.)

pH must remain between 5.5 - 12.0 standard units

Sample Location: 0105

MWRA

Pollutant Instantaneous Limit (mg/l)

Oil and Grease 300

Sample Location: 0206

MWRA

Pollutant Daily Maximum Limit (mg/l)

1,1-Dichloroethylene 0.3 Acrolein 0.15 Antimony (Total) 10.0 Arsenic (Total) 0.5 Benzene 0.3 Cadmium (Total) 0.1 Chromium (+6) 0.5 Chromium (Total) 1.0 Copper (Total) 1.0 Cyanide (Total) 0.5 Each Toxic Organic (Unless Elsewhere Limited In 360 CMR 10.000) 1.0

Formaldehyde 9.0 Hexachlorobutadiene Prohibited Lead (Total) 0.2 Mercury (Total) Prohibited Nickel (Total) 1.0 PCB's Prohibited Pesticides Prohibited Phenol 5.0 Selenium (Total) 5.0 Silver (Total) 2.0

TTO 5.0

Vinyl Chloride (Chloroethylene) 0.02 Zinc (Total) 1.0

Sample Location: 0206

MWRA

x

Sample Location: 0206

MWRA

Pollutant Instantaneous Limit (S.U.)

pH must remain between 5.5 - 12.0 standard units

Sample Location: 0206

MWRA

Pollutant Instantaneous Limit (mg/l)

Oil and Grease 300

Sample Location: 0207

MWRA

Pollutant Daily Maximum Limit (mg/l)

1,1-Dichloroethylene 0.3 Acrolein 0.15 Antimony (Total) 10.0 Arsenic (Total) 0.5 Benzene 0.3 Cadmium (Total) 0.1 Chromium (+6) 0.5 Chromium (Total) 1.0 Copper (Total) 1.0 Cyanide (Total) 0.5 Each Toxic Organic (Unless Elsewhere Limited In 360 CMR 10.000) 1.0

Formaldehyde 9.0 Hexachlorobutadiene Prohibited Lead (Total) 0.2 Mercury (Total) Prohibited Nickel (Total) 1.0 PCB's Prohibited Pesticides Prohibited Phenol 5.0 Selenium (Total) 5.0 Silver (Total) 2.0

TTO 5.0

Vinyl Chloride (Chloroethylene) 0.02 Zinc (Total) 1.0

Sample Location: 0207

MWRA

xi

Sample Location: 0207

MWRA

Pollutant Instantaneous Limit (S.U.)

pH must remain between 5.5 - 12.0 standard units

Sample Location: 0207

MWRA

Pollutant Instantaneous Limit (mg/l)

Oil and Grease 300

9/15/2023

09/18/2023

PART A – SAMPLING, REPORTING AND OTHER REQUIREMENTS

Sample Location and Self-Monitoring Requirements

Samples shall be taken of wastewater from the following specified locations. The permittee shall follow the sampling and reporting schedule(s) provided in this Part.

Sample Location 0101

Process wastewater from Building 3 West Side First & Second Floor Clinical and Research Labs shall be sampled from the west side outdoor trapezoidal flume after pH neutralization, prior to mixing with any other streams.

If the permittee did not discharge wastewater to the sanitary sewer system during the required sampling period, the permittee shall submit a letter so indicating by the reporting due date.

The MWRA recommends an EPA analysis method for each pollutant listed in the Sampling and Reporting Schedule(s). The method may be one of a few that are approved by the EPA for a specific pollutant. A certified laboratory may substitute another method which is listed in 40 C.F.R. Part 136 for the pollutant being analyzed or if approved or otherwise authorized by the MWRA and EPA.

For a definition of the terms in the table, refer to the Definitions of Sampling and Reporting Terms found at the end of this permit.

Sampling and Reporting Schedule for Sample Location 0101

Pollutant/Parameter Recommended EPA Analysis

Sample Type Frequency Reporting Frequency

Copper (Total) 200.7 Composite (flow) Semi-Annual Semi-Annual Cyanide (Total) 335.4 Grab Semi-Annual Semi-Annual Flow Field Composite (flow) Semi-Annual Semi-Annual Formaldehyde * 1667A Grab Semi-Annual Semi-Annual Mercury (Total) 245.1 Composite (flow) Semi-Annual Semi-Annual Silver (Total) 200.7 Composite (flow) Semi-Annual Semi-Annual TTO (Volatile Organic Fraction) 624.1 Grab Semi-Annual Semi-Annual Zinc (Total) 200.7 Composite (flow) Semi-Annual Semi-Annual pH SM 4500H+B Grab Semi-Annual Semi-Annual

*Formaldehyde must be analyzed using MWRAs High Performance Liquid Chromatography (HPLC) method.

PART A – SAMPLING, REPORTING AND OTHER REQUIREMENTS

Sample Location 0102

Process wastewater from Building 3 East Side First & Second Floor Clinical and Research Labs shall be sampled from the east side outdoor trapezoidal flume after pH neutralization, prior to mixing with any other streams.

If the permittee did not discharge wastewater to the sanitary sewer system during the required sampling period, the permittee shall submit a letter so indicating by the reporting due date.

The MWRA recommends an EPA analysis method for each pollutant listed in the Sampling and Reporting Schedule(s). The method may be one of a few that are approved by the EPA for a specific pollutant. A certified laboratory may substitute another method which is listed in 40 C.F.R. Part 136 for the pollutant being analyzed or if approved or otherwise authorized by the MWRA and EPA.

For a definition of the terms in the table, refer to the Definitions of Sampling and Reporting Terms found at the end of this permit.

Sampling and Reporting Schedule for Sample Location 0102

Pollutant/Parameter Recommended EPA Analysis

Sample Type Frequency Reporting Frequency

Copper (Total) 200.7 Composite (flow) Semi-Annual Semi-Annual Cyanide (Total) 335.4 Grab Semi-Annual Semi-Annual Flow Field Composite (flow) Semi-Annual Semi-Annual Formaldehyde * 1667A Grab Semi-Annual Semi-Annual Mercury (Total) 245.1 Composite (flow) Semi-Annual Semi-Annual Silver (Total) 200.7 Composite (flow) Semi-Annual Semi-Annual TTO (Volatile Organic Fraction) 624.1 Grab Semi-Annual Semi-Annual Zinc (Total) 200.7 Composite (flow) Semi-Annual Semi-Annual

*Formaldehyde must be analyzed using MWRAs High Performance Liquid Chromatography (HPLC) method.

PART A – SAMPLING, REPORTING AND OTHER REQUIREMENTS

Sample Location 0103

Process wastewater from the Supply Processing and Sterilization Department (SPS) shall be sampled from the standpipe to the Palmer-Bowlus flume in the corridor outside of the SPS, prior to mixing with any other streams.

If the permittee did not discharge wastewater to the sanitary sewer system during the required sampling period, the permittee shall submit a letter so indicating by the reporting due date.

The MWRA recommends an EPA analysis method for each pollutant listed in the Sampling and Reporting Schedule(s). The method may be one of a few that are approved by the EPA for a specific pollutant. A certified laboratory may substitute another method which is listed in 40 C.F.R. Part 136 for the pollutant being analyzed or if approved or otherwise authorized by the MWRA and EPA.

For a definition of the terms in the table, refer to the Definitions of Sampling and Reporting Terms found at the end of this permit.

Sampling and Reporting Schedule for Sample Location 0103

Pollutant/Parameter Recommended EPA Analysis

Sample Type Frequency Reporting Frequency

Chromium (Total) 200.7 Composite (flow) Semi-Annual Semi-Annual Flow Field Composite (flow) Semi-Annual Semi-Annual Lead (Total) 200.7 Composite (flow) Semi-Annual Semi-Annual Mercury (Total) 245.1 Composite (flow) Semi-Annual Semi-Annual Nickel (Total) 200.7 Composite (flow) Semi-Annual Semi-Annual

PART A – SAMPLING, REPORTING AND OTHER REQUIREMENTS

Sample Location 0104

Process wastewater from the Building 21 Animal Research Lab cage washer shall be sampled from the discharge pipe behind the hatch on the side of the cage washer, prior to mixing with any other streams.

If the permittee did not discharge wastewater to the sanitary sewer system during the required sampling period, the permittee shall submit a letter so indicating by the reporting due date.

The MWRA recommends an EPA analysis method for each pollutant listed in the Sampling and Reporting Schedule(s). The method may be one of a few that are approved by the EPA for a specific pollutant. A certified laboratory may substitute another method which is listed in 40 C.F.R. Part 136 for the pollutant being analyzed or if approved or otherwise authorized by the MWRA and EPA.

For a definition of the terms in the table, refer to the Definitions of Sampling and Reporting Terms found at the end of this permit.

Sampling and Reporting Schedule for Sample Location 0104

Pollutant/Parameter Recommended EPA Analysis

Sample Type Frequency Reporting Frequency

Chromium (Total) 200.7 Grab Semi-Annual Semi-Annual Copper (Total) 200.7 Grab Semi-Annual Semi-Annual Flow Field Grab Semi-Annual Semi-Annual Lead (Total) 200.7 Grab Semi-Annual Semi-Annual Nickel (Total) 200.7 Grab Semi-Annual Semi-Annual Zinc (Total) 200.7 Grab Semi-Annual Semi-Annual

PART A – SAMPLING, REPORTING AND OTHER REQUIREMENTS

Sample Location 0105

Process wastewater from the Building 21 Research Lab steam sterilizer shall be sampled from the sample spigot on the side of the sterilizer, prior to mixing with any other streams.

If the permittee did not discharge wastewater to the sanitary sewer system during the required sampling period, the permittee shall submit a letter so indicating by the reporting due date.

The MWRA recommends an EPA analysis method for each pollutant listed in the Sampling and Reporting Schedule(s). The method may be one of a few that are approved by the EPA for a specific pollutant. A certified laboratory may substitute another method which is listed in 40 C.F.R. Part 136 for the pollutant being analyzed or if approved or otherwise authorized by the MWRA and EPA.

For a definition of the terms in the table, refer to the Definitions of Sampling and Reporting Terms found at the end of this permit.

Sampling and Reporting Schedule for Sample Location 0105

Pollutant/Parameter Recommended EPA Analysis

Sample Type Frequency Reporting Frequency

Chromium (Total) 200.7 Grab Semi-Annual Semi-Annual Flow Field Grab Semi-Annual Semi-Annual Lead (Total) 200.7 Grab Semi-Annual Semi-Annual Mercury (Total) 245.1 Grab Semi-Annual Semi-Annual Nickel (Total) 200.7 Grab Semi-Annual Semi-Annual

Sample Location 0206

Process wastewater from the Building 20 Research Lab steam sterilizer shall be sampled from the sample spigot on the side of the sterilizer, prior to mixing with any other streams.

If the permittee did not discharge wastewater to the sanitary sewer system during the required sampling period, the permittee shall submit a letter so indicating by the reporting due date.

The MWRA recommends an EPA analysis method for each pollutant listed in the Sampling and Reporting Schedule(s). The method may be one of a few that are approved by the EPA for a specific pollutant. A certified laboratory may substitute another method which is listed in 40 C.F.R. Part 136 for the pollutant being analyzed or if approved or otherwise authorized by the MWRA and EPA.

Sampling and Reporting Schedule for Sample Location 0206

Sample Type Frequency Reporting Frequency

Chromium (Total) 200.7 Grab Semi-Annual Semi-Annual Flow Field Grab Semi-Annual Semi-Annual Lead (Total) 200.7 Grab Semi-Annual Semi-Annual Mercury (Total) 245.1 Grab Semi-Annual Semi-Annual Nickel (Total) 200.7 Grab Semi-Annual Semi-Annual

Sample Location 0207

Process wastewater from the Building 20 Research Lab dishwashers shall be sampled from either of the two sample spigots on the dishwashers’ discharge line, prior to mixing with any other streams.

If the permittee did not discharge wastewater to the sanitary sewer system during the required sampling period, the permittee shall submit a letter so indicating by the reporting due date.

The MWRA recommends an EPA analysis method for each pollutant listed in the Sampling and Reporting Schedule(s). The method may be one of a few that are approved by the EPA for a specific pollutant. A certified laboratory may substitute another method which is listed in 40 C.F.R. Part 136 for the pollutant being analyzed or if approved or otherwise authorized by the MWRA and EPA.

Sampling and Reporting Schedule for Sample Location 0207

Sample Type Frequency Reporting Frequency

Copper (Total) 200.7 Grab Semi-Annual Semi-Annual Flow Field Grab Semi-Annual Semi-Annual Lead (Total) 200.7 Grab Semi-Annual Semi-Annual Mercury (Total) 245.1 Grab Semi-Annual Semi-Annual Zinc (Total) 200.7 Grab Semi-Annual Semi-Annual

General Sampling and Analysis Requirements

Sampling All samples and measurements collected for the purpose of this permit shall be representative of the typical volume and nature of the permittee's discharge. The discharge shall be free of any uncontaminated water, sanitary wastes, or other non-process water. Samples shall be collected, preserved, and handled in accordance with the procedures established in 40 C.F.R. Part 136 and amendments.

The permittee shall not manipulate its sampling schedule to avoid taking samples that may contain discharge violations, such as on days of higher or lower production, on days of unusual production, or when the permittee otherwise has or should have information that violations may occur.

Sampling required by the MWRA shall be performed by an independent laboratory with DEP certification or accreditation from the EPA’s National Environmental Laboratory Accreditation Program (NELAP).

All samples collected for the purpose of this permit shall be transported to the laboratory accompanied by completed MWRA chain of custody forms that have been filled out by the individual who collected the samples.

Sample locations shall be safely located and accessible to MWRA staff and monitoring equipment. Wastewater measuring devices, which the MWRA reserves the right to approve, shall be compatible with MWRA monitoring equipment. In addition, the devices shall be properly maintained and calibrated at all times to ensure measurement accuracy.

If the permittee samples more frequently than required in this permit, for any pollutant being discharged, using test procedures prescribed in 40 C.F.R. Part 136 or other United States Environmental Protection Agency (EPA) approved methods, the results of such monitoring shall be submitted to the MWRA, in accordance with the procedures required for submitting sampling reports.

Certification that a Grab Sample is Representative The following is an exception to the composite(VOA), composite(Cr+6) and composite(CN) requirements (see Definitions of Sampling and Reporting Terms found at the end of this permit):

You may submit the analysis of a single grab sample for TTO(volatile organic fraction), cyanide, and hexavalent chromium, if you believe that a single grab sample is representative of the daily process discharge at the sample location. Please be aware that if you submit the analysis of a single grab sample to the MWRA for TTO (volatile organic fraction), hexavalent chromium, and/or cyanide, the submittal of the chain of custody will serve as certification from you that a grab sample is representative of your daily discharge at the sample location. If you provide such certification, the MWRA reserves the right to take one grab sample to measure compliance with the limit for that pollutant/parameter.

Analysis Analysis required by the MWRA shall be performed by a DEP certified independent or NELAP accredited laboratory that is fully certified for the pollutants being analyzed unless otherwise specified or approved by the MWRA. The use of a laboratory with provisional DEP certification is prohibited for the parameters for which it has provisional certification, unless the Authority determines that the factors resulting in the provisional certification should not adversely affect the quality of the analyses the laboratory may submit. A sample analysis performed by a laboratory without DEP certification or NELAP accreditation for the parameter may be submitted with the approval of the Authority. The Authority may grant such approval where DEP does not certify and NELAP does not accredit for the parameter to be analyzed, there is no DEP certified or NELAP accredited laboratory in Massachusetts or an adjoining state that performs the required test method, or in other extraordinary circumstances. The Authority may require a Permittee to submit a copy of the "Massachusetts Certification for Chemical Analysis of Waters" or the NELAP Certification of Accreditation, whichever is applicable, for each laboratory that performs an analysis submitted to the Authority by or on behalf of the Permittee.

The Authority may limit the laboratories a Permittee may use for any report required by the Authority. The Authority may specify the quality assurance/quality control methods to be performed by a laboratory for any report required by the Authority. Analysis for wastewater pollutants and parameters shall be conducted in accordance with applicable procedures approved by the United States Environmental Protection Agency (EPA) included in 40 C.F.R. Part 136, unless otherwise authorized or required by the Authority and EPA. If there is no applicable EPA approved procedure, the Authority may specify a procedure to be used.

Reporting Procedures for Self-Monitoring Requirements

All analyses done pursuant to this permit must be submitted to the MWRA. A report not submitted as required by this reporting procedure shall be considered a non-report, subjecting the permittee to enforcement action. The Authority may require that analytical data and reports, including a complete data package, be submitted to it directly by the laboratory that performed that analyses (See 360 C.M.R. 10.008(2)(g)).

Electronic Submittal of Self-Monitoring Results All wastewater sampling and analysis reports required by this permit must be submitted to the MWRA electronically by the permittee or its laboratory, utilizing the Pretreatment Information Management System Web Self-Monitoring Report (Web SMR) available at http://websmr.mwra.com/.

Chains of Custody/Field Forms The chains of custody/field forms enclosed with this permit shall be copied and used to document pertinent sampling information. The chains of custody/field forms shall be completed by the person who took the samples and then accompany the samples to the laboratory for analysis. Any time the samples are transferred from one individual to another during the transport and laboratory analysis of the samples, the person relinquishing the samples shall sign his/her name and indicate his/her name and the date and time the samples were relinquished, on http://websmr.mwra.com/ the bottom of the form. The receiving person must also sign and date the forms in the appropriate box. There should be one chain of custody/field form for grab samples collected and one chain of custody/field form for composite samples collected for each sample location.

Wastewater Sampling Analysis Reports Submittal/Laboratory Certification Forms The permittee must: a) assure that the laboratory provides the permittee with a copy of the data and corresponding chains of custody/field forms the laboratory submits to the MWRA, no later than the day the laboratory submits the electronic report to the MWRA; and b) shall have on file with the MWRA a current Sample Analyses and Reporting Certification Form provided by the MWRA (copy attached), signed and dated by the Authorized Representative of the permittee, authorizing the electronic data submittal from a laboratory and certifying the results. The permittee must thereafter submit a newly signed and dated certification form whenever it changes its Authorized Representative.

Certification Form/Authorized Representative The permittee shall submit the Sample Analyses and Reporting Certification Form required by this permit. Each certification form shall be signed and dated by an Authorized Representative of the permittee. An Authorized Representative is a:

(a) Responsible corporate officer, if the permittee is a corporation. For the purpose of this requirement, a responsible corporate officer means a president, secretary, treasurer, or vice president of the corporation in charge of a principal business function, or any other person who performs similar policy or decision-making functions for the corporation, or the manager of one or more manufacturing, production, or operating facilities, provided, the manager is authorized to make management decisions which govern the operation of the regulated facility including having the explicit or implicit duty of making major capital investment recommendations, and initiate and direct other comprehensive measures to assure long-term environmental compliance with environmental laws and regulations; can ensure that the necessary systems are established or actions taken to gather complete and accurate information for the permit requirements; and where authority to sign documents has been assigned or delegated to the manager in accordance with corporate procedures.

(b) General partner or proprietor if the permittee is a partnership or sole proprietorship respectively.

(c) Duly authorized representative of the individual designated in (a) or (b) of this section if:

i) the authorization is made in writing by the individual described in (a) or (b);

ii) the authorization specifies either an individual or a position having responsibility for the overall operation of the facility from which the industrial discharge originates, such as the position of plant manager, operator of a well, or well field superintendent, or a position of equivalent responsibility, or having overall responsibility for environmental matters for the company;

iii) the written authorization is submitted to the MWRA

If an authorization is no longer accurate because a different individual or position has responsibility for the overall operation of the facility, or overall responsibility for environmental matters for the permittee, a new authorization satisfying the requirements of this section must be submitted to the MWRA prior to or together with the next report required of the permittee.

Reports, Records and Devices You Must Maintain at Your Facility

Sample Location 0101

Flow Measuring Device Maintenance:

The permittee shall maintain its open-channel primary flow measuring device and continuously recording flow meter at Sampling Location 0101 to allow the accurate measurement of wastewater flow prior to mixing with any other streams.

Daily Flow Log:

The permittee shall maintain a daily flow log for Sampling Location 0101. The flow log shall list the daily discharge volume in gallons per day (GPD). Each entry in the log shall be initialed by the person making the entry. The flow log shall be kept on site for a minimum of three years and it shall be made available to the MWRA upon request.

Sample Location 0102

Flow Measuring Device Maintenance:

The permittee shall maintain its open-channel primary flow measuring device and continuously recording flow meter at Sampling Location 0102 to allow the accurate measurement of wastewater flow prior to mixing with any other streams.

Daily Flow Log:

The permittee shall maintain a daily flow log for Sampling Location 0102. The flow log shall list the daily discharge volume in gallons per day (GPD). Each entry in the log shall be initialed

Sample Location 0103

Flow Measuring Device Maintenance:

The permittee shall maintain its open-channel primary flow measuring device and continuously recording flow meter at Sampling Location 0103 to allow the accurate measurement of wastewater flow prior to mixing with any other streams.

Daily Flow Log:

The permittee shall maintain a daily flow log for Sampling Location 0103. The flow log shall list the daily discharge volume in gallons per day (GPD). Each entry in the log shall be initialed

Facility-Wide:

Laboratory Chemicals Management Plan:

The permittee shall have and implement a written laboratory chemicals management plan to control the discharge of regulated materials to the sewer system. Regulated materials are those that contain pollutants regulated by the MWRA at 360 C.M.R. § 10.021-10.024. At a minimum, the plan shall include procedures to:

A. Ensure that regulated materials do not spill or leak into the sewer system;

B. Eliminate or minimize the disposal of regulated materials to the sewer system so that MWRA discharge limits are met;

C. Properly handle, store, collect, and dispose of laboratory chemicals and maintain disposal manifests;

D. Train laboratory employees in proper laboratory chemical usage and disposal; and, E. Ensure that the laboratory chemicals management plan is followed by, among other measures, posting appropriate notices of proper chemicals usage and disposal practices at sinks where laboratory chemicals are used.

Hazardous Waste Manifests:

The permittee shall maintain copies of manifests for hazardous waste hauled away from the premises for a period of five (5) years. They shall be made available and copies shall be provided to the MWRA upon request.

Slug Control Plan:

The permittee shall have and implement a written Slug Control Plan to control slug discharges to the sewer system. For the purpose of this requirement, a slug is any discharge of a non-routine, episodic nature, including but not limited to an accidental spill or a non-customary batch discharge. The plan shall contain, at a minimum, the following elements:

A) Description of discharge practices, including non-routine batch discharges;

B) Description of stored chemicals;

C) Procedures for immediately notifying the MWRA of slug discharges, including any discharge that would violate a prohibition under 40 CFR 403.5(b), with procedures for follow-up written notification within five (5) days;

D) If necessary, procedures to prevent adverse impact from accidental spills, including inspection and maintenance of storage areas, handling and transfer of materials, loading and unloading operations, control of plant site run-off, worker training, building of containment structures or equipment, measures for containing toxic organic pollutants (including solvents), and/or measures and equipment for emergency response.

Authorized Discharge

Facility-Wide:

Reverse Osmosis Reject/Filter Backwash Discharge:

Pursuant to 360 C.M.R. 10.023(2)(a) and 10.023(19), and effective 10/10/1990, the MWRA granted authorization to the permittee to discharge RO reject water to the sanitary sewer.

Sampling Records

VA Boston Healthcare System shall maintain accurate records of all monitoring activities including:

a. date, exact place, time, and methods of sampling or measurements, and sample preservation techniques or procedures;

b. name of the person performing the sampling or measurements;

c. date(s) analyses were performed;

d. name of person performing the analysis;

e. analytical techniques or methods used, detection limit, analysis/extraction date;

f. results of the analyses; and

g. laboratory quality control/quality assurance documentation for the analysis performed.

The permittee shall retain records of all monitoring activities for at least three years. This includes calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, copies of reports required by this permit, and information used to complete the Permit Application. This period may be extended by notice from the MWRA at any time. In addition, the MWRA may examine or require the submittal of records upon request in accordance with 360 C.M.R. 10.010(3).

When You Should Notify the MWRA

Notification of Discharge of Hazardous Waste

The permittee shall provide the notifications required by 40 CFR 403.12(p) by the dates indicated in that section. This requires certain written reports by the permittee if it discharges into the MWRA Sewer System certain substances which if otherwise disposed of would be a hazardous waste under 40 CFR Part 261.

Giving Notice and Resampling in the Event of a Violation

If sampling performed by the permittee pursuant to this permit indicates a violation of the discharge limits and prohibitions, the permittee shall notify the MWRA at (617) 242-6000, and request Toxic Reduction and Control within 24 hours of becoming aware of the violation that it has noted the existence of the violation. The permittee shall submit to the MWRA the report containing the violation. The permittee shall also repeat the sampling and analysis and submit the results of the repeat analysis to the MWRA within 30 days of becoming aware of the violation, except the permittee is not required to resample if: (a) the MWRA samples the permittee at least once a month; or (b) the MWRA sampled the permittee between the time of the sampling that contained the violation and the time the permittee received the results of the sampling showing the violation. If the permittee believes it meets an exception to resampling, it shall request confirmation from the MWRA and shall resample unless confirmation is given.

Notification of Upsets

The permittee shall notify the MWRA and the Municipality within 24 hours of becoming aware of an Upset at its facility. During normal business hours the MWRA should be notified by telephone at (617) 242-6000, and request Toxic Reduction and Control. At all other times the MWRA should be notified by telephone at (617) 305-5940 after 5:00 p.m. Monday - Friday or weekends and holidays. This notification shall be followed, within 5 days of the date of occurrence, by a detailed written statement to the MWRA and the Municipality describing the causes of such discharge and the measures being taken to prevent future occurrence.

For the purposes of this section, Upset means an exceptional incident in which there is unintentional and temporary noncompliance with the discharge standards of 360 CMR 10.000, or any permit thereunder, because of factors beyond the reasonable control of the permittee. An Upset does not include noncompliance to the extent caused by operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive maintenance, or careless or improper operation. An Upset shall constitute an affirmative defense to an action brought for noncompliance with categorical Pretreatment Standards if the requirements of paragraph below are met.

A permittee who wishes to establish the affirmative defense of Upset shall demonstrate, through properly signed, contemporaneous operating logs, or other relevant evidence that:

(1) An Upset occurred and the permittee can identify the cause(s) of the Upset;

(2) The facility was at the time being operated in a prudent and workman-like manner and in compliance with applicable operation and maintenance procedures;

(3) The permittee has submitted the following information to the MWRA and the Municipality within 24 hours of becoming aware of the Upset (if this information is provided orally, a written submission must be provided within five days):

(i) A description of the discharge and cause of noncompliance;

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(ii) The period of noncompliance, including exact dates and times or, if not corrected, the anticipated time the noncompliance is expected to continue;

(iii) Steps being taken and/or planned to reduce, eliminate and prevent recurrence of the noncompliance.

In any enforcement proceeding the permittee seeking to establish the occurrence of an Upset shall have the burden of proof.

In the usual exercise of prosecutorial discretion, MWRA enforcement personnel should review any claims that non-compliance was caused by an Upset. No determinations made in the course of the review constitute final MWRA action subject to judicial review. The permittee will have the opportunity for a judicial determination on any claim of Upset only in an enforcement action brought for noncompliance with 360 CMR 10.000.

The permittee shall control production or all discharges to the extent necessary to maintain compliance with 360 CMR 10.000 upon reduction, loss, or failure of its treatment facility until the facility is restored or an alternative method of treatment is provided. This requirement applies in the situation where, among other things, the primary source of power of the treatment facility is reduced, lost or fails.

Notification of Noncomplying Discharges (Accidents, Slug Loads, Spills)

The permittee shall notify the MWRA and the Municipality immediately by telephone upon the occurrence of an accidental discharge of substances prohibited or limited by this permit or by 360 C.M.R. 10.021 - 10.024, or of any slug loads or spills that may reasonably be expected to enter the sanitary sewer from the permittee's facility. During normal business hours the MWRA should be notified by telephone at (617) 242-6000, and request Toxic Reduction and Control. At all other times the MWRA should be notified by telephone at (617) 305-5940 after 5:00 p.m.

Monday - Friday or weekends and holidays. The notification shall include location of the discharge, date and time thereof, type of waste, including concentration and volume, and corrective actions taken. The permittee's notification of accidental release in accordance with this section does not relieve it of other reporting requirements that arise under local, State, or Federal laws, regulations, or this permit.

This notification shall be followed, within 15 calendar days of the date of occurrence, by a detailed written statement to the MWRA and the Municipality describing the causes of such discharge and the measures being taken to prevent future occurrence.

The notification shall provide the following information:

(1) Description of the discharge, type of waste, concentration and volume.

(2) Duration of noncompliance, including exact dates and, if the noncompliance continues, the time by which compliance is reasonably expected to occur.

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(3) All steps taken or to be taken to reduce, eliminate, and prevent recurrence of such a condition of noncompliance.

Duty to Notify of Actions which May Substantially change the Volume or Nature of a Discharge

The permittee shall provide at least 30 days advance written notification to the Authority before taking any action which may substantially change the volume or nature of its discharge, including a substantial change in the volume or character of pollutants in its discharge, from any compliance measurement location, or from any sewer connection. Such actions may include, but not be limited to, the following:

a) substantial expansion or contraction of the facility from which the discharge originates;

b) substantial increase or decrease in production;

c) modification of any process;

d) alteration of the Pretreatment system or the operation of the Pretreatment system; or

e) discharge from a different or relocated sewer connection.

f) changes that require the permittee to modify or implement a plan to control slug discharges as defined by 40 C.F.R. §403.8

Mailing and Email Address for Reports and Notifications

All documents and materials required to be submitted shall be mailed to:

Massachusetts Water Resources Authority 2 Griffin Way Chelsea, MA 02150 Attn.: Toxic Reduction and Control

In addition to your hard copy submittal, all reports and materials required by your permit shall also be submitted as an attachment to an email submitted to:

TRACPermits@mwra.com

The electronic copy of each individual report required by your permit must be submitted as a single pdf file. The file name must include your permit number, the report type (i.e., pH log, Compliance Report), and the sampling location number and the date range covered in the report where applicable (example file names are: 12345678_pHlog_101_0321to0421.pdf and 12345678_ComplianceReport.pdf). The same information (permit number, report type, sample location, and date range) should be included in the subject line of your email. Do not send a single pdf that includes multiple documents (for example, a flow log and a pH log). Each report should be submitted as an individual file. If the files are too large to email, please send an email to TRACPermits@mwra.com and request a link to the MWRA file share.

mailto:TRACPermits@mwra.com mailto:TRACPermits@mwra.com

All submittals shall include a completed TRAC submittal form. A copy of the TRAC submittal form is attached to this permit. It should be photocopied as needed.

PART B…