1. Waste Water Management: Drain disposal, recent MWRA violations and system upgrades at Harvard Presented by Josh Fawson, PE Wastewater Program Manager

2. Agenda 1.Brief wastewater program overview 2.Recent violations and lessons learned 3.Disposal in SAA vs. Drain? 4.Other Updates

3. 1. Program Overview

4. Wastewater Overview Industrial users have permits based on their operations to protect water quality. Chemical contamination impacts compliance and water quality in the Boston Harbor. MWRA (Massachusetts Water Resources Authority) permits waste water discharged from greater Boston.

5. Permit Required Monitoring 1.Harvard has 12 monitoring locations in Longwood – 3 for SPH 2.Scheduled Monthly, Quarterly, or Semi Annual Sampling. – Based on flow 3.MWRA Unannounced Sampling. 4.Daily pH and Flow Logs. 5.Monitoring and annual report for photo fixer units.

6. MWRA Permit Limits Include Heavy Metals Organic Solvents, VOCs, or Toxic Organics. Odiferous chemicals (i.e. mercaptans). Hazardous chemicals (highly flammable etc) Slugs from equipment cleaning. Temperature >82 degrees C Oil and Grease >300 PPM pH must be between 5.5 and 12

8. Because this happened…fortunately not here. Louisville - 1981

9. 2. Recent Permit Violations

10. Recent Permit Violations Mercury – – legacy in pipes and in some lab products. Construction related activities caused release (SGM) Took over 6 months identify and remedy Significant costs for system cleaning and sampling – Improper chemical disposal Limited amount of chemical solution containing mercury discharged to sink Training had recently been completed Used chemical inventory to identify source

11. PerspectiveSources 1 PPB – enforcement limit for mercury – 1 grain of sand in a billion – 2 blades of grass in a football field It doesn’t take much to cause a violation EHS tested bleach which can have mercury Bleach purchased through VWR stockrooms are mercury free Other chemicals may have trace amount of mercury – Review SDS and collect if unsure

12. Recent Permit Violations Copper – Improper disposal of copper shavings (TMEC)

13. Recent Violations NRB violation for ethylbenzene Improper disposal should have gone in SAA Concentrations of other chemicals in sample matched common chemical used in the labs

14. 3. Drain Disposal Guidelines

15. Wastewater Discharge Prohibitions H410 Very toxic to aquatic life with long lasting effects. P273 Avoid release to the environment. P391 Collect spillage. H300 Fatal if swallowed H310 Fatal in contact with skin H330 Fatal if inhaled H340 May cause genetic defects H341 suspected of causing genetic defects H350 May cause cancer H351 Suspected of causing cancer H360 May damage fertility or the unborn child H361 Suspected of damaging fertility of the unborn child H362 May cause harm to breast –fed children H400 very toxic to aquatic life H410 very toxic to aquatic life with long lasting effects H411 toxic to aquatic life with long lasting effects H412 Harmful to aquatic life with long lasting effects H413 may cause long lasting harmful effects to aquatic life If SDS Section 2.2 contains any of the following hazard statement and the concentration is > 0.01% then the material is prohibited from drain disposal. RCRA or State Regulated Hazardous Waste Reactive, Flammable (FP 12.5),or Toxic (P or U EPA Listed) Mixtures containing controlled substances Non-hazardous solutions that exceed MWRA or POTW discharge limits. Heavy Metals, Slugs from Cleaning Equipment, Temperatures > 180ᵒC, Oil and Grease > 300 PPM, PCBs, solids, pesticides Odiferous Chemicals (e.g. Mercaptans, Paraformaldehyde) Radioactive materials that exceed allowable limits Biohazardous waste that has not been suitably disinfected Help us meet our regulatory requirements by preventing materials with these characteristics from entering laboratory sinks. See the EH&S website for additional information https://www.ehs.harvard.edu/sites/ehs.harvard.edu/files/wastewater_sink_disposal_guidance.pdf https://www.ehs.harvard.edu/sites/ehs.harvard.edu/files/wastewater_sink_disposal_guidance.pdf

16. Drain Disposal vs. SAA Continued EHS is updating sink disposal guidelines – Current guidelines: http://ehs.harvard.edu/sites/ehs.harvard.edu/files/wast ewater_sink_disposal_guidance.pdf Current guidelines: http://ehs.harvard.edu/sites/ehs.harvard.edu/files/wast ewater_sink_disposal_guidance.pdf We will review later on this year

17. Disposal of Pipette Tips Pipette tips can: – Damage pumps (even those designed for solids) – Prevent valves from operating properly Pipette tips are being found in increasing numbers throughout wastewater systems in Longwood

18. Disposal of Pipette Tips Cause blockages in pH systems and piping Pipette tips should be disposed of: – In a rigid trash container or – collected as biowaste waste if they are contaminated

19. 3. Other Updates

20. 2016 Permit Renewal The Longwood MWRA permit expires in December Application is due in October This summer you may get an RFI from EH&S – RO/DI water use – Chemical inventory updates – Photo Processor information – Rack/Tunnel Washing Operations