Hello Eric,
Thank you for your response, it prompted me to look up the sewer
regulations
rather than try to make a hazardous waste determination. In
19.04 Rules
of the City of New York (RCNY) I found that copper is limited to 5mg/l
prior
to discharge. So I have my answer.
Thanks to everyone that responded.
Regards,
Anthony
--- On Thu, 8/19/10, Eric Clark
<erclark**At_Symbol_Here**PH.LACOUNTY.GOV>
wrote:
From: Eric Clark <erclark**At_Symbol_Here**PH.LACOUNTY.GOV>
Subject: Re: [DCHAS-L] Cupric Sulfate Solution Disposal
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Date: Thursday, August 19, 2010, 12:05 PM
Anthony,
Sometime during the process while you're figuring out how to manage
that
aqueous waste, be sure to contact the POTW and describe exactly what
it is
you're planning on putting down the drain. Then be sure to get
something in writing from them, don't accept a verbal OK from the POTW
engineer over the phone. You never know when you'll have to pull
that
letter out during an inspection. I have a letter from the POTW
granting
permission to drain-dispose of pH-neutralized solutions of certain
waste
streams with very low concentrations of some D-coded metals.
These
metals are well below the TCLP threshold concentrations and therefore
are not
HW by EPA's regulatory definition. The POTW engineer might ask
you to
send a sample of that waste stream to a certified environmental lab
for a
proper hazardous waste determination and POTW compatibility testing
before he
signs anything.
The POTW's major concern is that whatever wastewater they receive
doesn't
somehow kill their colonies of activated sludge. If that
happens, it's
upsetting for them and they'll trace the contaminant back to the
facility
that caused the problem. The folks here at one of the Los
Angeles POTWs
still talk about a colony-killing event that happened more than ten
years ago
and what a hassle that was for them to mitigate.
And when you talk to the POTW, avoid using the words "Hazardous
Waste" because that's an EPA regulatory term, and Hazardous Waste
also
carries waste codes - and they'll immediately remind you that you
cannot
dispose of "Hazardous Waste" down the drain. Dilute
solutions
of cupric sulfate don't carry any EPA waste codes. I think this
is
going to be easy waste stream problem for you to solve, and you'll
save a lot
of money in disposal costs in the long run if you do it
right.
Eric
Eric Clark, MS, CCHO, CHMM
Safety & Compliance Officer
Los Angeles County Public Health Laboratory
>>> Dan Crowl <crowl**At_Symbol_Here**MTU.EDU> 8/19/2010 8:01
AM
>>>
Hi Anthony,
A general waste disposal guideline that I use for liquid waste to the
POTW is:
BOD: 200 mg/liter max
COD: 300 mg/liter max
Benzene: 0.050 mg/liter max
BETX: 0.750 mg/liter max
Temperature: no greater than 104 deg. F
Ph: no less than 5, no greater than 12.
Please be advised that there is a lot of local variation on this.
The chemical oxygen demand (COD) is probably the issue you will need
to
deal with, although this is more relevant for organic rather than
inorganic compounds.
Dan Crowl
Michigan Tech
On 8/19/2010 10:52 AM, Bradley, Shelly wrote:
> City Sewer Ordinance here allows discharge to sewer system of
copper at
> 2 ppm or less.
>
> Shelly Bradley
>
> Instrumentation Specialist
>
> Laboratory Development Assistant
>
> Campus Chemical Compliance Director
>
> Chemistry Department
>
> Hendrix College
>
> Conway, AR 72032
>
> (501) 450-3812
>
> bradley**At_Symbol_Here**hendrix.edu
<mailto:bradley**At_Symbol_Here**hendrix.edu>
>
>
------------------------------------------------------------------------<
br>
>
> *From:* DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] *On
Behalf
> Of *Anthony Santoro
> *Sent:* Thursday, August 19, 2010 9:12 AM
> *To:* DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
> *Subject:* [DCHAS-L] Cupric Sulfate Solution Disposal
>
> Hello,
>
> I am curious as to how others may be handling dilute solutions of
cupric
> sulfate. Do you drain dispose if it is a very low concentration?
At what
> concentration would you consider managing this solution as
hazardous
waste?
>
> Regards,
> Anthony
>
|