Geez, Monona – this makes me embarrassed to be from Vi rginia!!

In over 14 years at three different academic institutions in Virginia, we never pursued any kind of discharge permit.  All waste wa s dealt with by disposal using a third party vendor (though at one of these institu tions – years ago – I know ‘evaporation’ was used to deal with some of the volatile solvents (but you didn’t hear it from me!)

Brad

Dr. Bradley K. Norwood

Laboratory Director

Arista Laboratories

1941 Reymet Road

Richmond, VA  23237

(804) 271-5572 ext. 307

(804) 641-4641 (cell)

brad.norwood**At_Symbol_Here** aristalabs.com

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All,

I need advice.  As some of you know, the "laboratories" I de al with come under EPA's definition of laboratory for the new Subpart K which includes "art studios."  But we use a lot of the same solven ts, acids, metal compounds, etc., as you do.

I do building planning.  Among my practices is to obtain from the loca l waste water treatment plant 1) the limits for solvents, grease, pH, and var ious metal ions for the school's effluent (or the plant's influent) and 2) the discharge limits for local storm sewers if we have basement ceramics, sculpture, or other studios with storm drain access.

This usually is easy. Some Texas universities have the limits on their EH&a mp;S websites.  Large cities often have municipal or state (if they are sta te colleges) websites they can direct me to.  Small city plants usually s end them to me by e-mail. Some colleges have especially low limits because thei r plants discharge to protected waterways.  Others have very high limits because they go to massive big-city plants.

However, I planned one building in Virginia and the plant in this city told me they don't have any limits.  They said people at the college can put w hat ever they want into drains!   I figured they were wrong and used common sense limits to guide me so that the photography department would install a silver recovery unit, flammable solvents would never go down the drains, and so on.

Now I've got another college building in a different city in Virginia.  ; The school's EH Consultant contacted the local DEQ and plant for me.  She was told they never monitor what comes out of the school and have no limits for them.  So her advice to her people is we spend nothing from the budget on systems to protect water discharges!

It is really possible that in Virginia we can just dump our lead, cadmium, mercury, and chromium soluble pigments, our flammable solvents, etching aci ds, cyanide compounds, silver ion, etc., in the drains?   If that's t he case, can they deal with sweepings and mop water from the ceramic glaze roo m floor by dumping it in the sink?  A school in Maine was cited by EPA f or that because glaze waste won't pass a TCLP.  And does that mean that college chemistry labs in Virginia also have no limits on what goes down th eir drains?

Surely something is wrong here.  Can anyone help?

Monona Rossol

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