Date: June 22, 2010 11:14:19
AM EDT
Subject: RE: [DCHAS-L] help
needed with water discharge limits
It is very surprising that a DEQ official would offer
such an advice. It may be in the best interest of the
institution to select sampling point/points before the wastewater
discharge into a POTW and conduct several analyses of water samples to
get a baseline idea of how much of the RCRA metals are found in the
discharge water. The local city or POTW would have
their own limits on the quality of wastewater that they can
accept. If the analytical results are higher than their
limits, the water may have to be treated before the POTW would accept.
If there are no limits coordinate with the POTW and get it
in writing that the water discharged would not affect their operations
and therefore is acceptable. This is very important to
protect against any Notice of Violation arising out of inspections by
the DEQ or the EPA. The link below has several useful information
on water quality standards in Virginia.
Venkat Subramanian,
Ph.D,
Regional Environmental
Manager
American
Airlines
4333, Amon Carter Blvd, MD
5285
Ft Worth, Texas
76155
(817) 963-2258
(work)
(817) 931-6392
(fax)
===
Date: June 22, 2010 11:19:52 AM
EDT
Subject: RE: [DCHAS-L] help
needed with water discharge limits
Monona:
I think your clients and
their consultants are getting a bit confused about the difference
between specific pre-treatment ordinances, which are in effect in
certain larger cities (EPA has a tiered system) and general, federal
statutory bans on disposal.
If you
are disposing to a POTW and the POTW has an EPA-approved pretreatment
program and issues you a permit, you can - in certain instances -
dispose of materials that would be considered as hazardous waste (e.g.,
small concentrations of solvents, metals). If there is no approved
pre-treatment plan, you may be subject to federal RCRA
requirements.
As for Dr. Norwood=92s
situation - Richmond has pretreatment limits and a program (although
it is a bit sketchy):
Sec. 29-314. Discharge of
industrial, etc., wastes into sewers--Generally.
It shall be
unlawful for the owner or operator of any industrial plant or
enterprise, located within or without the corporate limits of the City,
to discharge or cause to be discharged, in any manner, directly or
indirectly, into the sewers of the City, whether located within or
without the corporate limits thereof, any water used in industrial
processes, any industrial waste or liquid or other matter which injures
or is likely to injure the sewers, overcharges or is likely to
overcharge the sewers, or is detrimental or is likely to become
detrimental to navigation, public health, safety or welfare.
(Code
1985, =A7 30-314)
Sec. 29-315. Same--Specific prohibited
discharges.
(a) No industrial user of the City's wastewater system
shall discharge or cause to be discharged into such system the following
liquid or material:
(1) Any material which creates or may create a
fire or explosion hazard at any point in the City's wastewater
system;
(3) Any solids or viscous matter in an amount which may
cause obstruction or interference in the wastewater system;
(4) Any
material that, by its constituents, character, volume, strength or any
combination thereof, may cause or contribute to an interference with the
normal operation of the City's wastewater system;
(5) Heat in an
amount that would inhibit biological activity or cause wastewater
treatment plant influent temperature to exceed forty (40) degrees
Celsius (one hundred four (104) degrees Fahrenheit).
(b) Industrial
user for purposes of this section is defined to include any nondomestic
source.
(Code 1985, =A7 30-315)
There is a compendium of national sewer discharge
regulations that your consultant should be able to tap into, especially
if they have worked with platers or photo labs in the
past.
Regards,
Dave
DAVE EINOLF
Managing
Director
Endeavour EHS,
LLC
5750 SE Carlton
Street
Portland OR
97206-6753
971.678.8111 (w)
912.717.1533
(fax)
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