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Date: Thu, 19 Aug 2010 10:17:03 -0700
Reply-To: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: "Painter, Socorro M." <painter2**At_Symbol_Here**LLNL.GOV>
Subject: Re: Cupric Sulfate Solution Disposal
In-Reply-To: <4C6CF443.8648.0091.0**At_Symbol_Here**ph.lacounty.gov>
Eric is correct. POTW's have standards that they have to follow to make sur
e they are in compliance with their National Pollutant Discharge Eliminatio
n System (NPDES) permit. So See NPDES website http://cfpub.epa.gov/npdes/al
lfaqs.cfm?program_id=0#107 The amount of copper you can discharge will de
pend on the POTW discharge limits for copper.
I worked in a wastewater treatment plant for 7 years in the 80's and yes I'
ve seen whole activated sludge tanks die because of a bad discharge from on
e of our companies. I've also seen whole tanks turn pink or purple because
of a carpet manufacturer. Of course we knew exactly who it was discharging
those pink wastewater. One way to find out is to have our engineers and tec
hnicians follow the trail by opening manholes until they find the culprit.
So please think about it carefully when you're dumping something into the s
ewer.
As for hazardous waste, that's a different regulation. You can look at 40CF
R261.
There are different ways of calling something hazardous. Either by characte
ristics, (e.g.ignitable, corrosive, toxic, reactive) or by listing.
See website or just type in 40CFR261 on Google.
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx c=ecfr&tpl=/ecfrbrowse/Ti
tle40/40cfr261_main_02.tpl
Socorro Maniquis Painter
Lawrence Livermore National Laboratory
Physical and Life Sciences Directorate (PLSD)
Chemical Sciences Division (CSD)
P.O. Box 808 L-283
Livermore, CA 94551
Tel.: (925) 423-1473
Fax: (925) 424-3281
E-mail: painter2**At_Symbol_Here**llnl.gov
-----Original Message-----
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of Er
ic Clark
Sent: Thursday, August 19, 2010 9:06 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] Cupric Sulfate Solution Disposal
Anthony,
Sometime during the process while you're figuring out how to manage that aq
ueous waste, be sure to contact the POTW and describe exactly what it is yo
u'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-dis
pose of pH-neutralized solutions of certain waste streams with very low con
centrations of some D-coded metals. These metals are well below the TCLP t
hreshold concentrations and therefore are not HW by EPA's regulatory defini
tion. The POTW engineer might ask you to send a sample of that waste strea
m to a certified environmental lab for a proper hazardous waste determinati
on and POTW compatibility testing before he signs anything.
The POTW's major concern is that whatever wastewater they receive doesn't s
omehow kill their colonies of activated sludge. If that happens, it's upse
tting 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 t
alk 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" beca
use that's an EPA regulatory term, and Hazardous Waste also carries waste c
odes - and they'll immediately remind you that you cannot dispose of "Hazar
dous 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 proble
m 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 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
>
> ------------------------------------------------------------------------
>
> *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 wast
e?
>
> Regards,
> Anthony
>
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