DCHAS-L Archives Aug 19 2010 - Re: Cupric Sulfate Solution Disposal

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Hello Eric, Thank you for your response, it prompted me to look up the sewer regulation s rather than try to make a hazardous waste determination.=A0 In 19.04 Rule s of the City of New York (RCNY) I found that copper is limited to 5mg/l pr ior to discharge.=A0 So I have my answer. Thanks to everyone that responded. Regards, Anthony --- On Thu, 8/19/10, Eric Clark wrote: From: Eric Clark 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 aq ueous waste, be sure to contact the POTW and describe exactly what it is yo u're planning on putting down the drain.=A0 Then be sure to get something i n writing from them, don't accept a verbal OK from the POTW engineer over t he phone.=A0 You never know when you'll have to pull that letter out during an inspection.=A0 I have a letter from the POTW granting permission to dra in-dispose of pH-neutralized solutions of certain waste streams with very l ow concentrations of some D-coded metals.=A0 These metals are well below th e TCLP threshold concentrations and therefore are not HW by EPA's regulator y definition.=A0 The POTW engineer might ask you to send a sample of that w aste stream to a certified environmental lab for a proper hazardous waste d etermination and POTW compatibility testing before he signs anything.=A0=A0 =A0 The POTW's major concern is that whatever wastewater they receive doesn't s omehow kill their colonies of activated sludge.=A0 If that happens, it's up setting for them and they'll trace the contaminant back to the facility tha t caused the problem.=A0 The folks here at one of the Los Angeles POTWs sti ll talk about a colony-killing event that happened more than ten years ago and what a hassle that was for them to mitigate.=A0 =A0 =A0=A0=A0 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.=A0 Dilute solutions of cupric sulfate don't car ry any EPA waste codes.=A0 I think this is going to be easy waste stream pr oblem for you to solve, and you'll save a lot of money in disposal costs in the long run if you do it right.=A0=A0=A0 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:=A0 200 mg/liter max COD:=A0 300 mg/liter max Benzene:=A0 0.050 mg/liter max BETX:=A0 0.750 mg/liter max Temperature:=A0 no greater than 104 deg. F Ph:=A0 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 > --0-2030813851-1282236899=:44963

Hello Eric,

Thank you for your respons e, 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 Yo rk (RCNY) I found that copper is limited to 5mg/l prior to discharge. So I have my answer.

Thanks to everyone that responded.

Rega rds,
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 Sul fate Solution Disposal
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Date: Thursday, Augus t 19, 2010, 12:05 PM

Anthony,
Sometime during the process while you're figuring out how to manage that aqueous was te, be sure to contact the POTW and describe exactly what it is you're planning o n putting down the drain. Then be sure to get something in writing fr om 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 inspe ction. 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 T CLP threshold concentrations and therefore are not HW by EPA's regulatory d efinition. The POTW engineer might ask you to send a sample of that w aste stream to a certified environmental lab for a proper hazardous waste d etermination and POTW compatibility testing before he signs anything.

The POTW's major concern is that whatever wastewater th ey receive doesn't somehow kill their colonies of activated sludge. If that happens, it's upsetting for them and they'll trace t he contaminant back to the facility that caused the problem. The folk s here at one of the Los Angeles POTWs still talk about a colony-killing ev ent that happened more than ten years ago and what a hassle that was for th em to mitigate.

And when you talk to the POTW, avoid using the words "Hazardous Waste" because that's an EPA re gulatory term, and Hazardous Waste also carries waste codes - and they'll i mmediately 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, C CHO, 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 was te 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 thi s.

The chemical oxygen demand (COD) is probably the issue you will n eed to
deal with, although this is more relevant for organic rather tha n
inorganic compounds.

Dan Crowl
Michigan Tech

On 8/19 /2010 10:52 AM, Bradley, Shelly wrote:
> City Sewer Ordinance here al lows discharge to sewer system of copper at
> 2 ppm or less.
>
> Shelly Bradley
>
> Instrumentation Speci alist
>
> Laboratory Development Assistant
>
> Camp us Chemical Compliance Director
>
> Chemistry Department
> ;
> Hendrix College
>
> Conway, AR 72032
>
> (501) 450-3812
>
> bradley**At_Symbol_Here**hendrix.edu <mai lto: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, Augu st 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 dilu te solutions of cupric
> sulfate. Do you drain dispose if it is a ver y low concentration? At what
> concentration would you consider manag ing this solution as hazardous waste?
>
> Regards,
> Anth ony
>

--0-2030813851-1282236899=:44963--

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