And all of the buildings I've done in Massachusetts had the same issue.  They have so many good rules in MA, this one is such an anachronism.   

BTW, friends, The Boston Society of Architects gave ACTS an award for design for our work on James Madison University's art building in 2016.  

Monona Rossol, M.S., M.F.A., Industrial Hygienist

President:  Arts, Crafts & Theater Safety, Inc.

Safety Officer: Local USA829, IATSE

181 Thompson St., #23

New York, NY 10012     212-777-0062

actsnyc**At_Symbol_Here**cs.com   www.artscraftstheatersafety.org

 

-----Original Message-----
From: Margaret Rakas <mrakas**At_Symbol_Here**SMITH.EDU>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Thu, Nov 30, 2017 10:21 am
Subject: Re: [DCHAS-L] Acid Neutralization Tanks

In Massachusetts, DEP has NOTHING to do with requiring (or inspecting, or regulating) these ridiculous items.  HOWEVER, the state plumbing board (made up of appointed 'concerned knowledgeable citizens', mostly plumbers I am betting) has jurisdiction, requires them, and adamantly refuses to move into even the late 20th century.  It doesn't matter that we can't discharge any hazardous materials into the drains--they see this as either a fail safe (I'm giving them the benefit of the doubt) or a way for their constituents to get extra hours during construction (you have to have separate lines to the tank from labs, at least in MA).  A Massachusetts college (forget which one) tried to argue against it and (no surprise) failed after spending a lot of $$.  The local plumbing inspector doesn't want to lose his license by 'forgetting' to require their installation, and so we all just do it.  What a waste of money, and with the new 'active' neutralization tanks, chemicals as well.

If I were in a different state, I would consider finding out exactly who (is there an appointed board, is it *just* the state agency employees) regulates/requires these in that state and then see if it's possible to dialogue with them.  What might persuade them (perhaps a solid training program would be enough or would they require other information)?  Not business or legal advice, may not be the opinion of my employer or any group I'm affiliated with...

If you succeed--please let us know how you did it!!!

good luck,

Margaret

On Wed, Nov 29, 2017 at 8:54 PM, Michael D Ahler <mahler**At_Symbol_Here**hancockcollege.edu> wrote:

Steve, et.al.

Look into the Hazardous Waste regulations that exist in area where you are.     In California and other states, generators are prohibited by regulation from treating a hazardous waste, including acid-base neutralization, without a Permit from the State Agency (some minor exceptions), and Treatment Permits are a major headache and expense to get - paper work, inspections, record keeping, annual Permit Fee$ ....  

 If your state or county or the CUPA you deal with has similar regulations, this may be an argument against installing an "acid waste treatment tank" in your building.   Instead, create and document waste containment procedures (organized and managed chemical waste collection) to show minimal acid release into the plumbing system.   This may involve some or a lot of staff training.    I'm not sure what the recent experience at Auburn is concerning chemical waste handling. 

Attorneys may get involved if there is a conflict between the Plumbing Code and Hazardous Waste Regulations.

Best of Luck.

Michael

Michael Ahler

Part-Time Faculty Member

LPS (Chemistry) Allan Hancock College,  and 

CHO (retired) Cal Poly, San Luis Obispo

---

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> on behalf of Steven Nelson <nelsost**At_Symbol_Here**AUBURN.EDU>
Sent: Tuesday, November 28, 2017 2:44:53 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: [DCHAS-L] Acid Neutralization Tanks

 

We are interested in getting a variance from the plumbing code requirement for installation of Acid Neutralization Tanks for our lab buildings. I would like to hear from others who have been successful in eliminating these tanks from their campus'.  Please reply to this post or feel free to contact me off-line at nelsost**At_Symbol_Here**auburn.edu . I'd like to find out what strategy was used and what data if any was developed.

Also, I seem to recall a study that one institution did on their lab building waste water effluent.  If anyone has a copy or can point me in the right direction I would be grateful.

Best regards,

 

Steve Nelson

Auburn University

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--

Margaret A. Rakas, Ph.D.
Manager, Inventory & Regulatory Affairs
Clark Science Center
413-585-3877 (p)

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