Date: Tue, 22 Jun 2010 09:39:16 -0400
Reply-To: rphifer**At_Symbol_Here**
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Russ Phifer <rphifer**At_Symbol_Here**WCENVIRONMENTAL.COM>
Organization: WC Environmental, LLC
Subject: Re: help needed with water discharge limits
In-Reply-To: <3036a.18be9029.39520fe3**At_Symbol_Here**>

Monona – every wastewater treatment plant in the country that discharges to a body of water after treatment has to have a NPDES permit. While there is no universal requirement for individual permits from dischargers (limits on what you discharge to the system) within the Clean Water Act requirements, there are national limits on some things – you can follow this link to the list - ext-idx?c=ecfr&sid=ef332aa37d8c6324385f34859726d7c2&rgn=div 8&view=text&node=40:


What’s interesting is that POTWs are REQUIRED to develop pre-treatment standards. In other words, they pretty much need to publish / provide discharge limits (40CFR 403.5(c):


“Each POTW developing a POTW Pretreatment Program pursuant to =A7403.8 shall develop and enforce specific limits to implement the prohibitions listed in paragraphs (a)(1) and (b) of this section. Each POTW with an approved pretreatment program shall continue to develop these limits as necessary and effectively enforce such limits.”

I suspect the POTWs you are dealing with are in rural Virginia, and that they are either not aware of the requirements or assume a university won’t generate prohibited wastewaters. If I were you, I’d develop your own internal limits based on the NPDES limits. You should still try to get the discharge limits from the POTW though…


Russ< /span>


Russ Phifer

WC Environmental, LLC

1085C Andrew Drive

West Chester, PA=A0 19380

610-696-9220x12/ fax 610-344-7519

rphifer**At_Symbol_Here**< /p>

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From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of ACTSNYC**At_Symbol_Here**CS.COM
Sent: Tuesday, June 22, 2010 9:09 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] help needed with water discharge limits


I need advice.  As some of you know, the "laboratories" I deal 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 solvents, acids, metal compounds, etc., as you do.

I do building planning.  Among my practices is to obtain from the local waste water treatment plant 1) the limits for solvents, grease, pH, and various 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&S websites.  Large cities often have municipal or state (if they are state colleges) websites they can direct me to.  Small city plants usually send them to me by e-mail. Some colleges have especially low limits because their 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 what 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 acids, cyanide compounds, silver ion, etc., in the drains?   If that's the case, can they deal with sweepings and mop water from the ceramic glaze room floor by dumping it in the sink?  A school in Maine was cited by EPA for 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 their drains?

Surely something is wrong here.  Can anyone help?

Monona Rossol

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