Date: Tue, 22 Jun 2010 12:38:23 -0500
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From: "Long, Don" <don.long**At_Symbol_Here**WGINT.COM>
Subject: Re: 2 RE: [DCHAS-L] help needed with water discharge limits
In-Reply-To: A<10B7AF91-9980-4D60-BF35-03D585DFA109**At_Symbol_Here**>

Another thought could be NOT to dispose of the wastes in this manner at all. In almost all laboratories, there are other haz-wastes that are generated and managed - not just the stuff you can run down the drain. If this lab is already or will be producing/managing other haz-wastes it should not be that difficult to characterize, manage and dispose the new waste streams. Then the waste will be known to be disposed of properly and the area water supply won't be compromised.
And remember, just because it MAY be okay today to dump it down the drain, it doesn't mean it'll be okay in 5 years. And the damage and liability will still be there.
Just some thoughts..........

Don A. Long
Southwest Research Institute Laboratory
Pine Bluff Chemical Agent Disposal Facility
PO Box 20130
White Hall, AR  71612

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Subject: [DCHAS-L] 2 RE: [DCHAS-L] help needed with water discharge limits

From: "Subramanian, Venkatraman" <Venkatraman.Subramanian**At_Symbol_Here**aa .com>
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)
venkatraman.subramanian**At_Symbol_Here**aa .com


From: "Dave Einolf" <dave**At_Symbol_Here**>
Date: June 22, 2010 11:19:52 AM EDT
Subject: RE: [DCHAS-L] help needed with water discharge limits



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.






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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