Date: Thu, 19 Aug 2010 09:05:34 -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: Eric Clark <erclark**At_Symbol_Here**PH.LACOUNTY.GOV>
Subject: Re: Cupric Sulfate Solution Disposal
In-Reply-To: <4C6D4746.3000008**At_Symbol_Here**>
Sometime during the process while you're figuring out how to manage that 
aqueous waste, be sure to contact the POTW and describe exactly what it is 
you'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-dispose of pH-neutralized solutions of certain waste streams with 
very low concentrations of some D-coded metals.  These metals are well 
below the TCLP threshold concentrations and therefore are not HW by EPA's 
regulatory definition.  The POTW engineer might ask you to send a sample 
of that waste stream to a certified environmental lab for a proper 
hazardous waste determination and POTW compatibility testing before he 
signs anything.   

The POTW's major concern is that whatever wastewater they receive doesn't 
somehow kill their colonies of activated sludge.  If that happens, it's 
upsetting 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 talk 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" 
because that's an EPA regulatory term, and Hazardous Waste also carries 
waste codes - and they'll immediately 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 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** 
> ------------------------------------------------------------------------
> *From:* DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**] *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 
> Regards,
> Anthony

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