Environmental Health & Safety Compliance Blog

Meeting metal limits in wastewater discharge permits

Posted by Rebecca McDaniel on Mar 23, 2010 7:36:00 AM

 The importance of proper sample collection.

By Sandy Perry, Director of Water Management and Wastewater Services

Whether you discharge to the sewer or directly to a water body, the importance of collecting truly representative samples of your treated wastewater cannot be overstated. So what does "representative" mean? It means that:

  1. your wastewater treatment system is operating properly,
  2. you've selected a day to sample that is typical of your daily operations,
  3. your composite sampling equipment is set up to take flow proportioned samples properly,
  4. your flow meter is sized appropriately for your flow rates and is calibrated at least annually, and finally,
  5. the sampling equipment and collection containers are clean!!

To my last point, the last thing you want is a cross-contaminated sample. If you think about it, there are actually quite a few opportunities for contamination. And with metals limits in parts per billion, it doesn't take much to tip the lab results over the limit.

Dischargers should check with their sampling contractor regarding their procedures to prevent sample contamination. Do they change the pump tubing or just rinse it out between yours and another client's sampling? Do they acid wash and rinse the collection container? And how does he or she appear when they are onsite to setup and collect the samples - is their appearance neat and clothing clean? Even dirty hands and dust/dirt on clothing can be a potential source of contamination.

Did you know that in some areas of the country, dischargers are subject to limits in parts per trillion (Maine and the Great Lake areas' mercury limits are in ug/L) and must perform "clean sampling"? The U.S. EPA's Clean Sampling guidance includes using non-metal sampling equipment, and wearing tyvek suits and gloves, and even warns against breathing near the sample (ex. mercury in dental fillings).

You might also check with your contractor to find out if they perform periodic equipment or field blanks as part of their Quality Control program? Do they have a Quality Control Program? Non-compliance is not a pleasant situation to be in and can lead to enforcement actions including fines and penalties. Don't take a chance, make sure that your samples are being collected properly to ensure that your data is "representative" of your discharge.

Tags: EPA, Compliance, Wastewater

Do I Really Need to Label Everything?

Posted by Rebecca McDaniel on Dec 23, 2009 10:43:00 AM

By Greg Brady, Operations Coordinator

One of the most important, but often overlooked, aspects of chemical management is the proper labeling of chemical containers. In the interest of safety, it is important that all chemicals, used and unused, are clearly labeled and if your facility has a Hazard Communication Plan, it is a requirement. It is crucial in maintaining a safe working environment that the people that are working at your facility are very clear on what they are working with. It is also essential in the event of an emergency response, that the people responding know what materials are in use as well as what materials may have been released. When managing chemicals that are considered hazardous waste, there are four essential requirements for your label:

• Containers must be labeled with the words “HAZARDOUS WASTE”.

• Containers must be labeled with all of the constituents. Constituents must be written clearly and completely without using abbreviations or chemical formulas. It’s also a good idea to use pencil instead of pen so that if the tag gets wet, the constituents can still be read.

• One or more of these four hazard classes must be checked: Ignitable, Corrosive, Reactive or Toxic. Additional information can be included on the tag for informational purposes such as oxidizer, but it is not required.

• Containers must be dated when they are full or no longer in use. Depending on your facility requirements, you must then dispose of the waste within a certain amount of time.

By following these simple guidelines, you can ensure that your facility continues to be a safe place to work while maintaining compliance.

Tags: Emergency Response, Safety, Compliance, Chemical Management

Main Accumulation Area Compliance: Time for a Refresh?

Posted by Rebecca McDaniel on Dec 21, 2009 2:07:00 PM

By Alexa Kaubris, Chemist

With all the rules and regulations, things can get confusing when you have an entire room filled with chemicals. If you’re overwhelmed don’t worry you’re not alone. Here are some helpful hints and reminders when inspecting or reorganizing your MAA in Massachusetts. Don’t forget, not only are there a ton of rules but they change from state to state.

1. Every hazardous waste bottle in the MAA needs a label with a) the words “Hazardous Waste” b) the constituents of the container written in full (no abbreviations or chemical formulas) c) the hazards of the bottle identified (corrosive, ignitable, etc.) d) the date the container was filled in its respective satellite accumulation area (SAA) or the date accumulation began if you fill drums in the MAA.

Do: Make sure you can see this label.

Do: Make sure the container is closed tightly.

Do: Inspect the containers for leaks and cracks.

Do: Make sure the label is on the side of the containers (not on the top).

Hint: It’s always a good idea to label empty drums and containers in the MAA for clarity.

2. These bottles should be segregated out into secondary containment bins so that incompatible chemicals won’t react and an underlying impermeable surface will be ensured.

3. The room itself needs to have an impervious underlying surface, a base that slopes or elevated containers in case of a leak, and run-on needs to be prevented unless containment has excess capacity. Basically, if you have a spill, you need to make sure the other chemicals you are storing in the MAA won’t be sitting in the mess.

Do: Check expansion joints on concrete pads.

Do: Make sure there are no drains in the MAA.

Do: Make sure every hazardous waste container in the MAA is in a designated area for waste. Putting tape on the floor is a quick way to delineate the waste area. Everything else should be stored elsewhere in the MAA.

Hint: For best management practices any material labeled as non-hazardous should be kept separate for the hazardous material.

4. Watch out for aisle spacing! If the waste is not reactive or ignitable all you need is enough room to inspect each row. If the waste is ignitable or reactive you need four feet as required by the NFPA chapter 30.985(3).

Hint: If you’re tight on space, one solution is to make a double row of drums back to back in the middle of the room and then give 4ft to either side. Another is using a pallet to separate containers if you need to stack them.

Fast Facts: Reactives/Ignitables need to be stored 50 feet from the property line. The fire department does not like Reactives/Ignitables to be stored in underground rooms like basements (waste or not). The idea behind this being safety of personnel that would have to respond to a fire in a basement when there are limited entrance/exits.

Good luck and have fun! Be sure to take before and after pictures. Make-overs are the best!

Tags: Hazardous, MAA, Main Accumulation Area, Compliance