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

EH&S News: EPA Exclusion of Rags and Wipes

Posted by Rebecca McDaniel on Nov 17, 2009 11:38:00 AM

By Kristina Florentino, Environmental Compliance Specialist

Wide arrays of industries use wipes-including rags, shop towels, disposable wipes and paper towels-are used for cleaning, disinfecting and degreasing. These wipes are considered hazardous waste when discarded if the wipes exhibit a hazardous waste characteristic or are contaminated with a listed solvent (RCRA waste codes F001 through F005). Listed waste mixtures are regulated under the Resource Conservation and Recovery Act (RCRA) under the mixture rule, which states that a mixture composed of any amount of a non-hazardous waste and any amount of a listed hazardous waste is considered a listed hazardous waste. Thus, any amount of a listed waste, no matter how minute, when mixed with a large volume of non-hazardous waste, the resulting mixture will carry the same waste code and regulatory status as the initial waste carried. The rule is applicable regardless of the chemical composition and properties of the resulting mixture.

On October 27, 2009, the EPA published a Notice of Data Availability (NODA) in the federal register, 74 FR55163, seeking comments on a revised risk analysis methodology of an earlier proposed rule relating to solvent contaminated wipes. The Proposed revisions relate to RCRA hazardous waste regulations governing the management of solvent contaminated wipes and would exclude these wipes from the definitions of solid and hazardous waste for solvent-contaminated wipes sent to a laundry or dry cleaner and solvent-contaminated wipes sent to a landfill or combustion facility, provided certain conditions are met. If the rule goes final, states with approved RCRA programs would have to adopt the rule into their own hazardous waste regulations before generators could take advantage of this regulatory relief.

The EPA is currently seeking comment on the proposed rule and the risk analysis used. The comment period is through December 28, 2009.

Tags: EPA, Non-Hazardous Waste

Why do I need to label my drums / stock materials / waste?

Posted by Rebecca McDaniel on Nov 4, 2009 12:48:00 PM

By Melissa Iozzo, Technical Specialist

“I know what’s in there!”, “it’s just water!”, “The transporter can label the stuff”.

Sound familiar? Take a walk around your lab or manufacturing floor. You run a tight ship; you have neatly filed folders filled with POs and receipts for materials going for use in all aspects of your business. You know who’s using what, where, when, how much, and at what point you are going to need to order more. So why do you have to label all this stuff!

I’ll tell you – because I don’t know what’s in them, and neither does the EPA, OSHA, the fire department, or any other agency that regularity audits facilities just like yours! It’s called hazard communication – and it’s at the top of the list when talking about safety.

Fines for unlabeled container run high across the board – and they sure can add up; especially if you are being audited by multiple facilities. Furthermore, the EPA and the fire department don’t discriminate – regardless of if you have water, piranha etch, oil, or hydrofluoric acid in that bottle on the sink. 100 mls of 2 gallons – if it’s not labeled, then you aren’t taking necessary measures to keep your employees, visitors, and contractors aware – and that is a safety violation.

Even scarier than fines is the safety of your people – you don’t want to be responsible for a spill, or even worse, an exposure in your facility when you don’t know what the chemical involved in was due to having new labels available! On top of that, if this stuff ends up out on the roads missing the proper labeling and markings, you get a whole new set of agencies and fines to deal with!

Luckily – though it may seem at a tedious task at first, labeling is quick, easy, and can sure save you a lot of time, money, and overall pain in the end – especially if you keep up with it. Triumvirate can help. We can profile your waste streams and stock materials and print out reusable labels for just about anything – so you have to do pretty much nothing!

Tags: EPA, Triumvirate Environmental, OSHA, Safety

Pharmaceuticals in the Water: Compliance and Social Responsibility

Posted by Rebecca McDaniel on Oct 13, 2009 2:45:00 PM

By Bob Shuman, National Healthcare Director

Many hospital organizations today are struggling internally with the dilemma of meeting the regulatory standards for the management, collection and disposal of pharmaceutical waste. This predicament is further complicated with both the uncertainty of the direction E.P.A. is headed with its adoption of its proposed universal waste rule, as well as the harsh reality that many pharmaceuticals developed post-RCRA are far more dangerous to human beings, wildlife and the environment than those currently regulated (and enforced).

Given the latter issue related to those post-RCRA pharmaceuticals, the conundrum arises as to "how much" of the pharmaceutical band-width a hospital should be prepared to collect to achieve both compliance with applicable regulations, and, to also adopt the "socially responsible" position that promotes the preservation of our waterways and drinking water.

To be sure, hospitals are faced with the quandary of where they each feel they should place themselves along the pharmaceutical collection continuum. This decision is not a simple one; it brings to bear questions related to cost, training, time and resource allocation, to name just a few considerations.

In the end, there is no "one" best solution; however, each hospital must take the plunge into the water soon, no matter how cold it may be, at first.

Tags: Waste Disposal, EPA, Drinking Water, Universal Waste Rule, Pharmaceuticals