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Guidelines for Drain Disposal of Chemicals at University of California, Berkeley
2008


EMERGENCY SPILL REPORTING INSTRUCTIONS:

If a chemical spill enters a sink or floor drain, immediately notify theOffice of Environment, Health & Safety (642-3073) during business hours 8:00 AM—5:00 PM. After business hours, immediately notify UC Police Department (642-6760) and ask them to contactthe EH&Soff-hours emergency responder. EH&S will notify EBMUD of the discharge.

TABLE OF CONTENTS

1. INTRODUCTION

2. OVERVIEW OF DRAIN DISPOSAL 3. OVERVIEW OF DRAIN DISPOSAL OF RADIOACTIVE MATERIALS

4. CHARACTERISTICS OF HAZARDOUS WASTE

5. GENERAL RULES FOR SANITARY DRAIN DISPOSAL

6. SPECIFIC GUIDELINES FOR LABORATORY DRAINDISPOSAL

7. SPECIFIC GUDILINES FOR DRAIN DISPOSAL IN SHOPS,STUDIOS, KITCHENS, JANITORIAL AREAS, GROUNDS,
    ATHLETICS OPERATIONS,MAINTENANCE OPERATIONS AND CONSTRUCTION SITES

8. ACCIDENTAL SPILL PREVENTION AND EMERGENCY NOTIFICATION


APPENDICES:

Appendix I: Class A Chemicals (little or no hazard)

Appendix II: Class B Chemicals (moderatehazard)

Appendix III: Class C Chemicals (high hazard)

Appendix IV: Additional Guidance on the Disposal of Radioactive Materials (all hazards)

Appendix V: Additional Guidance on the Determination of Solubility

Appendix VI: Decision Making Tree

REFERENCES AND EH&S TELEPHONE NUMBERS


Guidelines for Drain Disposal of Chemicals
at University of California, Berkeley


1. INTRODUCTION

Disposal of chemicals into the sanitary sewer is regulated by federal andstate laws and regulations, by the local East Bay Municipal Utility District(EBMUD) Ordinance and by the EBMUD Wastewater Discharge Permit issued to thecampus. These laws and regulations prohibit any drain disposal of hazardous wastesand limit the allowable wastewater concentration of a number of specific substances.The University of California, Berkeley (UC Berkeley) is committed to protectionof the local community and the environment through strict compliance with theselaws and regulations. Discharge of hazardous chemical wastes into the campussanitary sewer system is prohibited by campus policy (Water Protection Policy,http://campuspol.chance.berkeley.eud/policies/waterprotection.pdf).

The range of substances that can be considered hazardous waste is enormous. Indeed,almost any substance is a hazardous waste if it is disposed of in large quantitiesor in high concentrations. Federal and California laws permit laboratories todrain dispose small amounts of some chemicals in quantities that do not posea hazard to human health or the environment.

The following guidelines for drain disposal of chemicals at UC Berkeley weredeveloped by the Environmental Management Committee (EMC) together with the Officeof Environment Health & Safety (EH&S). These guidelines are based onstate law, EBMUD regulations and permits, and on procedures set forth in theNational Research Council (NRC) publication "Prudent Practices for Disposalof Chemicals from Laboratories," National Academy Press, Washington D.C.,1983 (Reference 1) and "Prudent Practices for Handling of Hazardous Chemicalsin Laboratories," National Academy Press, Washington D.C., 1981 (Reference2). Drain disposal is permitted by campus policy only within the guidelines setforth in this document.

Disposal of radioactive materials into the sanitary sewer is also regulated byfederal and state laws and regulations. These limit both the total amount andthe concentration of radioactive materials that may be disposed to the drain.Additionally, solubility limits are also specified. UC Berkeley is committedto protection of the local community and the environment through strict compliancewith these laws and regulations. Discharge of radioactive materials into thecampus sanitary sewer system is authorized by application for and issuance ofa Radiation Use Authorization (RUA). The RUA specifies what materials may bedischarged to the drain and the quantity of these materials that can be dischargedand the rate of discharge.

Guidelines for drain disposal of radioactive materials at UC Berkeley were developedby the Radiation Safety Committee (RSC), the EMC, and EH&S.

These guidelines were revised in 2006 - 2007 to consolidate all campus operationsthat discharge to sanitary sewers including maintenance, custodial, and foodservice operations, and to include all types of wastes; nuclear, biological,radioactive, and chemical.  In addition, this revision includes referencesto several new laws and regulations.  This version of the Drain DisposalGuidelines replaces any previous versions.

Notice:
EBMUD regularly monitors campus wastewater. Failure to comply withwastewater discharge regulations could lead to fines of up to $25,000 per dayand/or restrictions on University water use.

 


2. OVERVIEW OF DRAIN DISPOSAL OF CHEMICALS

Campus interior drains (and several outside drains) are connected to sanitarysewer systems, and their effluent drains to the EBMUD water pollution controlplant. Chemicals and some food wastes may be prohibited from drain disposal fora variety of reasons.

Potential Problems at EBMUD Water Pollution Control Plant:

Chemicals and some food wastes may be prohibited from disposal to the water pollution control plant becausethey:

UC Berkeley policies governing drain disposal of chemicals and certain food wastes to campus sewers have specificallybeen formulated to comply with these prohibitions.

In addition, Bay Area Air Quality Management District (BAAQMD) air toxics regulationsrequire EBMUD to reduce their release of reactive organic gases (ozone precursors)and other toxic air contaminants. One strategy EBMUD uses to reduce air emissionsfrom the water pollution control plant is source control, limiting the releaseof chemicals through permit restrictions. For example, for the campus EBMUD hasset very low limits for discharge of chlorinated hydrocarbons to the wastewater,which are eventually released as toxic air contaminants from the water pollutioncontrol plant.



Potential Problems in Drains and Campus Sewers:

Chemicals and some food wastes may be prohibited from disposal to laboratory drains because they can:

Campus drains are generally interconnected; substances that go down one sink drain may well come up as avapor in another. Sinks are usually communal property, and there is a very realhazard of chemicals from two sources contacting one another; the sulfide pouredinto one drain may contact the acid poured into another with unpleasant consequencesfor all in the building.

Much of the campus plumbing infrastructure is old and may not be resistant to chemicals placed into the drains.The cost of replacing corroded plumbing can easily exceed the cost of disposal of corrosive chemicals as hazardous waste.

 


3. OVERVIEW OF DRAIN DISPOSAL OF RADIOACTIVE MATERIALS

Radioactive materials may only be disposed to campus interior drains connectedto sanitary sewer system.

Potential Problems at EBMUD Water Pollution Control Plant:

Radioactive materials could “settle out” or concentrate in the plant. UC Berkeley avoids this problem by prohibitingthe disposal of materials that can re-concentrate in the system.

Potential Problems in Drains and Campus Sewers:

Radioactive materials could “settle out” or concentrate in the sewer lines. Again, this is avoided by prohibitingthe disposal of materials that can re-concentrate in the system.

 


4. CHARACTERISTICS OF HAZARDOUS WASTES

Hazardous wastes are prohibited from discharge. Chemical wastes are hazardous if they are:

Drain Disposal of Mixed Wastes (thosethat are radioactive and are a chemical hazard)

Waste that contains both a radioactive constituent and a chemical of whicheither is prohibited from drain disposal is called a “mixed waste.” Disposalof mixed waste into the campus sewer system is prohibited. Exceptions to thispolicy may be granted by case by case action of the campus RSC and the EMC. Productionof mixed waste is to be avoided or minimized. When mixed waste is generated,store it in a safe and protected location. Contact EH&S (642-3073) for disposalof mixed waste.

Drain Disposal of Biohazardous Wastes

Disposal of infectious or biohazardous waste, as defined by the CaliforniaDepartment of Health Services (CDHS), into the campus sewer system is prohibited.Infectious or biohazardous waste must be handled, stored, treated, and disposedof in accordance with the California Medical Waste Management Act and requirementsof Biological Use Authorizations(BUAs).

 


5. GENERAL RULES FOR SANITARY DRAIN DISPOSAL

A. General Rules for Sanitary Drain Disposal of Non-Radioactive Materials

The following general rules apply to drain disposal of chemicals to sanitarysewers at UC Berkeley*. Disposal of chemicals is limited tooccasional disposal of small amounts of chemicals, as detailed in the guidelinesbelow. Large scale or continuous disposal of any chemical is permitted only withthe written approval of the EMC. (EH&S should be contacted to obtain thisapproval.)

a. Only water-soluble substances** may be disposed of in sinks, toilets,and floor drains. Solutions should be flushed down the drain with an appropriateamount of water. (Residue animal or vegetable fats and oils generated as a resultof normal cleaning activities are an exception to the solubility rule. However,significant amounts of these oils and fats (approximately more than a pint) cancause clogging in interior drains and so should be collected and disposed ofappropriately (see Appendix V for additional guidance on solubility).

(Note**:A compound is considered water-solubleif it dissolves to the extent of at least 3%. In general, a soluble substancethat contains a substance that is not soluble should not be poured down the drain.However, if the water-insoluble material comprises less than about 2% of themixture, drain disposal is usually acceptable because the small quantity of water-insolublematerial will be well dispersed in the aqueous effluent.)

b. Only acid and basic solutions in the range of pH 5-10 may be disposed ofin the sink.

c. Highly toxic, malodorous, or lachrymatory (that is, those that cause strong eye irritation) chemicals shall not be disposed of down the drain.

d. Old, unwanted, or waste chemicals and products must not be poured down the drain as a means of disposal. These materials must be picked up by EH&S personnel.
* Adapted from Reference 2, pp 231-232.

** Adapted from Reference 1, pp 52-53.

B. General Rules For Sanitary Drain Disposal of Radioactive Materials

The following general rules apply to drain disposal of radioactive materialsto sanitary sewers at UC Berkeley. Disposal of radioactive materials is limitedto occasional disposal of small amounts as detailed in the user-specific permit(the RUA) that both authorizes the work and may permit sewer disposal of radioactivematerials. In addition to meeting the requirements placed on the disposal ofradioactive materials to the sewer, the materials must also meet the requirementsfor disposal of the associated chemicals. The first requirement is to assurethat any chemicals associated with the radioactive materials would be allowedto be disposed to the sanitary sewer. If a material cannot be drain disposedbased on the chemical nature of the material it can only be disposed of by specificwritten pre-approval. Normally, this pre-approval will come from the RSC andthe EMC. EH&S will coordinate these special reviews. Please contact EH&S so that specific pre-approval can be sought and approved or rejected.

  1. Just as with chemicals, only water-soluble substances** may be disposed of in sinks, toilets, and floor drains.

  2. Solutions must be flushed down the drain with an appropriate amount of water.

  3. Radioactive material to be released must qualify as being "readily soluble” in water. EH&S will work with you to assure that your wastes are “readily soluble.” (See Appendix V)

 


6. SPECIFIC GUIDELINES FOR LABORATORY DRAIN DISPOSAL

We divide chemicals into three groups with regard to drain disposal in laboratories: (1) Class A.
Class A includes chemicals that pose little or no hazard in dilute aqueoussolution. These aqueous solutions are suitable for disposal down the drainin quantities of up to about 100 g of solute per laboratory per day (e.g. 100g of ethanol in one liter of water).

(2) Class B.
Class B includes chemicals of moderate hazard in dilute aqueous solution.These aqueous solutions are suitable for disposal down the drain with excesswater in quantities no greater than 1 g of solute per laboratory per day.

(3) Class C.
Class C includes chemicals that may not be drain disposed in any amount exceptby written approval of the EMC or their delegate. Normallyrequests for exceptions are made to EH&S  Environment, Health and Safetywho obtains any necessary additional information and coordinates review by theCommittee(s).


Class A chemicals include many simple organic and inorganic compounds,as well as common inorganic chemicals. Included in Class A are most biologicalmetabolites and nontoxic cellular constituents (proteins, nucleic acids, carbohydrates,soluble fats, and their precursors and catabolites). A partial list of ClassA chemicals, derived from State regulations and Appendix K of Reference 2, isprovided below inAppendix I.

Class B chemicals include all of the chemicals listed as toxic (T) inthe California Code of Regulations Section 22-66261.30 et. seq. that are watersoluble, except for those listed as Class A chemicals in Appendix I or ClassC chemicals in Appendix III. Class B chemicals also include all inorganic saltslisted in reference 2 as "high hazard" in tables 6.1 and 6.2. A partiallist of Class B chemicals appears in Appendix II.

Class C chemicals include all chemicals that are not soluble as definedabove, chemicals that cause unacceptable concentrations of offensive, toxic orexplosive vapors, and chemicals that are toxic or reactive at concentrationsbelow 1 ppm in aqueous solution. Class C chemicals include the chemicals identifiedin the Main Campus EBMUD Wastewater Discharge Permit "Priority PollutantManagement Plan" Compliance Requirement (Federal Clean Water Act prioritypollutants listed in 40 CFR Part 122 Appendix D, Tables II and III). A partiallist of Class C chemicals appears in Appendix III.

 


7. SPECIFIC DRAIN DISPOSAL GUIDELINES FOR SHOPS, STUDIOS,KITCHENS, JANITORIAL AREAS, GROUNDS, ATHLETICS OPERATIONS, MAINTENANCE OPERATIONS,AND CONSTRUCTION SITES

Drain Disposable Chemicals and Process Wastewater

Chemicals and wastewater of little or no hazard in dilute solutions are suitablefor disposal down the drain in quantities that would be expected in normal operations(for example, latex paint brush wash-water or a bucket of mop water). Large quantitywastewater discharges from physical plant equipment can be drain disposed ifapproved by EBMUD (for example, cooling tower discharges and boiler blow-down).

Following are examples of drain disposable chemicals and process wastewaterfor shops, physical plant operations, kitchens, janitorial, grounds, and athleticoperations.