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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 the Office 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 contact the EH&S off-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 DRAIN DISPOSAL

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 (moderate hazard)

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 and state laws and regulations, by the local East Bay Municipal Utility District (EBMUD) Ordinance and by the EBMUD Wastewater Discharge Permit issued to the campus. These laws and regulations prohibit any drain disposal of hazardous wastes and limit the allowable wastewater concentration of a number of specific substances. The University of California, Berkeley (UC Berkeley) is committed to protection of the local community and the environment through strict compliance with these laws and regulations. Discharge of hazardous chemical wastes into the campus sanitary 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 quantities or in high concentrations. Federal and California laws permit laboratories to drain dispose small amounts of some chemicals in quantities that do not pose a hazard to human health or the environment.

The following guidelines for drain disposal of chemicals at UC Berkeley were developed by the Environmental Management Committee (EMC) together with the Office of Environment Health & Safety (EH&S). These guidelines are based on state law, EBMUD regulations and permits, and on procedures set forth in the National Research Council (NRC) publication "Prudent Practices for Disposal of Chemicals from Laboratories," National Academy Press, Washington D.C., 1983 (Reference 1) and "Prudent Practices for Handling of Hazardous Chemicals in Laboratories," National Academy Press, Washington D.C., 1981 (Reference 2). Drain disposal is permitted by campus policy only within the guidelines set forth in this document.

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

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

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

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

 


2. OVERVIEW OF DRAIN DISPOSAL OF CHEMICALS

Campus interior drains (and several outside drains) are connected to sanitary sewer systems, and their effluent drains to the EBMUD water pollution control plant. Chemicals and some food wastes may be prohibited from drain disposal for a 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 because they:

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

In addition, Bay Area Air Quality Management District (BAAQMD) air toxics regulations require EBMUD to reduce their release of reactive organic gases (ozone precursors) and other toxic air contaminants. One strategy EBMUD uses to reduce air emissions from the water pollution control plant is source control, limiting the release of chemicals through permit restrictions. For example, for the campus EBMUD has set very low limits for discharge of chlorinated hydrocarbons to the wastewater, which are eventually released as toxic air contaminants from the water pollution control 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 a vapor in another. Sinks are usually communal property, and there is a very real hazard of chemicals from two sources contacting one another; the sulfide poured into one drain may contact the acid poured into another with unpleasant consequences for 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 connected to 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 prohibiting the 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 prohibiting the 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 (those that are radioactive and are a chemical hazard)

Waste that contains both a radioactive constituent and a chemical of which either is prohibited from drain disposal is called a “mixed waste.” Disposal of mixed waste into the campus sewer system is prohibited. Exceptions to this policy may be granted by case by case action of the campus RSC and the EMC. Production of 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 disposal of mixed waste.

Drain Disposal of Biohazardous Wastes

Disposal of infectious or biohazardous waste, as defined by the California Department of Health Services (CDHS), into the campus sewer system is prohibited. Infectious or biohazardous waste must be handled, stored, treated, and disposed of in accordance with the California Medical Waste Management Act and requirements of 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 sanitary sewers at UC Berkeley*. Disposal of chemicals is limited to occasional disposal of small amounts of chemicals, as detailed in the guidelines below. Large scale or continuous disposal of any chemical is permitted only with the written approval of the EMC. (EH&S should be contacted to obtain this approval.)

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

(Note**:A compound is considered water-soluble if it dissolves to the extent of at least 3%. In general, a soluble substance that 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 the mixture, drain disposal is usually acceptable because the small quantity of water-insoluble material will be well dispersed in the aqueous effluent.)

b. Only acid and basic solutions in the range of pH 5-10 may be disposed of in 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 materials to sanitary sewers at UC Berkeley. Disposal of radioactive materials is limited to 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 radioactive materials. In addition to meeting the requirements placed on the disposal of radioactive materials to the sewer, the materials must also meet the requirements for disposal of the associated chemicals. The first requirement is to assure that any chemicals associated with the radioactive materials would be allowed to be disposed to the sanitary sewer. If a material cannot be drain disposed based on the chemical nature of the material it can only be disposed of by specific written pre-approval. Normally, this pre-approval will come from the RSC and the 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 aqueous solution. These aqueous solutions are suitable for disposal down the drain in quantities of up to about 100 g of solute per laboratory per day (e.g. 100 g 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 excess water 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 except by written approval of the EMC or their delegate. Normally requests for exceptions are made to EH&S  Environment, Health and Safety who obtains any necessary additional information and coordinates review by the Committee(s).


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

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

Class C chemicals include all chemicals that are not soluble as defined above, chemicals that cause unacceptable concentrations of offensive, toxic or explosive vapors, and chemicals that are toxic or reactive at concentrations below 1 ppm in aqueous solution. Class C chemicals include the chemicals identified in the Main Campus EBMUD Wastewater Discharge Permit "Priority Pollutant Management Plan" Compliance Requirement (Federal Clean Water Act priority pollutants listed in 40 CFR Part 122 Appendix D, Tables II and III). A partial list 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 suitable for 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 quantity wastewater discharges from physical plant equipment can be drain disposed if approved by EBMUD (for example, cooling tower discharges and boiler blow-down).

Following are examples of drain disposable chemicals and process wastewater for shops, physical plant operations, kitchens, janitorial, grounds, and athletic operations.