We are considering switching from receiving our muriatic (hydrochloric) acid, sulfuric acid, caustic and alkaline cleaners in drums or totes to dedicated bulk tanks. Before doing so, we want to know what regulations would apply to aboveground storage tanks for these chemicals in order to account for any regulatory compliance costs?
Is the filter press sludge hazardous even if it doesn’t exceed TCLP requirements?
Are any of these processes considered hazardous because we process aluminum?
How about the polishing filters after the clarifier?
We store all of our materials either inside the plant or in our rear warehouse. Upon review of the last several years of sampling data, it looks like our storm water is pretty clean. In our permit there is some language regarding “no exposure” exemption. Would we be able to qualify for this exemption? How do we get it?
Due to a huge increase in production of our aluminum products, we are evaluating the installation of an anodize line into our plant in order to anodize the parts in house instead of shipping parts off-site. Currently, we do not have any process wastewater discharges to the sewer. However, the scrubber water overflow does go to drain. Because this flow is very small, probably less than 100 gallons per day, the supplier says that this scrubber water can be discharged to the sewer “with no problem.”
We are considering switching to magnesium hydroxide since jar tests indicate a 30% reduction in treatment residue at a pH of 8.5 and still meet our metal finishing pretreatment limits.
How difficult is it to get the required wastewater permits for our discharge? How long does this permitting usually take? Can we start installation of equipment before permits are issued?
Our plant is experiencing wastewater discharge permit excursions on its limits for Total Cyanide as regulated by our very small town. I have about run out of places to look or things to test for and would appreciate any suggestions you have.
Question:
Steve, your column in the September 2005 issue, non-hazardous waste has become hazardous, in which you describe how changes in process and wastewater pretreatment chemistry can have a profound impact upon the filter press cake’s status as a RCRA hazardous or non-hazardous waste reminded me of a situation we had about 10 years ago.
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