# EPA Regualtion Documents



## lazersteve (Mar 7, 2008)

All,

This is the first of several US governmental guideline posts I'll be making.

Here's a good document I compiled today to give you all some of the EPA's ground rules for precious metals recyclers. I tried to include the various reference documents in the binder. You should be able to follow the hyperlinks by ctrl-clicking the links in the document.

EPA Requirements


Steve


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## chris66 (Feb 7, 2012)

I am a 66 yrs. old retired person living in Northern Nevada living in a area that has silver minning now, also historically had the bigest silver find in the world, I have 4.8 acres of land with silver, with possible flower gold or finer, (some miners refer to as yellow rock) I do not wish to use mercury or cynide, instead I have a document with chemical instructions with several elements that after its use can be neautralized with baking soda...considered environmentaly friendly by most (not all), that I have had for more then 30 yrs. I asked a high school, college chemistry teacher if it would work, he said yes it would (probably before this web site was ever created) Nevada has the highest unemplyment in the USA. I wish to get a permit for a hobiest, WHERE CAN I GET A PERMIT AS A HOBIEST? In the the future I would like to teach others(the unemployed) to help themselves. Also direct them to this web site. It is a wonderful, very helpful web site.


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## jack_burton (Feb 7, 2012)

Chris, I would think you should start with finding a NV BLM office near you, I am certain a clerk or official there can lead you in the right direction. I'd be willing to bet that if A. You owned the land and B. You are only planning to prospect as a hobbyist; you probably don't need a ton of permits.

Here is a link to find a BLM office near you, since you mentioned Silver, I'm guessing you are near Elko? or somewhere NE NV? http://www.blm.gov/nv/st/en.html


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## goldsilverpro (Feb 7, 2012)

Excellent, Steve!


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## publius (Feb 7, 2012)

goldsilverpro said:


> Excellent, Steve!


+1 8)


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## learn2live34 (Aug 8, 2016)

MO Department of Natural Resources is coming out for a inspection of my area that i have been learning all my refining studies. Im working on building a recpectfull business and i was calling around asking questions about filling out the EPA ID certification and it led me to calling the DNR. Now they want to schedule a meeting to come out and look everything over. Im nervous but it will be good to talk to them to give me the confidence to proceed with the refining studies. Or shut me down. The reason im getting the nerve to post other than just reading is because if i am going to ask for help, its going to be making the the goverment officials happy. So if you sucessful refiners have a check list or any pacific they will be looking at? Any advise would be awsome and more appreciated than you will ever know. I am so nervous . Thanks for any help


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## Lou (Aug 9, 2016)

Why would DNR have anything to do with your operations? Wrong fox, wrong henhouse. It's an EPA matter and unless you're above a certain threshold in generator status, are woefully mismanaging your waste and criminally polluting...they have much bigger fish that truly deserve frying. 

I do not know how large your business is, the waste stream(s) and many other factors but seems to me to be an unnecessary hassle.

In any event, I'd simply sit and have them do all the talking. I don't see any reason for a show and tell.

If you are doing R&D work to start your business and are not doing anything, for lack of better words...stupid and irresponsible, you should enjoy quite some leeway from a regulatory perspective.

Ignorance is no excuse of the law!


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## 4metals (Aug 9, 2016)

The Missouri DNR is the legal arm of the EPA in Missouri so they are the ones who will be doing the checking and listing any violations at your facility.

You have told us little of your operation but as Lou says, listen to their questions and do not offer up too much. If you are an existing operation, they will look at things like waste holding areas, whether or not they have proper containment berms, and whether or not all drums are labeled. 

They like to see records of incoming chemical purchases, as well as documentation of all hazardous waste leaving the facility. If you never had a EPA ID# that better be none! They also like to see a book full of MSDS's for all the chemicals you have on site. 

If your production exceeds certain parameters, they will require fume scrubbing on your air emissions. If you are small you can likely apply for a "de minimus" status as you will not be producing the quantities of pollutants they chase around after. (unless someone complains) Usually de minimus status is applied for and granted after an application process is submitted by a licensed PE in your juristiction. 

If you provide some details we can tell you what similar site visits would entail in other states, while the laws differ, the inspections seem to look for the same things.


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## learn2live34 (Aug 9, 2016)

Well where to start. I really got started studing and learning to refine after i perchased some uw-195 from uwin nanoteck. Wich was my first screw up. Because they wouldnt teach me how to recover the pgms out of solution ounce leached out of catalyic converters without a hansome fee. On top of that i still pechased, when i didnt ask all the questions to a refiner to get all the facts to consider when they except pm leaching solutions... 
The Uwin nanotech rep and i agreed that when i perchase there PT leaching, UW-195, that i would just leach and ship pregnant solution to a refiner and i wouldnt have nothing else to worry about. Just get payed for the leached pgms. Which sounded great. So i made the perchase and started to call refiners. Which i should of made befor i made perchase because thats when i found out that they didnt except anything smaller than a 55gal drum full to be profitable for everone..
I figured i good start smaller , like cashing in on a 5gal bucket and scale up from there, but that wasnt the case. The uw-195 is one part uw-195 and one part 65% nitric. Which to make a 55gal drum full it would be like $1000 in just the cost of nitric. ... Which is very expensive leaching methods. Still going to use the stuff but i started learning other methods to build the capitol to perchuse the nitric.
Now that i have started reaching out for other methodes, i perchased lazersteves cc pgm refining method wich worked great and i was successful other than getting my palladium to drop but thats another story. 
Now with Steve's method i zinced the hcl+cl and then and then used the classic AR methed with the pgm black, then i nutrlized acid with sodium carbcarbonate. I filtered the nutrlized solution, doubled the volume with water and dumped the nutrlized waste and kept, what i guess is zinc carbonate of sort. 
But i am learning more eco friendly methods. I perchased a sample of the eco goldex. Havent tried it yet.. Ganna wait till after DNR get done at my place. I am also working on getting my license with another paten through Sasckatchewan University. They want to make sure i am completely legal and have all my certifactions befor they give me there refining tech.
But there it is, everything that i have been up to and your coments have been much appreciated. Looking to here back from you all. As always thanks Lean2live


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## learn2live34 (Aug 9, 2016)

I called sunbelt waste disposal and asked them things to be propared for there vist hecause they are the ones who recomened me to call DNR. They just asked me if i had something for the spills. Which i have cat litter. He asked me about my ppe. I got everything there. Told me to make sure everything is stored properly and securely. Asked me how i do my process and im working on building a simple fume hood now. But at the moment i do my AR and so on in a pallet made fence around my processes and work area. Told me to make sure i have my msds sheets. And that about sums up are coversation and said i should be ok for the first part. I know they will find stuff for me to corrcet and make better which this i welcome with open mind, but im just scraed that they will shut me down and worst. Im usually a skeptic and think the worst.


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## 4metals (Aug 9, 2016)

According to UWin nanotech's website a 55 gallon drum will hold $21,000 worth of palladium. You seem to be shopping around and not settled on a method and you may have shot yourself in the foot by calling the DNR. Do you have a substantial quantity of converters to process? Are you willing to not recover the Rhodium? Have you stripped converters with the uw 195? 

I think you need to work out your process first, if you haven't done much processing the DNR will be easy to please, they just want to see what chemicals you are using and how much. And how you dispose of any waste. From what you have said if you ship acid containing precious metals to a refiner that is exempt from hazardous waste manifesting but the refiner needs to have the proper permits to pick it up.


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## learn2live34 (Aug 10, 2016)

The reason i didnt continue using uw-195 is because i didnt realize i would need another $1000 for nitric acid to be able to strip a 55gal full. And i dont have $1000 for the nitric at the monent. Thats why i said im looking for cheaper method to earn some capital for the nitric. Ontop of that Uwin told me that it would be $10000 for them to teach me PM recovery out of uw-195. She did send me the flow chart to percipitating the pgms out but never told how to use it. Maybe ill set another post of the flow chart and see if anyone here good work it out. The lady from Uwin asked not to show it to anyone tho. Should i honer her request and keep flow chart to myself?

The reason i called DNR is because i was updating my EPA Id application and i was trying to figure out if i was considered a treater if i treat my own chemicals. Besides i dont think i shot myself in the foot because i am not trying to hide nothing from no one. Im trying to build a respectfull company so if they could come in and help out and tell me what to do better, than im all for it. The DNR said i would be ok as long it wasnt total chaos. I guess she could just be saying that to get thereself in the door. 
Yeah i have a steady suply of catalyic coverters. I work at a tow company and my boss has gave me title to all cc. Yeah im going for Rhodium. Lol i go for any PM that i can. Why you ask if im going for Rhodium? Yes i have used and have about a half gal left from a pregnant solution. I had a gal of it but i tried working out the flow chart and got half of gal left. 
No i havent done to many proccess. I have been working slow trying to learn and get set up in proper refining techniques and enviroment. I got till this 24th to fix anything that might be a danger to me or the enviroment. 
As always i want to thank you and guess i need not to be such a stranger on the forum.


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## 4metals (Aug 10, 2016)

I have found that catalytic converters are processed in Europe in plasma arc furnaces at very reasonable rates, much better rates than you will spend on chemistry to solvate the PM's and equipment to recover the metals. 

You need a Cat Guillotine to de-can the converters and separate the matrix that holds the PM's from the steel housing. https://www.youtube.com/watch?v=Cf5YgUBCAWY Then you can crush and blend and prepare homogeneous samples to know what you have before you ship. 

You can accomplish the same thing with a shear and dust collectors but these units make life easier and the workplace cleaner and healthier.


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## learn2live34 (Aug 10, 2016)

Johnson Matthey is another magor PGM refiner also here in the US. And yes sure all that equipment and technology they have would be nice but you are talking to someone working on a shoe string budget. Starting with nothing , trying to end with something more than just a hoppy. 
So far my plan is to have my msds sheets, have something for spills if there ever was any, have my ppe, have my chemicals in proper containers, and have hazordous stickers on my containers with them. The only thing i can think of is that i dont have is a fume hood and a air scrubber. Ill be sure to keep you guys informed. Ahh Two weeks away tell they show up.


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## FrugalRefiner (Aug 10, 2016)

If you've got two weeks, you should be able to put together some kind of basic fume hood & scrubber. It doesn't have to be top of the line. If you have something, it's better than nothing.

Dave


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## learn2live34 (Aug 10, 2016)

Working on it. I was able to buy my inline blower motor yesterday. I need the funds to buy the plexy glass and some paint, oyeah the pvc pipeing. Got to get more ink for printing msds sheets. Its stuff that is able to be accomplished but is just something that takes time and money. Fortunately in this field, its not the cheepsest hobby or buisness.


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## butcher (Aug 10, 2016)

learn2live34,
The more you educate yourself the cheaper it is.
You do not have to spend a lot of money up front.


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## learn2live34 (Aug 11, 2016)

Butcher, 
All i do is read, watch videos on how to refine. If you put it that way. I could just use a good size reaction vessel with a single hole stopper, with a hose running out away. Matter of fact it would save a little power running a electric powed fume hood. Got ideas to build it cheaper.


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## FrugalRefiner (Aug 11, 2016)

learn2live34 said:


> Butcher,
> All i do is read, watch videos on how to refine. If you put it that way. I could just use a good size reaction vessel with a single hole stopper, with a hose running out away. Matter of fact it would save a little power running a electric powed fume hood. Got ideas to build it cheaper.


If you run that hose to a simple scrubber and put just a bit of vacuum at the end of the scrubber system, you'll be well on your way. 4 metals has shown a classic system.

Dave


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## learn2live34 (Aug 11, 2016)

Thank you Dave, 
You know its just that there is alot of information to take in, it can be a bit overwhelming, and its guys like you make life so much easier. I really think if i could show the DNR that i am in the working progress of accomplishing these things. As well as ppe, storage of chemicals, proper disposal of the waste, and proper labeling. I mean am i missing anything. I feel im ready for them to show up.


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## kurtak (Aug 12, 2016)

learn2live34

Take some advice from someone (me) that has already tried to do a "large scale" CAT PGM leaching process

Forget it :!: --- you are far better off de-canning the combs from the housing (as suggested by 4metals) & sending it to a company like Johnson Matthey

Here is a link to a thread I posted concerning leaching CATs :arrow: http://goldrefiningforum.com/phpBB3/viewtopic.php?f=51&t=20573&hilit=CATs

At the time I got side tracked & did not quite finish the thread - BUT - I posted enough info to show why trying this is a losing proposition 

To put it in perspective - I put a year into the project - working with a local scrap yard (so had access to LOTs of CATs) We had all of our DNR/EPA permits in place - 4 LARGE fume hoods with scrubber in place (for hood fume control) & we had reaction vessels from 20 liter in size up to 30 gallon in size & again set up with a vacuum fume scrubber system hooked direct to the reaction vessels

I admire your desire, drive & approach but I think you are going to find you are chasing a losing proposition - again - speaking from experience

So (again) I suggest you follow this advice given by 4metals ------



> I have found that catalytic converters are processed in Europe in plasma arc furnaces at very reasonable rates, much better rates than you will spend on chemistry to solvate the PM's and equipment to recover the metals.
> 
> You need a Cat Guillotine to de-can the converters and separate the matrix that holds the PM's from the steel housing. https://www.youtube.com/watch?v=Cf5YgUBCAWY Then you can crush and blend and prepare homogeneous samples to know what you have before you ship.
> 
> You can accomplish the same thing with a shear and dust collectors but these units make life easier and the workplace cleaner and healthier.



Kurt


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## learn2live34 (Aug 13, 2016)

Yeah Kurt i know exactly how you feel about proccing cats. Let me tell you, if you can master the filtering your a mile ahead. But i was amazed how much solution cats held. They are a ton of work. I have studied refining pgms out of cats. alot more than studing refining ewaste. I have got little Au from ewaste, so i got a good concept on how it works. I can tell you gold is alot less labor intensive and less waste.
But im trying to stick to the problem at hand. What kind of things will DNR be checking for. Be nice that im doing everthing within EPA codes. You know i try to be safe and do it right. I have no interest hurting my self or my enviroment.


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## kurtak (Aug 13, 2016)

learn2live34 said:


> Yeah Kurt i know exactly how you feel about proccing cats.



It has nothing to do with how I "feel" about it - its what I know about it - did you read the thread I provided the link to :?: 



> Let me tell you, if you can master the filtering your a mile ahead.



Filtering is not the problem - unless you crush the CAT combs before leaching --- crushing the CAT combs is a BIG mistake & creates a filtering nightmare - they need to be leached as whole CAT combs --- but that does not solve the real problem 

The real problem is that you WILL NOT leach all of the values out of the CATS --- at least not with a HCl/chlorine leach - or AR leach --- (1) "in part" that is due to the solubility of the metals them selves - (2) another part is due to the different wash coats used by different companies to apply the PGMs to the ceramic comb substrate - (3) & yet another part is due to the construction of the CATs - (4) & yet another problem is the HUGE amount of waste you are going to create - which then needs to be dealt with

All 4 of these things (& other problems) are explained - "in detail" in the thread I provided a link to in my last post --- read it & re-read it till you understand why trying to leach CATs as a profit making venture is a "losing proposition" 

Save your self some time & money (because it will cost you more to try to leach CATs then you will get out of them) & a lot of hassle

If I where you - I would call the DNR up & tell them after doing more research & talking with people in the know - that you have decided to abandon the idea of trying to recover the PGMs from CATs & so there is no need for them to come & look at anything because (1) instead you are ether going to simply sell your CATs directly to a CAT buyer - or - (2) de-can them & send the recovered combs to a company like Johnson Matthey for refining

Trust me when I tell you --- you will be WAY ahead of the game & make more money - with less hassle - with ether one of those two options --- or you can go ahead with your plan A & find out the hard way - the "truth" of what I am saying

To clarify let me put it another way - if leaching CATs was a "profitable" venture --- after investing one full year of my time & something like $45,000 - 50,000 (on top of my time) --- I would still be doing it - but I am not :!: 

Kurt


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## glorycloud (Aug 13, 2016)

Simple Definition of loose: not tightly fastened, attached, or held

Definition of losing : resulting in or likely to result in defeat <a losing battle> <a losing poker hand>

8)


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## kurtak (Aug 13, 2016)

glorycloud said:


> Simple Definition of loose: not tightly fastened, attached, or held
> 
> Definition of losing : resulting in or likely to result in defeat <a losing battle> <a losing poker hand>
> 
> 8)



 Now edited in both posts :mrgreen: 

Kurt


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## nickvc (Aug 13, 2016)

Kurt is right I'm afraid, as a commercial venture this won't succeed unless you get the cats very cheap or free.
No serious large refiner uses wet processing for them and the first plasma arc set up I saw was in the USA, and that was many years ago.
We had a member who was a very large trader in cats and he spent 100s of thousands of dollars trying it only to discover his loses were bigger than the refining charges from the big boys so he went back to trading, de canning, milling, sampling and shipping the powders on agreed assays.
You need deep pockets for this as the returns are 90 days at best so you need enough cash to keep you running for 120 days plus.
If you want to get into refining find an easier route such as e scrap, which isn't easy these days, or industrial bearing scraps with values, they are out there, finding them is the hard part.


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## kurtak (Aug 14, 2016)

nickvc said:


> Kurt is right I'm afraid, as a commercial venture this won't succeed unless you get the cats very cheap or free.



Even if he gets the CATs for cheap &/or free its still a losing proposition (he "might" make a profit if he gets the Cats cheap or free) but by the time you figure cost - both to set up AND process - waste treatment - & time/hassle to process etc. etc. - you are still going to be WAY ahead to simply selling out right to a CAT buyer - or - de-can & send to a refiner the specializes in CAT refining

The other thing - besides ALL the problems associated with leaching CATS - what has not yet been said is "the almost certain" exposure the PGM toxicity - unless you are set up with a VERY well equipped lab with VERY well controlled handling &/or environment

Just hope he listens to the advice being given here

Kurt


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## learn2live34 (Aug 14, 2016)

It has nothing to do with how I "feel" about it - its what I know about it - did you read the thread I provided the link to


Ok kurt let me put it thid way, I know eaxtly what you know about leaching cats. You prob know quiy a bit more about it because i didnt try to go such as big dcale as you did. And im glad i didnt. Cant believe you jumped into it at a large scale before doing smaller batches to learn the process . Or maybe you did and i missed it or forgpt about reading in your thread. So yes that answers your question if i read your thread. Yes i did read it. 
Now you told me i should call the DNR and tell them to foeget about them coming.. I dont think i want to do that because there other PM scrap to recover and to be refined and i attend to do so. If i can get with the DNR and set down with me face to face and have a heart to heart discussion, it will be good for me to learn what it will take to be safe for myself and the enviroment. Feeling more comfident in what doing and proceed in my refining studies.
If i can get legal and all my permits, i have universty in canada are going license me for there refining technology patent.
So guys please im not disagreeing that leaching methods on cats are profitable but that is not the task at hand. That is a total different post. Can we please stick to the topic"things that i need to be in place to make dnr and epa happy."


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## Palladium (Aug 14, 2016)

Your search seems to be one that is strictly knowledge driven. I think your missing the equally important aspect of wisdom.


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## learn2live34 (Aug 14, 2016)

quote="Palladium"]Your search seems to be one that is strictly knowledge driven. I think your missing the equally important aspect of wisdom.[/quote]



Could you please explain? 
I appreciate the insight of refining cats but my problem at hand is not profiting off refining at the moment, its just able to do it safe for myself and my surrounding within the EPA laws. 
Im asking if i have my MSDS, everthing labeled, hazardous labels and placards, my PPE, and proper clean up procedures in spills would this be heading in the right direction within EPA regulations. I still need to build myself a fume hood and scrubber. I dont know if it will be a big issue with them. Someone earlier said the fumehood and scrubber might not be an issue because im such a small waste generator. But i hope they will see that my place is a working progress.
Talking about being a small generator , i have only dropped like 3g of AU and i havent weighed the pt salt i have its maybe around 10g. O i am such a begginer at refining i havent been able to get my palladium to drop yet. Dont know what im doing wrong. But ounce again. Thats all another thread. Im trying to stick to the main problem at hand. Making DNR happy.
The only thing im not a hundred percent about is what im doing with the waste, but everything i do with the waste, is what i have read and learn from youtube, whats online, what i read here on the forum, and what i have read in C.M. Hoke's book.. I will share freely with what i do with it ,so if im wron,g than let the scolding begin. But pretty much i do two things.
1. I ether use zinc and drop all metals, then neutralize to ph7, filter, and dump liquide. I might have found a company to buy my copper and zinc carbonat/hydroxide by product. 
Or 
2. I simply put in with percious metal stock pot. I havent started my copper recovery pot yet.
I think it sums up all. 
I will definitely keep reading your guys theads and try to learn the answers im asking. And i want to be a donate and be a member but i have a little budget and got to have my funds for labing, placards, and anything else that would involve epa regulation. I will be more than happy to sign up for the Silver membership if i can get through the DNR vist. Any insight befor there vist would be great. If you can think of anything that im missing would be great. Tired of trying to sound smart and let you guys say what you will and say nome on this thread and let you guys say what uou will. Thanks for all info i may receive. Thanks


Learn2live34


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## butcher (Aug 14, 2016)

learn2live34 ,
Where do I begin?
It looks like you have the proper mindset, and are making good progress in the right direction. I think you are a smart man and will do well.
From your post, I say you are not dealing with your waste properly you are close (but no cigar), dangerous metals will still be in the solution your dumping (if you just bring it to pH7, many metals will not form insoluble hydroxides at that point). 

Where are you dumping the solutions, it can kill vegetation, ruin a septic system, and create problems in sewer treatment plant, which is normally the drinking water for those who live down river from the treatment plant.

Re-read dealing with waste in the safety section carefully. Cement values on copper, then to treat waste, I would use iron metal to cement the metals below iron in the "reactivity series of metals" from the solution, (zinc will work, but iron is cheaper and easier to get...), after decanting solution from the copper or other metals, initially bring the pH to around 9.5 where most of the dangerous metals will form insoluble hydroxides, then decant solution again from the sludge, and then bring the solution back to pH7, where again you may have some metals precipitate... Then you will be left with mainly clear salt water. I suggest drying and roasting the iron sludge (some just dry it out before disposal, but roasting forms more insoluble oxides).
I even evaporate my salt water down to crystals (mainly because I do not have a good place to dispose of the solution, where I live in the country. I also find uses for many things others here on the forum may consider waste, many times for me they are useful byproducts which can be used in recovery or some other process...

The safety thread can also give you Ideas for safety in your work area (eyewashes...), or nice plans for a small lab...

The more you show the authority's (when they come knocking on your door) that you know what you are doing and that you are doing it properly, the easier they are to get along with. Do not even ask me how I know...

https://www.google.com/?trackid=sp-006#q=reactivity+series+of+metals
https://www.google.com/?trackid=sp-006#q=insoluble+metal+hydroxide+pH+chart
https://www.google.com/search?q=insoluble+metal+hydroxide+pH+chart&biw=1280&bih=829&tbm=isch&tbo=u&source=univ&sa=X&ved=0ahUKEwjJk9asvsLOAhUL6mMKHVb1Cj0QsAQIGw


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## learn2live34 (Aug 15, 2016)

butcherfor the wounderful advice butcher.


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## learn2live34 (Aug 15, 2016)

Wow what a typo. How did that happen.


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## learn2live34 (Aug 25, 2016)

Well, Im up and still running my lilttle ewaste recycling and refining opperation in MO. DNR where not completely satisfied because i didnt have a manifest of my waste stream. Which wont be bad idea for my own personal data. The lady from DNR did give me a check list to go by for when they do stop by for there inspections. 
They told me that i needed to get ahold of air pollution, which they called today. Im in the clear, i dont have to have a pollution permit. You only need a air pollution permit if you process 10ton or more. Funny because i havent even proccessed 5lb of e-waste.
Still waiting to hear from water pollution department to see if i am required a permit. Um im guessing that im not going to be any threat there ether. I dont know why they are even bothering messing with me. But i do welcome it because if i would by any chance to be successful i will have already be applying the EPA regulations and requirements.
Befor i go i thank you guys for your input and just pointing the finger in the right place.


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## EMRE (May 29, 2021)

lazersteve said:


> All,
> 
> This is the first of several US governmental guideline posts I'll be making.
> 
> ...



hi Steve,
could you upload the file again? link does not work.
thanks


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## River21 (Jul 14, 2021)

Hello, 

I’m looking to set up a stable system fir my hobby refining…

I am in OHIo and I wanted to know how I go about finding out how much pollution is acceptable (small hobby refiner).

There threads here seem to be very old or disconjunct with broken links… can someone point me in the right direction?


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## Martijn (Jul 14, 2021)

You will want to aim as low as you can. I would. For our environment's sake. And on the other hand, if certain levels are the absolute minimum, how will you measure them? ppm, vol%, gr/liter, etc. You'll need an analyzer for that. No hobbyist can afford that. 

Most pollution leves are set to what (big) companies can reasonably achieve, not what is desirable or safe for life around the emission point. Money still has to be made... can you prove you got sick from it or can the defense still claim reasonable doubt? 

Like the BP director that went all the way to declare in front of court: "yeah, sure frackling is completely safe".... but sued another company to stop them from doing so in his own back yard... NIMBY!!

From what I could find after a quick search for "hazardous waste emission levels OHIO" on google:

https://epa.ohio.gov/derr/compliance 
Very helpful info there. 

https://epa.ohio.gov/derr/derrrules/rcra 

If you first cement on copper, decant and then cement on iron, decant, and then raise Ph to 9 with soda ash and filter, then raise again to 11 and filter, you'll have it as far down as you can get it. You could slowly lower the Ph again to see if any traces of hydroxides are pushed back out, but it will be minimal.
lowering Ph for disposal is not necessary imo, drain cleaner that goes in the toilet also isn't Ph neutral. 
I don't know if testing with ammonia will show anything in waste water.

Drying the hydroxides in the sun is a way to not have to dump any liquids in the sewage. All the salts and non volatiles will be in the waste. Or you can use the water to raise Ph of other acidic waste. The hydroxides can be taken to a local waste dump point, don't know how to call them in English, here in the Netherlands it's called "millieu straat"

Good to hear you care for our environment! 

Martijn.


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