United States
             Environmental Protection
           Office of Water
September 1989
Overview Of Selected
EPA Regulations And
Guidance Affecting
POTW Management

                                  Printed on Recycled Paper

                                  EPA 430/09-89/008
     Overview Of Selected
     EPA Regulations And
      Guidance Affecting
      POTW Management
             Office of Water
       Office of Municipal Pollution Control
          Municipal Facilities Division
           Washington, DC 20460
            September, 1989    :T "-  .   •
:. :/:i.on Agency
                               , II  60604


    Material in this document was prepared under contract numbers 68-03-3314,
work assignment number 2-9 and significantly revised under contract number
68-C8-0014, work assignment number 1-15 under the direction of Irene Horner of
EPA's Office of Water, Office of Municipal Pollution Control. Staff from several
EPA offices provided valuable comments on and extensive input to drafts of the
document. Special appreciation is extended to the following individuals for their
participation in the document's preparation:

    • Lam Lim, Bob Bastian, Atal Eralp, and Eric Cohen of the Office of
      Municipal Pollution Control.

    • Rick Brandes, Paul Connor, Desiree Di Mauro, Katharine Dowell,
      Marilyn Goode, Martha Segall, and Jim Taft of the Office of Water
      Enforcement and Permits.

    • Alan Rubin, Edwin Drabkowski,  and Marvin Rubin of the Office of Water
      Regulations and Standards.

    • Kathleen Bishop of the Office of Solid Waste and Emergency Response.

    • Ivette Vega and Hubert Waiters of the Office of Emergency and Remedial

    • Bob Lucas of the Office of Air Quality Planning and Standards.

    • David Hindin of the Office of Enforcement and Compliance Monitoring.

    • Roland DuBois, Randolph Hill, and Ruth Bell of the Office of General

    • Several  staff members of the RCRA/Superfund Hotline.

    The information in this document is meant only  as a summary of some of the
regulations and guidance that may apply to publicly owned treatment works
(POTW) operations. This document does not provide a comprehensive overview
of all applicable federal requirements. Use of this document should not replace
reference to official regulations as published in the Federal Register or the Code
of Federal Regulations or to other more specific guidance documents. Also, the
reader should be aware that EPA continuously updates and revises its regulations
in response to statutory amendments or to improve its regulatory program. Final-
ly, POTWs are  reminded that the Clean Water Act allows states and municipali-
ties to impose more stringent requirements on National Pollutant Discharge
Elimination System (NPDES) permittees than are required under federal law.
Therefore, EPA suggests that the reader contact the appropriate authorities to get
sources of detailed guidance for specific situations.

    Each day billions of gallons of domestic, com-
mercial, and industrial wastewaters contaminated with
a variety of pollutants flow through the sewers to
more than 15,000 publicly owned treatment works
(POTWs) serving the nation's cities and towns. These
POTWs remove pollutants and discharge the treated
water to rivers, bays, lakes, ground water, or the
ocean. POTWs may then dispose of the residues (typi-
cally sludges) of the treatment processes (e.g., by
incineration or landfilling), or use them in beneficial
reuse/recycling activities, such as compost to condi-
tion soil. POTWs have been regulated for many years
by several federal environmental statutes designed to
control effluent discharges and sludge disposal
     As our knowledge about the health and environ-
mental impacts of water pollution, hazardous waste,
air pollution, and toxic chemicals has increased, Con-
gress has revised these laws, frequently expanding
their scope, and passed additional legislation to pro-
tect public health and the environment. EPA and the
states now regulate POTWs under several environ-
mental laws, including:
  •  The Clean Water Act (CWA).  The CWA and its
     associated regulations are designed to ensure that
     our nation's water bodies are pure enough to sup-
     port the goals of the Act. The goals of the CWA
     are to eliminate the discharge of pollutants into
     navigable waters and, in the meantime, to pro-
     vide for protection and propagation offish, shell-
     fish,  and wildlife and recreation. These goals
     may be achieved through installation of appropri-
     ate technology and management practices or effi-
     cient reuse and  reclamation of wastewater. Under
     the CWA, states establish water quality standards
     that specify the uses for the water bodies, criteria
     for pollutants to protect those uses, and policies
     to protect water quality and prevent its degrada-
     tion.  POTWs must obtain National Pollutant Dis-
     charge Elimination System (NPDES) permits,
     which specify the permissible concentrations or
     levels of contaminants in their effluent. EPA and
     the states use the  NPDES permitting system to
     implement secondary treatment requirements and
any more stringent limitations necessary to attain
water quality standards. In addition to pollution
control levels required by federal regulations,
states may require that POTWs meet additional,
more stringent controls (which are then incorpo-
rated into the NPDES permits) in order to
achieve the state's own water quality standards.
Also under the CWA, POTWs with a total design
flow exceeding 5 million gallons per day (mgd)
(or less than 5 mgd where necessary to prevent
interference and pass-through) must establish
pretreatment programs. Under these programs,
POTWs must regulate industries and other non-
domestic sources discharging into municipal
sewers. In addition, POTWs are subject to regu-
lations developed under the CWA governing
sludge use and disposal.

The Resource Conservation and Recovery Act
(RCRA). RCRA sets forth a comprehensive sys-
tem for regulating both hazardous and non-
hazardous solid wastes. Under RCRA, EPA has
established regulations to define and control
hazardous waste from the moment the waste is
generated until its ultimate disposal. EPA regula-
tions include requirements for generators, trans-
porters, and facilities that treat, store, and/or
dispose of hazardous waste. Under RCRA,
POTWs first must determine if they are regulated
(i.e,. if they receive or generate regulated waste),
and if so, follow specific requirements for han-
dling their waste. In addition to hazardous
wastes, underground storage tanks and sludge
disposal in municipal solid waste landfills are
regulated under RCRA.

The Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA).
CERCLA or "Superfund" provides broad federal
authority to respond directly to releases or threa-
tened releases of hazardous substances. This law
also provides for the cleanup of inactive or aban-
doned hazardous waste sites. Under CERCLA,
EPA assesses the nature and extent of contamina-
tion at a site, determines the public health and
environmental threats posed by a site, analyzes
the potential cleanup alternatives, and takes ac-
tion to clean up the site. POTWs that discharge
CERCLA hazardous substances in effluent at
levels that equal or exceed NPDES permit limita-
tions, or for which no specific limitations exist,
or in spills or other releases, may be subject to
the notification  requirements and liability provi-
sions under CERCLA. In addition, POTWs that
disposed of sludge in impoundments or landfills
that are Superfund sites may be required to pay
for cleanup of those sites. At times, POTWs may
be requested to  accept wastewaters from Super-
fund cleanup activities. If discharge of CERCLA
wastewaters to a POTW is deemed appropriate,
the discharger must ensure compliance with sub-
stantive and procedural requirements of the
national pretreatment program and all local
pretreatment regulations before discharging
wastewater to the POTW.
The Superfund Amendments and Reauthori-
zation Act (SARA). This law, which amended
CERCLA, also  established in Title III a new pro-
gram to increase the public's knowledge of and
access to information on the presence of
hazardous chemicals in their communities and
releases of these chemicals into the environment.
Title III requires facilities,  including  POTWs, to
notify state and  local officials if they  have ex-
tremely hazardous substances present at their fa-
cilities in amounts exceeding certain  "threshold
planning quantities." If appropriate, the facility
must also provide material safety data sheets
(MSDSs) on hazardous chemicals stored at their
facilities, or lists of chemicals for which these
data sheets are maintained, and report annually
on the inventory of these chemicals used at their
facility. The law may also require certain POTWs
to submit information each year on the amount of
     toxic chemicals released by the facilities to all
     media (air, water, and land), if they fall within
     Standard Industrial Classification Codes 20 to 39
     and meet certain threshold limits.
  •  The Clean Air Act (CAA). Under this statute,
     EPA sets standards for the quality of ambient air
     and regulates sources of pollution that may affect
     air quality. The CAA requires states to set up
     programs (i.e., State Implementation Plans
     [SIPs]) to ensure that air quality standards are
     achieved and maintained. EPA has established
     National Ambient Air Quality Standards
     (NAAQS) for several classes of pollutants, as
     well as national emissions standards for both sta-
     tionary and mobile sources of pollution. POTWs
     that incinerate sludge, or that operate boilers,
     sludge dryers, or other sources of air pollution,
     may be regulated by EPA programs for New
     Source Review, New Source Performance Stan-
     dards (NSPS), and National Emissions Standards
     for Hazardous Air Pollutants (NESHAPs).
  •  The Toxic Substances Control Act (TSCA).
     TSCA  regulates the manufacture, use, and dis-
     posal of toxic substances. TSCA authorizes EPA
     to control the risks from over 65,000 existing
     chemical substances, as well as the risks from the
     use of new chemicals. POTWs may be regulated
     under TSCA if they accept wastewaters contami-
     nated with polychlorinated biphenyls (PCBs) or
     certain other toxic chemicals.

    This booklet is designed to familiarize POTW
owners and operators with the environmental laws and
requirements that may apply to their operations.
Figure 1 summarizes some of the potential sources
that may be subject to the above statutes, at each stage
of a POTW's operations.
  •  Chapter 2, Influent Wastes, discusses require-
     ments for managing and treating wastes that enter
     the sewage treatment plant.

  •  Chapter 3, Effluent Discharges, describes ap-
     plicable regulatory programs for controlling the
     discharge of effluents to the environment.
  •  Chapter 4, Sewage Sludge Use and Disposal,
     summarizes current and pending regulations for
     controlling sludge use and disposal practices.

                                            Stormwater intake

           Combined sewer overflow (CWA)
        Sludge incineration, boilers,
        air emissions (CAA)   ^-r-

Transport of sludge offsite/?*
for treatment or disposal/5'
(CWA, possibly RCRA,  -5—
Influent wastewaters
(nondomestic wastewaters, .  .  i
 subject to categorical pS>ow» v?j|
  fotrpatmont standards)

                                           (Categorical pretreatment
                                           standards for 34
                                           industries; local
                                           pretreatment programs)
                                                                              Dedicated pipeline, rail,
                                                                              or truck (possibly RCRA
                                                                              permit-by-rule or CERCLA)
                                       Transport of wastewater
                                       to POTW for treatment
                                       (CWA, possibly RCRA
                                        permit-by-rule or CERCLA)

Waste storage, herbicide
and pesticide wastes
(possibly RCRA)
J r-
Sludge storage 1
(possibly RCRA)
rncncncD I (poSsibly
Oil storage and spills
SARA) [*=
«ut JJw.
(possibly RCRA,
Storage Tanks (RCRA)
Effluent discharge
(CWA, possibly
        Construction (NEPA)
              Figure 1. Activities and Sources of Pollutants Potentially Subject to EPA Regulations.

   •  Chapter 5, Other Pollution Issues, discusses
     several additional environmental laws under
     which discrete portions of a POTW's operations
     may be regulated.

  • Appendix A is a glossary of commonly used ab-
  • Appendices B andC list sources of further infor-
    mation on pollution issues that affect POTWs.

    Throughout this document, citations are provided
so the reader can seek out additional, more detailed
information about the laws and regulations that apply
to their operations.
    This document summarizes the current federal
laws and regulations only. Most federal legislation,
including the environmental laws summarized in this
booklet, encourage or require states to develop and
run their own regulatory programs as an alternative to
direct EPA management.  Thus, in a given state, the
environmental programs described in this document
may be run by EPA or by a state agency, or by both (if
not all portions of the state program meet the federal
requirements). For a state to have control over its own
programs, it must receive approval from EPA by
showing that its programs are at least as stringent as
the EPA program. POTW owners and operators
should consult their state and local regulatory agen-
cies for additional help and information on state and
local requirements.
    There are no copyright restrictions limiting the
reproduction of this government publication, Federal
Registers, or the Code of Federal Regulations.

                                       CHAPTER  2
                             Influent  Wastes
    Pollutants can be generated by a POTW or can
reach a POTW through the sewer system, a dedicated
pipe, a ship or barge, a truck, or rail bulk loads.
Some of these pollutants may be toxic or hazardous.
Potential sources of hazardous pollutants include
industrial discharges (including illegal dumping of
toxic wastes), septage, sewage containing household
pesticides and cleaning wastes, wastes from hazardous
waste site cleanups (for example, landfill leachate,
contaminated runoff, or polluted ground water), sur-
face runoff from agricultural land, stormwater, wastes
from POTW machinery operations (for example, used
oil and chlorine), and POTW groundskeeping chemi-
cals (for example, pesticides and herbicides).

2.1 CWA Pretreatment Programs

    Pretreatment programs are designed to eliminate
the serious problems posed when toxic pollutants are
discharged into  sewage systems. The federal govern-
ment's role in pretreatment began with the passage of
the Clean Water Act (CWA) in 1972. The Act called
for EPA to develop national pretreatment standards to
control industrial discharges into sewage systems.
    The overall framework for the National Pretreat-
ment Program is contained in the General Pretreat-
ment Regulations (40 CFR 403) that EPA published
in 1978 and modified in subsequent rulemakings.
These regulations apply to all 15,000 POTWs nation-
wide, and include three national pretreatment stan-
dards: prohibited discharge standards, categorical
 standards, and local limits. The regulations also re-
 quire all POTWs designed to accommodate flows of
 more than 5 mgd and smaller POTWs with significant
 industrial discharges  (about 1,500 POTWs) to estab-
 lish local pretreatment programs to further increase
 compliance with national standards.
2.1.1 Local Pretreatment Programs
    A local pretreatment program must have certain
essential elements in order to be approved. The
POTW must have adequate legal authority to imple-
ment its approved program. This legal authority is
based on state law and local ordinances. State law
authorizes the municipality to regulate industrial users
of municipal sewage systems. The municipality, in
turn, establishes a local ordinance that sets forth the
components of its pretreatment program and identifies
the director as the person empowered to implement
the program.
    The legal authority granted by state and/or local
law must authorize the POTW to implement and
enforce the requirements of the National Pretreatment
Program, including national pretreatment standards,
and to develop and enforce local limits. Some of the
specific authorities that must be available to the
POTW include:

  •  Authority to control through permit,  order, or
     similar means the contribution to the POTW by
     each industrial user to ensure compliance with
     applicable pretreatment standards and re-
  •  Authority to require the submission of all notices
     and self-monitoring reports from industrial users
     necessary to assess and assure their compliance.
  •  Authority to inspect and monitor industrial facili-
     ties, and to take enforcement action against viola-
     tors. Monitoring is necessary to ensure that
     industrial facilities comply with applicable
     pretreatment standards.
     The POTW cannot rely solely on the information
supplied by dischargers in self-monitoring reports. It
must, therefore, conduct its own inspection and
monitoring activities. Municipal personnel periodical-
ly should visit (either unannounced or scheduled)
each industrial site to collect wastewater samples at
designated sampling locations within the  facility.

    The authority to take enforcement action comes
into play when an industrial plant violates pretreat-
ment standards or requirements. The sewer authority
with an approved program must have the authority to
take immediate action to halt all discharges from a
facility when the discharge could threaten human
health or the environment, or interfere with the opera-
tion of the POTW. In less serious cases the POTW
will immediately inform the violator of the violation
and take necessary action, which may include addi-
tional monitoring of the facility's discharges. When
standards, compliance deadlines, or other require-
ments are not met, civil and/or criminal proceedings
may be initiated against the violator. In some cases,
violations can be handled without litigation. However,
the POTW may levy fines, seek injunctions, or take
other strong enforcement actions to bring the violat-
ing facility into compliance.

2.2  National  Pretreatment

2.2.1 Prohibited Discharge Standards
    The prohibited discharge standards forbid certain
types of discharges by any nondomestic sewer system
user, regardless of entry route.  These standards apply
to all nondomestic POTW users, regardless of
whether they are covered by categorical pretreatment
standards. The general prohibitions in 40 CFR Part
403 forbid any discharges into the sewerage system if
they pass through the POTW untreated or if they in-
terfere with POTW operations. The terms "pass
through" and "interference"  are defined in 40 CFR
403.3. The specific prohibitions in Part 403.5(b) out-
law the introduction into any POTW of:

  • Pollutants that create a fire hazard or explosion
    hazard in the collection system or treatment

  • Pollutants that are corrosive, including any dis-
    charge with a pH lower than 5.0 (unless the
    POTW is specifically designed to handle such
  •  Solid or viscous pollutants in amounts that will
     obstruct the flow in the collection system and
     treatment plant, resulting in interference with

  •  Any pollutant discharged in quantities sufficient
     to interfere with POTW operations.

  •  Discharges with temperatures hot enough to
     interfere with biological treatment processes at
     the POTW, or above 104 F (40 C), when they
     reach the treatment plant.

    POTWs must enforce these general and specific
prohibitions as a condition for approval of their
pretreatment programs. EPA recently (November 23,
1988) proposed additional specific prohibitions  for
flammables and used oil (53 FR 47632).

2.2.2 Categorical Standards
    Federal categorical pretreatment standards regu-
late the level of pollutants that certain industries can
discharge to POTWs. Categorical pretreatment stan-
dards place restrictions on three classes of pollutants:

  •  Conventional pollutants, which include bio-
     chemical oxygen demand, total suspended solids,
     fecal coliform, oil and grease, and pH.
  •  Priority pollutants, which include one or more
     of the designated 126 priority pollutants.

  •  Nonconventional pollutants, which are not in-
     cluded in the above lists but that nevertheless
     present a threat to the environment or to human

    Categorical pretreatment standards now exist for
34 industrial categories (40 CFR Parts 405-471).
Within each industrial category, EPA may have estab-
lished requirements for distinct industrial processes or
"subcategories."  For example, the "battery manufac-
turing" industrial category refers to establishments
that manufacture all types of storage batteries. Within
that category, EPA has established pollutant discharge
limitations for six subcategories.

    To set categorical pretreatment standards for an
industry, EPA reviews environmental and engineering
data to determine the types and quantities of effluents
generated by that industry. EPA next identifies the
best available technology economically achievable to
control the industry's effluents. EPA then analyzes the
performance of this technology to determine how
much of each pollutant the technology can remove
from the effluent and sets numerical pollution control
limits based on the capabilities of available technolo-
gy. EPA does not require industries to use specific
treatment processes to comply with the standards.
Rather, industries choose methods to meet the
2.2.3 Local Limits
    Local limits  are local discharge limitations deve-
loped and enforced by POTWs to implement the
general and specific prohibitions and to protect the
POTW. Local limits are site-specific protections
necessary to meet pretreatment objectives that are de-
veloped by the agencies in the best position to under-
stand local concerns-namely the POTWs.
    The POTW  develops local limits in three steps.
First, the POTW must identify sources and pollutants
of concern. Second, the POTW must calculate the
allowable head work loadings. Finally, the POTW
must allocate local limits to its industrial users.
    POTW development and implementation of local
limits is a critical link in ensuring that pretreatment
standards are in  place to protect the treatment works,
the receiving stream, and sludge quality.

2.3  Slug  Loadings
    A slug loading is any discharge that could cause
problems to the  POTW, including any "interference"
(as defined in 40 CFR 403.3) or violation of specific
prohibitions under 40 CFR 403.5(b). Under 40 CFR
403.12(f), all categorical and noncategorical industrial
users must immediately notify the POTW of slug
    The Report  to Congress on the Discharge of
Hazardous Wastes to Publicly Owned Treatment
Works (Domestic Sewage Study) documented the
problem of slug  loadings of toxic pollutants and
hazardous constituents by industrial users. The
Domestic Sewage Study recommended expansion of
pretreatment controls on spills and batch discharges.
The study acknowledged that categorical pretreatment
standards, locally derived numerical limits, and
reporting requirements were not always effective in
handling accidental spills or irregular high strength
batch discharges that the POTW may receive as slug
loadings. (See 53 FR 47632).
    Where industrial user slug loadings are not
prevented and reach the plant, POTWs should assess
the potential for interference or pass-through, notify
EPA and state authorities pursuant to all appropriate
reporting requirements (see Sections 3.1.6, 3.3.1, 4.4,
and 5.2 for some of them), and take appropriate meas-
ures to minimize impacts to the treatment works and
the environment. Such measures may include arrang-
ing for additional treatment of wastewaters or disposal
of contaminated sludge in facilities specially designed
and permitted to accept such material. Failure to take
such measures may lead to NPDES permit violations,
cause environmental problems that may require
corrective action under RCRA at POTWs that have
permit-by-rule status, or lead to liability under
CERCLA for any hazardous substance releases
(either on or  off-site) generated by the POTW (see
Section 2.5).
    By supplementing existing and future pretreat-
ment standards, slug control measures will help
reduce influent loadings overall, including loadings of
toxic pollutants and hazardous constituents. In addi-
tion, slug controls can be useful in ensuring that
POTWs comply with NPDES effluent limitations  on
specific chemicals or whole-effluent toxicity.

2.4 RCRA Hazardous Waste

    To determine if a POTW is regulated by EPA's
RCRA hazardous waste management program, a
POTW owner or operator must first determine if any
waste generated, transported, treated, stored, or
disposed of by the facility is hazardous. According to
RCRA, hazardous waste is a subcategory of solid
waste, and solid waste can be a solid, a semi-solid, a
liquid, or a contained gas. This means that
wastewaters, sludges, used oil, unused herbicides, and
other wastes treated or generated by POTWs may be
regulated under EPA's hazardous waste management
program if such wastes meet the definition of a RCRA
hazardous waste.

2.4.1 Wastes Covered Under RCRA Regulation
    Wastes are regulated as hazardous under RCRA
based on their characteristics ("characteristic wastes")
or their designation in lists published by EPA ("listed
wastes")  (40 CFR Part 261). A waste is hazardous if it
exhibits one or more of the following four charac-

  • Ignitability. Ignitable wastes can create fires
    under certain conditions. Examples include li-
    quids such as solvents that readily catch fire.
  • Corrosivity. Corrosive wastes include those that
    are highly acidic or basic, having a pH less than
    or equal to 2 or greater than or equal to 12.5.

  • Reactivity. Reactive wastes are those that are un-
    stable under normal conditions, or can create
    explosions and/or toxic gases,  fumes, and vapors
    when mixed with water.

  • Toxicity,  A waste is identified as exhibiting the
    EPA toxicity characteristic through use of the Ex-
    traction Procedure (EP) toxicity test. This test is
    designed to identify wastes likely to leach
    hazardous concentrations of particular toxic con-
    stituents into ground water. During the proce-
    dure, the waste is analyzed to determine if it
    possesses any of 14 toxic contaminants (certain
    metals and pesticides). If the concentration of
      any of the toxic constituents exceeds specified
      levels, the waste is classified as hazardous. EPA
      is planning to finalize a revised toxicity test in
      1989. This Toxicity Characteristic test will ana-
      lyze for metals and more organic constituents
      than the existing test. Because the test identifies
      more organic constituents than the EP toxicity
      test, more POTW sludges may be singled out as
      hazardous (EPA anticipates that only a few
      POTWs will generate a hazardous sludge).
     A waste also may be regulated as hazardous if it
 appears on one of three EPA lists:

   • Source-specific wastes. This list includes wastes
     from specific industries such as petroleum refin-
     ing and wood preserving. Sludges  and
     wastewaters from treatment and production
     processes in these industries are examples of
     source-specific wastes.

   • Consource-specific (or generic) wastes. This list
     identifies wastes from common manufacturing
     and industrial processes, such as solvents used in
     degreasing operations in any industry.

   • Commercial chemical products. This list in-
     cludes specific discarded commercial chemical
     products, off-specification chemicals, container
     residues, and spill residues, such as creosote and
     some pesticides and herbicides that may be used
     at POTWs.

2.4.2 Wastes Exempt From RCRA Regulation
    Hazardous waste mixed with domestic sewage
and conditionally exempt small quantity generator
wastes, among others, are excluded from most, if not
all, RCRA hazardous waste management regulations.
Any hazardous waste that has been mixed with
domestic sanitary sewage in a sewer system that con-
veys the waste to a POTW for treatment is not regulated
as hazardous waste under RCRA. For this reason,
POTWs are not subject to RCRA requirements for
hazardous waste discharged by other facilities to the
sewers. This domestic sewage exclusion, however,
does not extend to dedicated pipe wastes or to truck or
rail shipments of hazardous wastes discharged into the
sewer system or received by the treatment facility.
This waste must be accompanied by a manifest and
accepted by the POTW as a RCRA facility (See Sec-
tions 2.4.3 and 2.4.4).

    POTWs that produce only small amounts of
hazardous waste are subject to fewer and/or less strin-
gent regulations than other generators. Hazardous
waste generators that produce fewer than 220 pounds
(or approximately half of a 55-gallon drum) of
hazardous waste per month, or fewer than 2.2 pounds
of acute hazardous waste (listed in 40 CFR 261.31,
261.32, 261.33[e]) per month, are called conditionally
exempt small quantity generators and are excluded
from nearly all of EPA's hazardous waste management
requirements. Generators of between 220 and 2,200
pounds of hazardous waste per month, or fewer than
2.2 pounds of acute hazardous waste per month, are
subject to fewer recordkeeping and reporting require-
ments, but must comply with RCRA regulations in 40
CFR 261.5 governing treatment, storage, disposal,
and accumulation of wastes onsite.
2.4.3 Hazardous Waste Management
    To ensure proper management of hazardous waste
from the moment the waste is generated until its ulti-
mate disposal, EPA has developed a tracking system
to monitor and control hazardous waste. All
hazardous waste generators, transporters, and facili-
ties that treat, store, and/or dispose of hazardous
waste must obtain an EPA identification number.
The tracking system requires that a shipping docu-
ment, called a uniform hazardous waste manifest,
must accompany any hazardous waste sent to another
location. All (except  some rail and vessel transport-
ers) who handle the waste must sign the manifest and
keep one copy.  When the waste reaches its final desti-
nation, the owner of that facility returns a signed copy
of the manifest to the generator to confirm that the
waste arrived.
    Additional paperwork accompanies hazardous
waste subject to land disposal restrictions.  A notice
from the waste generator must tell the POTW what
treatment standard must be achieved prior to placing
the waste on land (see Section 4.3) and provide the
POTW with available chemical analysis of the waste.
    In addition, all facilities treating, storing, and/or
disposing of hazardous waste operate under a permit
unless excluded. The permit system ensures that facil-
ities meet the standards established under the RCRA
program for proper waste management. Before a
POTW owner or operator accepts a waste for treat-
ment or disposal that has been determined to be
hazardous, he or she must have an EPA identification
number and a permit.

2.4.4  RCRA Permit-by-Rule
    As described above,  POTWs that accept
hazardous wastes by truck, rail, vessel, or dedicated
pipeline and manage such wastes in nonexempt units
are regulated  as RCRA treatment, storage, and dis-
posal  facilities (TSDFs) and must operate under a
RCRA permit (40 CFR Part 270). Obtaining a permit
to treat, store, or dispose of hazardous wastes can be a
costly and time-consuming process. POTWs are ex-
empt  from this process and from many of the TSDF
standards of 40 CFR Part 264 if they qualify for a
permit-by-rule (40 CFR 270.60[c]). A POTW quali-
fies to operate under the  RCRA permit-by-rule to
manage hazardous waste if:
   • The facility is in compliance with its NPDES
   • The facility has an EPA identification number.

   • The facility complies with the manifest system
   • The facility maintains the required records for
    the waste (including copies of manifests and
    reports on the quantities of hazardous waste
   • The facility has instituted a corrective action pro-
    gram, if necessary as specified in the NPDES
    permit, to remedy releases of hazardous consti-
    tuents from the POTW.

   • The waste meets all federal,  state, and local
    pretreatment requirements that would be applic-
    able to the waste if it were being discharged to
    the POTW via  a sewer, pipe, or similar con-
    Other RCRA requirements may apply as well
 (minimum technology rquirements and land disposal
 restrictions, for example).

2.4.5 Emergency Permit
    In cases where an imminent and substantial
danger to human health or the environment is posed,
a POTW can accept and treat, store, or dispose of
hazardous waste without a permit-by-rule for 90 days
or less if it obtains an emergency permit from EPA or
the state (40 CFR 270.61). The emergency permit can
be issued either orally or in written form. If issued
orally, it must be followed within five days by a writ-
ten emergency permit.

2.4.6 Storing Hazardous Waste
    Different storage regulations apply depending on
how much hazardous waste a  POTW generates.
POTWs that generate more than 2,200 pounds of
hazardous waste a month can  only store it for up to 90
days without obtaining a storage permit (40 CFR
262.34[a]). POTWs that generate between 220 and
2,200 pounds of hazardous waste a month can store
up to  13,200 pounds for 180 days (or 270 days if the
waste is to be shipped to a treatment, storage, or dis-
posal  facility that is located over 200 miles away) (40
CFR 262.34[d]). POTWs that generate less than 220
pounds a month can store up to 2,200 pounds for an
unlimited period of time (40 CFR 261.5[g]). Unless
they qualify for an exemption, permit-by-rule,  or
emergency permit, POTWs that  accept and store
hazardous waste from offsite must obtain a RCRA
storage permit.
2.4.7  Wastewater Treatment Exclusion
    A POTW with  a NPDES  permit is exempt from
RCRA permitting if the hazardous waste  is always
kept in a wastewater treatment unit (40 CFR
264.1[g][6]). This wastewater treatment unit exclu-
sion applies to tanks or tank systems that are part of
an onsite wastewater treatment facility. In addition,
sludges taken from wastewater treatment  units that are
hazardous waste are subject to RCRA hazardous
waste management requirements for use and disposal
(Section 4.3). Hazardous wastes stored or treated in
surface impoundments or containers at POTWs are
not exempt from RCRA regulation under the
wastewater treatment exclusion, and such units would
need a RCRA permit (presumably a permit-by-rule).
The permit-by-rule  requirements for POTWs do not
apply to exempt wastewater treatment units.
    To accept manifested shipments of hazardous
waste for storage or treatment in a wastewater treat-
ment unit, a POTW must have a RCRA facility iden-
tification number and be operating as a "designated"
TSDF (including operating under a permit-by-rule)
(See Section 2.4.4). However, a POTW which has
only wastewater treatment units on site cannot be a
"designated facility"  since such a POTW does not
need a RCRA permit.

2.4.8 Mixture Rule for Listed Wastes
    Any waste mixture containing a "listed"
hazardous waste is  considered a hazardous waste,
regardless of the percentage of the listed waste con-
tained in the mixture  (40 CFR 261.3 [a] [2] [iv]). Con-
sequently, if a POTW accepts a "listed"  hazardous
waste by truck, rail, vessel, or dedicated pipeline, the
resulting wastewater mixture, as well as the sludge or
incinerator ash and scrubber water produced as a con-
sequence of treating this mixture, is deemed a
hazardous waste under RCRA (40 CFR 261.3[c][2][i]).
On the other hand,  any waste mixture containing a
"characteristic" hazardous waste is considered a
hazardous waste only if the mixture itself exhibits the

2.4.9 Unmanifested Wastes
Any hazardous wastes accepted for treatment or dis-
posal by a POTW (other than those arriving via the
collection system) should be accompanied by a uni-
form hazardous waste manifest. Some POTWs,
however, may be sent hazardous wastes by truck, ves-
sel, or rail that are not accompanied by a manifest. To
prevent this from happening, a POTW may choose to
occasionally test incoming shipments for RCRA
hazardous waste characteristics or request documenta-
tion from the waste generator that the shipment is not
deemed  hazardous under RCRA. While not a require-
ment under RCRA, this precautionary measure may
reduce or eliminate a  POTW's potential hazardous
waste liability by  enabling the facility to refuse accep-
tance of the waste. A POTW also can evaluate indus-
trial users' activities to ascertain whether those
activities may be generating RCRA hazardous wastes
that are then sent to the POTW.

2.5 CERCLA (Superfund)
    Under the Superfund program, EPA responds to
actual or threatened releases of hazardous substances,
pollutants, and contaminants into any media (air, sur-
face water, ground water, and  soil). With few excep-
tions, Superfund coverage extends to all sources of
releases and all means of entry of a substance into the
environment.  POTWs that accept Superfund
hazardous substances (generated by cleanup activities
at a site) or that experience a release of hazardous
substances (for example, a spill) may be subject to
CERCLA requirements, including reporting the
release to appropriate authorities, cleaning up the
release, and accepting financial responsibility for any
response actions deemed necessary by EPA.

2.5.1 Hazardous Substances
    Under Superfund, a "reportable" hazardous
substance is any substance (excluding petroleum and
natural gas) designated under certain sections of the
Clean Air Act, the Clean Water Act, the Toxic Sub-
stances Control Act, and the Resource Conservation
and Recovery Act. EPA may designate additional sub-
stances as hazardous if they could present substantial
danger to health and the environment.  EPA maintains
and updates the list of hazardous substances covered
under Superfund (including the "reportable quantity"
[RQ] associated with each hazardous substance) in  40
CFR 302.4. There are currently 725 substances on the
list, which include, but are not limited to, the follow-
ing compounds that the POTW may encounter:
  • Any toxic pollutant listed under Section 307 (a) of
     the Clean Water Act (i.e., the list of 126 priority
  • Any substance designated under Section
     311(b)(2)(A) of the Clean Water Act.
  • Any characteristic or listed RCRA hazardous

  • Radionuclides.
     Wastewaters generated or received by POTWs
may contain one or more of these hazardous sub-
stances (see Section 5.2 for SARA extremely
hazardous substances).
2.5.2 Wastewaters From CERCLA Cleanups
    A POTW may be requested to accept wastewaters
from a Superfund cleanup action. POTWs under con-
sideration as a potential receptor of CERCLA
wastewaters may include those POTWs with or
without an EPA-approved pretreatment program. A
POTW may refuse to accept CERCLA wastewaters,
especially if, among other reasons, it is determined
that acceptance would result in potential problems to a
POTW (e.g., damages to a POTW's physical facilities
or contamination of the POTW's sludge).
    If discharge of CERCLA wastewaters to a POTW
is deemed appropriate, the discharger must ensure
compliance with substantive and procedural require-
ments of the national pretreatment program and all
local pretreatment requirements before discharging
wastewaters to a POTW. In addition, if the POTW ac-
cepts  the waste, the POTW's NPDES permit and fact
sheet may need to be modified to reflect the condi-
tions of acceptance of the CERCLA wastewaters.
    If CERCLA wastewaters are to be managed by a
POTW, EPA recommends that the NPDES permit be
modified to reflect the conditions of acceptance of
these wastewaters. The permit modifications would
incorporate specific pretreatment requirements, local
limits, monitoring requirements,  and/or limitations on
additional pollutants of concern in the POTW's dis-
charge, or other factors. Changes to the permit may
reduce CERCLA reporting requirements and provide
protection against possible CERCLA liabilities (see
Sections 3.3.2 and 3.3.4).

                                        CHAPTER  3
                         Effluent  Discharges
     EPA's control of point sources of water pollution
 is implemented through the National Pollutant Dis-
 charge Elimination System (NPDES), which was
 established under the Clean Water Act (CWA). The
 NPDES program requires dischargers to obtain per-
 mits specifying the permissible concentration or level
 of contaminants in their effluent. EPA and the states
 use the NPDES permitting system to control point
 sources and thereby help attain and maintain ambient
 water quality standards for their surface water bodies.
 Every POTW must apply for and obtain an NPDES
 permit that includes limits which control the pollu-
 tants that may be discharged in its effluent.
    EPA has  established specific technology-based ef-
 fluent  limitations for sewage treatment plants. In
 general, POTWs must provide a minimum of secon-
 dary treatment. Secondary treatment is defined in part
 as treatment to achieve an effluent concentration of
 biochemical oxygen demand (BODS) and total sus-
 pended solids (TSS) of 30 mg/L or less for each
 parameter. POTWs must also meet any more stringent
 limits necessary to protect water quality. In addition,
 effluent discharges from POTWs may be regulated in
 certain cases under CERCLA.

 3.1 Effluent  Discharges Under
     the CWA

 3.1.1 Ambient Water Quality Standards
    States are responsible for setting water quality
 standards for the waters within their borders. These
 standards designate the uses of specific water bodies
 and the associated numeric or narrative criteria
 applicable to these waters which are to be maintained
 via effluent limits set in permits. EPA reviews and
 approves the state standards, in  accordance with EPA
 regulations specified in 40 CFR Part 131.
    When setting standards, states must consider toxic
pollutants listed pursuant to Section 307 of the CWA
to determine whether:

  • The discharge or presence  of any pollutant on the
    list could interfere with the designated uses of the
    water body.
   • EPA has published numeric criteria for those pol-
     lutants under Section 304(a) of the CWA.

     If both of these conditions are met, the state must
 adopt specific numeric criteria for those pollutants;
 otherwise, adopt a procedure to derive a numeric limit
 from a narrative criterion to protect the designated
 uses of the water body. Depending on the state's
 evaluation of local conditions, its numeric pollutant
 criteria may be more or less stringent than EPA criter-
 ia. In cases where the  state determines that a specific
 toxic pollutant could interfere with a water body's
 designated uses but EPA has not yet published numer-
 ic criteria, the state must adopt pollutant criteria
 based on biological monitoring or assessment

 3.1.2 Controlling Effluent Toxicity
     Reducing effluent  toxicity may be considerably
 more difficult than treating conventional pollutants.
 Not only are there hundreds of toxic chemicals that
 may be discharged to receiving waters, but analysis of
 these chemicals is sometimes difficult. In addition, it,
 is difficult to predict the toxicity of chemical mixtures.
     In response to these difficulties, EPA has placed
 considerable emphasis  on a water quality-based ap-
 proach to NPDES permitting, while also requiring
 that all applicable technology-based requirements be
 met. In its 1984  "Policy for the Development of
 Water-Quality Based Permit Limitations for Toxic
 Pollutants" (49 FR 9016), EPA recommended the use
 of biological testing of  effluents in conjunction with
 other data to establish NPDES permit conditions.
    In addition to meeting the technology-based
 requirements of secondary treatment, POTWs must
 meet any more stringent water quality-based limits
 imposed by the permitting authority. In some cases,
 local limits for industrial users of the POTWs may
need to be developed to ensure attainment and main-
tenance of water quality-based limits established in
POTW permits.

    Effluent toxicity can be managed in some cases
by chemical-specific effluent analysis and control (for
example, removing residual chlorine in the effluent).
Frequently, however, biological monitoring is needed
to identify the interactive effects of toxic pollutants  in
the discharge. This is known as whole effluent toxici-
ty monitoring. EPA and the states will develop
NPDES permit limits based on whole effluent toxicity
where it is an appropriate control parameter.

3.1.3 Toxicity Reduction Evaluations
    In the event of toxicity permit limitation viola-
tions, POTWs may be required to conduct a toxicity
reduction evaluation (TRE). A TRE is an investiga-
tion conducted within a plant or municipal system to
isolate sources of effluent toxicity, identify the pollu-
tants causing the toxicity, and determine the effective-
ness of pollution control options in reducing the
toxicity. If specific chemicals are identified as the
cause of a water quality standards violation, the
POTWs permit may include limitations on these in-
dividual pollutants.

3.1.4 Individual Control Strategies for
      Impaired Waters
    Another element of EPA's surface water toxics
control program is found in Section 304(1) of the
CWA. A portion of Section 304(1) requires states to
identify all waters with known water quality impair-
ment due entirely or substantially to point source dis-
charges of the "Section 307(a)" toxic pollutants.
Section 304(1) requires states to identify the point
sources discharging the toxic pollutants and the
amounts of discharged pollutants. For such waters,
states must develop individual control strategies for
each such point source by February 4, 1989. These
individual control strategies are designed to ensure
that applicable water quality standards are achieved by
June 4, 1992. If such controls are established for a
POTW, they will be included in the POTWs revised
NPDES permit.
    The Section 304(1) individual control strategies
will address  only the 126 priority pollutants.
However, the national surface-water toxics-control
program requires that any pollutant (conventional,
non-conventional, or toxic) that causes toxic effects
and violates  applicable water quality standards be
 3.1.5 Combined Sewer Overflows (CSOs)
     Combined sewers transport domestic sewage,
 industrial waste, and stormwater to the POTW for
 treatment. CSOs are flows from a combined sewer in
 excess of the interceptor or regulator capacity that are
 discharged to a receiving water without going to a
 POTW CSOs can result in the discharge of untreated
 sewage and industrial waste.  EPA issued an interim
 final national control strategy for CSOs on  January
 27, 1989. The strategy reaffirms that CSOs  are point
 sources subject to the requirements of the CWA.
 CSOs are not subject to secondary treatment regula-
 tions applicable to POTWs. CSOs discharging without
 a permit are unlawful and must be eliminated or issued
 permits that ensure compliance with technology-based
 and water quality-based requirements of the CWA.
 POTWs are responsible for planning and implement-
 ing system-wide combined sewer management plans.
 State-wide permitting strategies will be developed by
 the states or regions to ensure implementation and
 consistency with the CSO strategy. The goals of the
 strategy are threefold:

  •  To ensure that if CSO discharges occur, they
     occur only as a result of wet weather.

  •  To minimize water quality, aquatic biota, and
     human health impacts from overflows that do

  •  To bring all wet weather CSO discharge points
     into compliance with the technology-based
     requirements of the CWA and applicable state
     water quality standards.
3.1.6 NPDES-Required Notifications for Upsets
     and Bypass
    Two types of events specified in NPDES permits
that require reporting are upsets  and bypass. Upsets
result in unintentional, temporary noncompliance
with technology-based permit effluent limitations but
do not include noncompliance events resulting from
events such as operational errors and other factors
identified in 40 CFR  122.42 (n). Upsets must be
documented,  dealt with and reported within 24 hours,

as described in 40 CFR 122.42 (n). Bypass is the
intentional diversion of waste streams as discussed in
40 CFR 122.42 (m). Bypass events that do not exceed
effluent limitations are allowed only if it is for essen-
tial maintenance. Otherwise, bybass events must be
reported within 10 days for anticipated bypass (which
are subject to approval) and 24 hours for unanticipated
bypass events. Bypass events exceeding effluent limi-
tations are prohibited except under limited conditions
discussed in 40 CFR 122.42(m).

3.2 Effluent Discharges Under
    Effluent discharges from a POTW, including
those POTWs treating hazardous waste mixed with
domestic sewage or operating under a RCRA permit-
by-rule (see Sections 2.4.2 and 2.4.4), are subject only
to NPDES regulations and not to RCRA's other
hazardous waste provisions.

3.3 Effluent Discharges Under
    A POTW must report releases of CERCLA
hazardous substances, equal to or in excess of their
reportable quantities (RQs), or exceeding federally
permitted release levels by an RQ or more, to the fed-
eral government (and to state and local authorities
under SARA Section 304). The POTW may be
assessed civil or criminal penalties for failing to
report and may be liable for the costs  of cleaning up
the release and damages resulting from the release.
For example, POTWs may be subject to CERCLA
reporting and response actions if chemical spills occur
at the treatment plant, if sludge disposal contaminates
ground water or soil, or if hazardous air emissions are
released during treatment operations.
3.3.1 CERCLA RQs and Reporting
    POTWs must immediately report any release of a
hazardous substance (to air, surface water, ground
water, or soil) that equals or exceeds the RQ for that
substance to the National Response Center [(800)
424-8802, or (202) 267-2675 in Washington, DC]
(40 CFR 302.6), unless the release is federally per-
mitted or otherwise exempt (as described immediately
below). Section 5.2 details  other reporting require-
ments. A list of hazardous substances and their RQs
appears in 40 CFR 302.4. When a POTW reports a
release of an RQ or more of a hazardous substance,
the federal government or the state may initiate
response actions to protect  public health or the
environment from any threats.

3.3.2 Reporting Exemption for Federally
     Permitted Releases
    On July  19, 1988, EPA proposed a rule clarifying
the federally permitted release exemption from
CERCLA release reporting. These federally permit-
ted releases,  which include routine NPDES-permitted
releases from POTWs, are exempt from liability under
CERCLA for response costs and damages incurred
due to the releases (53 FR 27268).  The proposed rule
would require a facility to report a  release to the
National Response Center only if the release exceeds
the federally permitted level by an RQ or more. For
example, if a POTW's effluent discharge of cadmium
is limited by an NPDES permit to 1.5 pounds per day,
then the POTW would be subject to CERCLA's
reporting requirements only if the effluent discharge
contained 2.5 or more pounds per day of cadmium
(because the RQ for cadmium is one pound).
    According to the proposed rule, a point source
discharge covered by an NPDES permit is exempted
from reporting if it meets one of the following con-

  • The discharge is in compliance with an NPDES
    permit limit that specifically addresses the
    hazardous substance in question, either directly
    or through the use of an indicator pollutant. In
    the case of the latter, the permit must identify the
    amount of the specific pollutant allowed at
    accepted levels of the indicator pollutant.
  • The source, nature, and amount of a potential
    discharge were identified and made part of the
    public record, and the NPDES permit contains a
    condition requiring that the treatment system be
    capable of eliminating or abating a potential dis-
  • The POTW's NPDES permit or permit applica-
    tion identifies a continuous or anticipated inter-
    mittent discharge caused by events occurring
    within the scope of the relevant operating and
    treatment systems. Included are chronic, process-
    related discharges resulting from periodic upsets
    in the manufacturing and treatment systems, such
    as a discharge created by a system backwash.

3.3.3 Reduced Reporting for Continuous
    On April 19, 1988, EPA proposed a rule clarify-
ing the continuous release reporting requirement (53
FR 12868). Section 103(f)(2) of CERCLA provides
relief from reporting releases of hazardous substances
that are continuous, stable in quantity and rate, and
are releases for which notification has been given un-
der Section 103(a) for a period sufficient to establish
the continuity, quantity, and regularity of such
releases. Section 103(f)(2) provides further that in
such cases, notification shall be given annually or at
such a time as there are any statistically significant
increase in the quantity released of any hazardous
substance. For example, if a POTW experiences a
reportable release of a hazardous substance that is
continuous and stable in quantity and rate, instead of
reporting such a release under CERCLA on a per-
occurrence basis, the POTW may report only annual-
ly and in the event of a statistically  significant in-
crease in the release.
3.3.4 Liability Under CERCLA
    Anyone responsible for a hazardous substance
release that is not federally permitted is liable for the
costs of cleaning up the release and for any natural
resource damages caused by the release, if deemed
necessary and consistent with the National Contin-
gency Plan (40 CFR Part 300). Even if a release is
reported as required, the POTW could still be liable
for response costs.
    Releases include activities such as discharging,
spilling, leaking, pumping, pouring, injecting, leaching,
or disposing into the environment (40 CFR 302.3).
    Even properly managed POTWs may be subject
to potential CERCLA liability as a result of  sludge
disposal at improperly designed or managed off-site
land disposal sites. Accordingly, POTWs should select
sludge disposal sites carefully to avoid being identi-
fied as a potentially responsible party (PRP) at a facil-
ity, such as a landfill, that becomes a Superfund site.
In this case,  the POTW is identified as a party respon-
sible for creating a hazardous waste problem and may
be required to pay for all or part of the cleanup costs.

                                      C  H  A
 E R 4
    Sewage  Sludge  Use And  Disposal
    The need for effective sludge management is con-
tinual and growing. The quantity of municipal sludge
produced annually has almost doubled since 1972,
when the Clean Water Act imposed uniform minimum
treatment requirements for municipal wastewater dis-
charges. Municipalities currently generate approxi-
mately 7.7 million dry metric tons of sludge each year.
This quantity is expected to double by the year 2000
as the population increases and as more municipali-
ties comply with Clean Water Act requirements.

4.1 EPA Policy and Regulations
    For many years, sewage sludge was regulated
under a number of federal statutes, with no  compre-
hensive program at the national level. Existing federal
regulations are authorized under several legislative
mandates and have been developed independently in
response to media-specific concerns.  The primary
role for control over sewage sludge use and  disposal
has fallen to the states, and while nearly all  states have
some type of sludge program in place, these programs
vary widely in comprehensiveness of coverage.
    In 1984 EPA adopted its first policy on  municipal
sludge management. This policy  stated that  sludge
management was a responsibility to be shared by
EPA, states, and local governments. The policy estab-
lished roles and duties for each entity. EPA's primary
responsibility is to develop and enforce the national
technical standards for sludge management  and over-
see state programs implementing these standards. The
local governments must select sludge management
options and maintain sludge quality in accordance
with federal requirements.
    Sewage sludge is both a waste and a resource.
Used properly, it can be recycled as a fertilizer and
soil conditioner. However, contaminated sludge or
poor disposal practices can pose an environmental
threat to air, surface water, ground water, or the food
chain. EPA's policies and regulations  reflect the two-
fold purpose of regulating sewage sludge to  ensure
that it is handled properly and is of sufficient quality
for use as a soil conditioner and fertilizer.
4.2 Sewage Sludge Use and
     Disposal Under the CWA

    Section 405 of the CWA, as amended by the
Water Quality Act of 1987, requires EPA to develop
technical standards which:

  • Identify the major sludge use and disposal

  • Identify toxic pollutants that may in certain con-
    centrations interfere with each use and disposal

  • Establish acceptable levels of the identified pol-
    lutants for each use and disposal method to pro-
    tect public health and the environment.

  • Establish management practices, where
    In addition, Section 405 of the CWA requires that
the technical standards be implemented through an
NPDES permit (or another permit listed in Section
405). Finally, Section 405 also requires that prior to
promulgation of the technical standards, EPA must
incorporate sludge conditions developed on a case-by-
case basis into NPDES permits (or take other
appropriate measures) to protect public health and the
    POTWs should be aware that pursuant to these
CWA requirements (and EPA regulations and policies
developed under the CWA), NPDES permits issued or
reissued after the effective date of the CWA amend-
ments (February 4, 1987) must contain some sludge
conditions, or reference sludge conditions in another
permit. Most importantly, the permit must require
compliance with existing requirements (see Table 4-1
for current regulations). EPA's recently promulgated
Sludge  State Program and Permitting final rules for
standard permit conditions, and EPA's "Sewage
Sludge  Strategy" and draft "Guidance for Writing
Case-by-Case Permit Requirements for Municipal
Sewage Sludge" (June 1988) contain guidance on
permit  coverage prior to promulgation of the technical

                                     TABLE 44
 Existing  And  Pending Sludge Regulations
Existing Regulations
Biphenyls (PCBs)

Ocean Dumping
New Sources
Standards for Sewage Sludge


Cadmium, PCBs,
Pathogenic Organisms

Characteristic of
EP Toxicity

Land Disposal Restrictions
40 CFR 761

40 CFR 220-228

40 CFR 60

40 CFR 61

40 CFR 257
40 CFR 261
Appendix II

40 CFR 268
New (Final, Promulgated) Regulations
State Sewage Sludge           40 CFR 501
Management Programs         40 CFR 122-4
and Permit Requirements

Pending (Proposed) Regulations
Sludge Technical               40 CFR 503

Municipal Landfill Regulations    40 CFR 258
40 CFR 261
Appendix II
All sludges containing more than 50
milligrams of PCBs per kilogram of sludge

The discharge of sludge from barges or
other vessels

Incineration of sludge at rates above 1,000
kilograms per day
Incineration and heat drying of sludge

Land application of sludge, landfilling and
storage in lagoons

Defines whether sludges are hazardous
for some organic and metallic species

Restricts hazardous waste applied to land
                     Requirements for state sludge
                     management permit programs
                     and permitting requirements
Technical requirements for sludge use
and disposal

Co-disposal of sludges and municipal
solid waste

New test to determine if sludges are
hazardous for a number of organic and
metallic species

    EPA proposed technical standards for use and
disposal of sewage sludge on February 6, 1989, to be
codified in 40 CFR Part 503 (54 FR 5746). These
proposed rules cover five sludge use and disposal

  • Incineration.

  • Land application (including agricultural and non-
    agricultural uses).

  • Distribution and marketing (e.g., composted
    sludge products).

  • Disposal in a monofill (sludge-only landfill).

  • Surface disposal (e.g., long-term storage in

    The proposed standards include specific numeric
pollutant limits in sludge and management practices
for each use and disposal method. Disposal of sludge
in a municipal solid waste landfill will be covered un-
der 40 CFR Part 258 (proposed on August 30, 1988 in
53 FR 33314 and expected to be finalized in late
    The CWA set very  tight deadlines for compliance
with the technical standards; facilities have one year
after promulgation to achieve compliance with the
technical standards (two years if construction is need-
ed). This deadline applies whether or not the techni-
cal standards have been incorporated into a permit.
    EPA intends that Part 503 technical standards will
be the primary regulatory authority for sewage sludge
use and disposal. Thus these regulations will either
incorporate or supersede 40 CFR Part 257 require-
ments for land application and disposal  in a monofill,
and the Clean Air Act requirements for  incineration.
The Part 503 regulations will not cover:

   •  Sludges that are found to be hazardous, and
     therefore regulated under RCRA Subtitle C.

   • Ocean disposal of sewage sludge, which is
     governed by the Marine Protection, Research and
     Sanctuaries Act (MPRSA) as amended by the
     Ocean Dumping Ban Act of 1988.
4.3 Sludge Disposal Under RCRA
    Any sludge produced by a POTW that is a
hazardous waste must be stored, shipped, and disposed
of in accordance with the RCRA hazardous waste
regulations (see Sections 2.4.3, 2.4.6, and below).
Sewage sludge is generally considered a hazardous
waste if it exhibits a hazardous waste characteristic
(for example, it fails the EP toxicity test and is not
further treated), or is derived from the treatment of
listed hazardous waste received by the POTW by
truck, rail, vessel, or dedicated pipe. Only RCRA-
permitted treatment, storage, or disposal facilities can
manage hazardous waste for incineration, land appli-
cation, or landfilling (see Section 2.4).
    Under the Agency's land disposal restrictions
program, EPA has developed (and is continuing to
develop) regulations designed to ensure that land dis-
posal of hazardous wastes is protective of human
health and the environment (40 CFR Part 268). The
regulations require certain hazardous wastes, includ-
ing POTW-generated hazardous sludges, to meet treat-
ment standards expressed as specified treatment
technologies, total pollutant concentrations, or TCLP
leachate concentrations prior to being disposed of on
land. POTWs that generate or ship wastes covered by
the land disposal restrictions (i.e., "restricted
wastes") must identify the applicable treatment stan-
dards, certify whether the waste meets the standard,
and provide this information to the land disposal facil-
ity or any other treatment, storage, or disposal facility
when delivering the waste. POTWs that dispose of any
restricted waste are responsible for ensuring that only
wastes meeting the treatment standards are land
disposed. These facilities must document that the waste
has been treated in accordance with the applicable EPA
treatment standards. Most POTWs will not generate
sludge that exhibits the hazardous waste toxicity
characteristic as currently defined (see Section 2.4.1).

 4.4 Sludge Disposal Under

    If the sludge from a POTW contains any CERCLA
 hazardous substance and the sludge is released into
 the environment in an amount equal to or greater than
 its RQ within a 24-hour period, the POTW is subject
 to the reporting requirements under Section 103 (a) of
 CERCLA and Section 304 of SARA (50 FR 13462
 [April 4, 1985]). For example, if 1,000 pounds of
 sludge containing 1 pound or more of 1,4-dichloro-
 2-butene is released to the environment in one day, the
 release containing this hazardous substance must be
 reported to the National Response Center and state
 and local authorities. An exception to these reporting
 requirements for federally permitted releases and the
 reduced reporting requirements for continuous
 releases of hazardous substances were described in
 Section 3.3.2.
    POTWs that previously disposed of sludge in an
 impoundment or landfill that are designated as Super-
 fund sites needing cleanup may be PRPs who are
 required  to pay for cleanup of the site (see Section

 4.5 Sludge Disposal Under TSCA

    POTW sludges contaminated with polychlori-
 nated biphenyls (PCBs) containing more than 50 ppm
 PCBs must be handled in accordance with 40 CFR
 Part 761,  and disposed of in an incinerator (that com-
 plies with 40 CFR 761.70), a chemical waste landfill
 (that complies with 40 CFR 761.75), or an alternative
 method approved by EPA. Spills of PCB-contaminated
 sludges (including intentional or unintentional spills,
 leaks, and other uncontrolled discharges) must be
 cleaned up to stringent levels in accordance with
 EPA's PCBs Spill Cleanup Policy (52 FR 10688,
 Subpart G of 40 CFR Part 761). POTWs that experience
 PCB spills resulting in the direct contamination of
 sewage treatment systems must immediately notify
 EPA and  clean up the spill (40 CFR 761.120). POTWs
may be excluded from final decontamination stan-
dards as determined on a case-by-case basis by EPA.
4.6 Air Pollution Regulations
    POTWs that incinerate sludge or operate sludge
dryers or utility steam boilers are currently regulated
by three EPA programs under the CAA—New Source
Review (either Prevention of Significant Deterioration
(PSD) or nonattainment area permitting), the New
Source Performance Standards (NSPS), and the
National Emission Standards for Hazardous Air Pol-
lutants (NESHAPs). POTWs may also be regulated by
state standards that are more stringent than the federal
requirements. EPA's program for Prevention of Sig-
nificant Deterioration (PSD) is a system whereby new
sources of pollution are subject to special require-
ments. The requirements are designed to protect and
maintain air quality in those areas that meet the
National Ambient Air Quality Standards (NAAQS).
NAAQS have been set for carbon monoxide,  particu-
late matter, lead, nitrogen dioxide, ozone, and sulfur
oxides. For areas meeting the NAAQS (referred to as
attainment areas), increments in air pollution are
specified that would be considered significant in their
impact on public health and welfare. These PSD
increments serve as limits on allowable additions to
existing air emissions. POTWs that plan to construct
an incinerator, boiler, or other air pollution source in
the areas meeting the NAAQS must show that they
will not create pollution sufficient to violate any of the
PSD increments. In addition, these facilities must
employ the Best Available Control Technology for
controlling the air emissions. EPA's PSD program ap-
plies to major stationary sources that have the poten-
tial to emit or do emit more than 100 tons per year (or
250 tons per year, depending on the source category)
of any pollutant covered under the CAA (40 CFR Part
52). For areas not meeting the NAAQS (nonattain-
ment areas), POTWs may be required to achieve even
more stringent emissions levels.

    EPA's New Source Performance Standards
(NSPS) program regulates emissions from sources
that threaten the NAAQS. The NSPS program res-
tricts emissions from new industrial facilities or facili-
ties undergoing major modifications. The NSPS
standards are uniform national rules for specific
industrial categories, such as utility steam boilers.
The NSPS standards for sewage treatment plants cur-
rently cover only paniculate matter and opacity (40
CFR Part 60).  The standards specify that no sewage
sludge incinerator can discharge particulate matter at
a rate in excess of 0.65 g/kg dry sludge input (1.30
Ib/ton dry sludge input), or discharge any gases that
exhibit 20 percent opacity or greater. In addition, cer-
tain boilers may be subject to NSPS standards for par-
ticulate matter, sulfur dioxide, and nitrogen oxides.
These standards depend upon the BTU output and
type of fuel utilized by the unit. POTWs planning to
construct, modify, or expand a sludge incinerator are
regulated by EPA's NSPS program.
    The National Emission Standards for Hazardous
Air Pollutants (NESHAPs) program is applicable to
both sludge incinerators and dryers and requires
POTWs whose mercury emissions exceed 1,600 g per
24-hour period to test their sludge or emissions for
mercury at least once every year. Emissions from any
combination of sludge incineration and sludge drying
cannot exceed 3,200 g. of mercury per 24-hour period
(40 CFR Part 61  Subpart C). Although EPA antici-
pates that few POTWs  will exceed NESHAPs stan-
dards, all facilities must demonstrate compliance
through testing. POTWs that incinerate beryllium-
containing waste may be subject to the beryllium
NESHAP, which sets daily emission limits from the
incinerator. Only POTWs  receiving significant
volumes of wastewater from a beryllium processing
plant could potentially exceed the limit (see 40 CFR
Part 61 Subpart E).

                    Other  Pollution  Issues
5.1  RCRA Corrective Action
    Any POTW holding a RCRA permit (including
POTWs that handle hazardous waste under a permit-
by-rule) that releases a hazardous waste to the en-
vironment may be required to take several corrective
measures. First, the POTW may be required to take
immediate action to reduce imminent danger posed by
waste at the facility or any waste that has leaked be-
yond the site. In addition, EPA may require the facili-
ty to perform ground-water monitoring to evaluate the
extent of the problem. Finally, EPA may require the
facility to clean up the contamination and take other
steps to protect public health. EPA (or the authorized
state) then incorporates these corrective action re-
quirements into the POTWs NPDES permit. For ex-
ample, if EPA discovers that hazardous waste from a
POTWs surface impoundments has leaked into
ground water, the Agency could require a POTW to
pump and treat pollutants in contaminated ground
water and to supply nearby residents with alternative
sources of drinking water.  These requirements would
then be incorporated into the POTWs NPDES permit.
    Releases of hazardous constituents to all media
are subject to corrective action. EPA's corrective action
program applies to all solid waste (as defined by
RCRA) management units (SWMUs), including
containers, tanks, waste piles, surface impoundments,
and landfills. For example, all wastewater treatment
units within a POTWs boundaries are covered by cor-
rective action requirements. EPA has developed
guidance to assist POTWs in complying with RCRA's
corrective action requirements.

5.2 Emergency Planning and
     Community  Right-To-Know
    In 1986, Congress  amended CERCLA by enact-
ing the Superfund Amendments and Reauthorization
Act (SARA), which included a new provision: Title
III—the Emergency Planning and Community Right-
to-Know Act. This law requires that detailed informa-
tion about the nature of hazardous substances in or
near communities be made available to the public.
Several components of this legislation affect POTWs
and the chemicals they use.
    Sections 302 and 304 of Title III (40 CFR 355.30
and 355.40) require that POTWs notify their State
Emergency Response Commission (SERC) and Local
Emergency Planning Committee (LEPC) in writing if
they have any of 366 extremely hazardous substances
(EHS) present at their facilities above "threshold
planning quantities" (TPQs), or immediately if any of
the chemicals are released in quantities equal to or
exceeding their "reportable quantities (RQs)" estab-
lished under CERCLA, or 1 pound if they are not
CERCLA hazardous substances. In addition, Title III
requires that these POTWs participate in emergency
planning. The 366 EHS and their threshold quantities
are listed in 40 CFR Part 355 Appendix A, and in-
clude the chemicals listed in Table 5-1 that are fre-
quently used by POTWs.

    Moreover, POTWs must immediately report to
their SERC and LEPC any release of a CERCLA
hazardous substance equal to or in excess of its
reportable quantity (40 CFR 355.40), in addition to
calling the National Response Center (see Section
3.3.1). Some chemicals commonly found at POTWs,
including ferrous chloride, methanol, potassium per-
manganate, ferric chloride, phosphoric acid, sodium
hypochlorite, and calcium hypochlorite, are
hazardous substances that should be considered in the
NPDES permit. For example, ferrous chloride dis-
charges exceeding 100 pounds daily in the effluent
that are federally permitted would  not require notifi-
cation under 40 CFR 355.40. Note that hydrogen
peroxide, ozone, and sulfur dioxide are currently
proposed for designation as Superfund hazardous
substances and must be reported to SERC and LEPCs
at the one-pound level.
    In addition to emergency notification provisions,
Section 311 provides that facilities which are required
by the Occupational Safety and Health Administra-
tion (OSHA) to prepare or have available Material
Safety Data Sheets (MSDSs) for hazardous chemicals
must also provide SERCs, LEPCs, and fire depart-
ments certain information on these chemicals if they

                   Table 5-1
        Some  Of  The EHS
       Chemicals At Or  In
      POTWS That  Trigger
          SARA Reporting


 Chloride (anhydrous)


 Nitric Acid


 Sulfur Dioxide

 Sulfuric Acid
Threshold    Title III
 Planning   Reportable
 Quantity    Quantity
 500 Ibs.     100 IDS.

 100lbs.      10 Ibs.

 500 Ibs.   5,000 Ibs.
 1000 Ibs.
1 Ib.
1000 Ibs.    1000 Ibs.

  100 Ibs.       1 Ib.

  500 Ibs.       1 Ib.

1000 Ibs.    1000 Ibs.
 *A standard chlorine gas cylinder weighs 150
  pounds, so most POTWs must notify under
  Section 302.

produce, use, or store certain quantities. This infor-
mation includes copies of the MSDSs or a list of
chemicals on which MSDSs are maintained and an
annual inventory form indicating amounts used and
stored. Many of the chemicals used at POTWs are
subject to this requirement if they are stored in quan-
tities greater than 10,000 pounds, including, but not
limited to: lime (calcium oxide), polymers, methanol,
potassium permanganate, alum, ferric chloride, pick-
le liquor, phosphoric acid, sodium hypochlorite, cal-
cium hypochlorite, copper sulfate, carbon dioxide,
other compressed gases, gasoline, cleaning solvents,
and strong acids and bases. In addition, hazardous
substances generated and/or stored by POTWs, such
as methane and chlorine dioxide, are subject to
MSDS requirements. Publicly owned and operated
POTWs may not be covered by this requirement if
they are not covered by OSHA's Hazard Communi-
cation Standard. However, states may enact their
own community right-to-know laws paralleling the
federal Title III requirements and these statutes may
require publicly owned and operated facilities to
comply with the MSDS requirements.
5.3 Underground Storage Tanks
    Most POTWs use underground storage tanks
(USTs) to store fuel oils, gasoline, waste oils, or other
chemicals. These tanks are now regulated under
RCRA. POTWs with USTs containing either petroleum
or CERCLA hazardous substances must notify the
state or local implementing agency of the number and
type of tanks on the premises, and abide by require-
ments covering, among other things, proper design
and installation of tanks, general operating practices,
detection and reporting of leaks or spills, and investi-
gation and cleanup of releases. Financial responsibili-
ty for taking corrective measures and compensating
individuals who are harmed by leaks or spills extends
only to those facilities that store petroleum products
in USTs. (The September 23, 1988, 53 FR 37082 and
October 26, 1988, 53 FR 43322 regulations will be
codified in 40  CFR Part 280, available in fall,  1989).

5.4 Oil Pollution Prevention
    Many POTWs store fuel oil, machinery lubrica-
tion oil, or waste oil (including oil-laden sludges,
precipitates, and residues) on site. POTWs are pro-
hibited by EPA regulations, under the Clean Water
Act, from discharging oil that causes a film or sheen,
discolors the water surface or adjoining shorelines (40
CFR Part 110), or violates any water quality stan-
dards. Discharges in compliance with an NPDES per-
mit, however,  are exempted from these regulations.
    POTWs with the potential to discharge oil (in any
form, including petroleum, fuel oil, sludge, oil
refuse, or oil mixed with waste) in harmful quantities
into navigable  waters or adjoining shorelines may be
required to prepare a Spill Prevention Control and
Countermeasure (SPCC) Plan (40 CFR Part 112).
POTWs maintaining an oil storage capacity in excess
of 660 gallons in a single above-ground tank, or an
aggregate storage capacity of 1,320 gallons in above-
ground containers or 42,000 gallons in below-ground
containers, must comply by establishing a SPCC
Plan. The SPCC Plan must describe the procedures,
methods, and equipment that the POTW will use to
prevent any spilling, leaking, dumping, or other dis-
charge of oil to navigable waters. Due to the broad
range of types of facilities required to develop SPCC

Plans, EPA has no specific plan format requirements;
however, the Agency lists a number of facility-specific
requirements in 40 CFR Part 112.
    In addition, any waste oils contaminated with
PCBs at 50 ppm or over must follow the storage and
disposal requirements of 40 CFR Part 761.

5.5 National  Environmental
     Policy Act (NEPA)
    If a POTW receives federal funding, the facility
is required to plan its policies and actions in light of
                                  the environmental consequences under the National
                                  Environmental Policy Act (NEPA), enacted in 1969.
                                  The POTW must prepare an environmental impact
                                  statement (EIS) for any major action that will signifi-
                                  cantly affect the quality of the human environment.
                                  Such actions could include expansion of the facility or
                                  changing the location of the discharge pipes. The EIS
                                  must identify and address the environmental impacts
                                  of the proposed action and identify, analyze, and com-
                                  pare options (40 CFR Part 1500).
                                   APPENDIX  A
              Glossary and  Abbreviations

                   CAA   -   Clean Air Act (1970)

               CERCLA   —   Comprehensive Environmental Response, Compensation,
                              and Liability Act (1980) (pronounced "sir kla ), as
                              amended (Superfund)

                   CFR   —   Code of Federal Regulations

                   CSO   —   Combined Sewer Overflow

                  CWA   —   Clean Water Act of 1972, as amended

             EP Toxicity   —   Extraction Procedure Toxicity (40 CFR Pt. 261, App. II
                              of RCRA)

                   EPA   —   U.S. Environmental Protection Agency

                    FR   —   Federal Register: week-day government publication that
                              contains proposed and final regulations with explanatory
                              preambles; [54 FR 5746 is the 1989 FR starting on page

                   GPO   —   Government Printing Office; sells FR subscriptions, daily
                              FR copies as available, and CFRs; (202) 783-3238

                           -   Defined by and regulated by CWA and CERCLA
                              (CERCLA's list contains all of the CWA substances, plus
                              additional substances).

                              Defined by and regulated by RCRA

                  LEPC   —   Local Emergency Planning Committee, as established in
                              SARA Title III, Sections 301 to 303. LEPCs develop local
                              emergency response plans.


   MSDSs   —   Material Safety Data Sheets (OSHA)
 Monofills   —   Landfills designed to accept only one type of waste
    NEPA   —   National Environmental Policy Act
NESHAPS   —   National Emission Standards for Hazardous Air Pollutants
   NPDES   —   National Pollutant Discharge Elimination System (CWA)
    NSPS   —   New Source Performance Standards (CAA)
    OSHA   —   Occupational Safety and Health Administration
    PCBs   —   Polychlorinated biphenyls (TSCA)
   POTW   —   Publicly Owned Treatment Works (CWA)
   Priority   —   Listed in 40 CFR Part 423, Appendix C (CWA)
     PRP   —   Potentially Responsible Party (CERCLA)
     PSD   —   Prevention of Significant Deterioration (CAA)
    RCRA   —   Resource Conservation & Recovery Act, as amended
                 (pronounced "rick-ra" or "wreck-ra")
      RQ   —   Reportable Quantity of hazardous substances (CERCLA)
    SARA   —   Superfund Amendments and Reauthorization Act of 1986
                 (amended CERCLA)
    SERC   —   State Emergency Response Commission, as established in
                 SARA Title III, Sections 301 to 303. SERCs establish
                 emergency planning districts, and appoint, supervise, and
                 coordinate LEPCs.
    SPCC   —   Spill Prevention Control and Countermeasure
   SWMU   —   Solid Waste Management Units (RCRA)
    TCLP   —   Toxicity Characteristic Leaching Procedure (RCRA)
   Title III   —   Emergency Planning and Community Right to Know Act
                 of 1986 (EPCRA, part of SARA)
     TPQ   —   Threshold Planning Quantity (Title III of SARA)
     TRE   —   Toxicity Reduction Evaluation (CWA)
    TSCA   —   Toxic Substances Control Act (pronounced "toss-ka")
    TSDF   —   Treatment, Storage, and Disposal Facility (RCRA)
     UST   —   Underground Storage Tank (RCRA)
    Vessel   —   Object designed for navigation on the water (ships, boats,
    WQA   —   Water Quality Act

                      APPENDIX  B
  Sources of Additional Information
CERCLA issues

RCRA issues
Underground storage
  tank regulations
Emergency planning and
  community right-to-know

CFRs, Acts, FR
EPA Contact Name
& Organization
RCRA/Superfund Hotline

RCRA/Superfund Hotline

RCRA/Superfund Hotline

TSCA Hotline
Emergency planning and
community right-to-know
information line

Not copyrighted or protected;
at many libraries or for
purchase from the Government
Printing Office (GPO)
Contact Phone
(800) 424-9346
(202) 382-3000

(800) 424-9346
(202) 382-3000
(800) 424-9346
(202) 382-3000
(202) 554-1404
(800) 535-0202
(202) 479-2449
(202) 783- 3238
Title 40 CFR is updated as of July 1 of each year. The July 1, 1989 versions will
be available from GPO in fall 1989. 40 CFR Parts are bound as follows (e.g., 40
CFR 403.5 is in the volume containing 40 CFR Parts 400-424):

   1- 51    EPA general, grants, air programs
     52    Air programs, cont.
 53- 60    Air programs, cont.
  61- 80   Air programs, cont.
 81- 99    Air programs, cont.
100-149    Water programs (1988 version costs $25)
150-189    Pesticide programs
190-299    Radiation, Noise, RCRA (1988 version costs $24)
300-399    Superfund, Emergency Planning & Community Right to Know
          (1988 version costs $8.50)
400-424    Effluent guidelines (1988 version costs $21)
425-699    Effluent guidelines, cont., Energy policy (1988 version costs $21)
700-end    TSCA, NEPA

                                            P E  N  D  I X   C
                     EPA  Regional   Offices
U.S. EPA Region 1
John F. Kennedy Federal Building
Room 2203
Boston, MA 02203
(617) 565-3715

U.S. EPA Region 2
26 Federal Plaza Room 900
New York, NY 10278
(212) 264-2657

U.S. EPA Region 3
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-9800
U.S. EPA Region 4
345 Courtland Street NE
Atlanta, GA 30365
(404) 347-4727
U.S. EPA Region 5
230 South Dearborn Street
Chicago, IL 60604
(312) 353-2000
New Hampshire
Rhode Island

New Jersey
New York
Puerto Rico
Virgin Islands

District of Columbia
West Virginia
North Carolina
South Carolina

U.S. EPA Region 6                 Arkansas
1201 Elm Street                    Louisiana
Dallas, TX 75270                   New Mexico
(214) 655-6444                     Oklahoma
U.S. EPA Region 7                 Iowa
726 Minnesota Avenue               Kansas
Kansas City, KS 77101               Missouri
(913) 236-2800                     Nebraska

U.S. EPA Region 8                 Colorado
One Denver Place — Suite 1300       Montana
999 18th Street                     North Dakota
Denver, CO 80202-2413              South Dakota
(303) 293-1603                     Utah

U.S. EPA Region 9                 Arizona
215 Fremont Street                  California
San Francisco, CA 94105             Hawaii
(415) 974-8071                      Nevada

U.S. EPA Region 10                Alaska
1200 Sixth Avenue                  Idaho
Seattle, WA 98101                   Washington
(206) 442-5810                     Oregon
NOTE: The telephone numbers listed are general information numbers
only; please ask for the program office to obtain specific information on
the issues discussed in this booklet.


     United States
     Environmental Protection
     Washington, DC 20460

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