oEPA
Unittd State*
Environmental Protection
Agency
Off ice of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9441.08(83)
TITLE: Leachate from a Municipal Landfill
APPROVAL DATE: io-2i-83
EFFECTIVE DATE: 10-21-33
ORIGINATING OFFICE: osw
SPINAL
D DRAFT
LEVEL OF DRAFT
. , . . . . i. • ' - - .
' ~ D A — Signed by AA or DAA
D B — Signed by Office Director
- D C — Review & Comment
REFERENCE (other documents):
OS WER OS \NER OS WER
VE DIRECTIVE DIRECTIVE Dl
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PART 261 SUBPART A - GENERAL
DOC: 9441.08(83)
Key Words:
Regulations:
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Leachate, Municipal Landfill, Sanitary Landfill
40 CFR Part 261
Leachate from a Municipal Landfill
N. C. Vasuki, General Manager, Delaware Solid Waste Authority,
P.O. Box 455, Dover, Delaware 19903-0455
John H. Skinner, Director, Office of Solid Waste
#9441.08(83) . .
10-21-83
Leachate from a municipal landfill is subject to the hazardous waste
regulations if it is hazardous. Waste is considered hazardous if it is ignit-
able, reactive, corrosive, or toxic. If the le'achate .is a hazardous waste,the .
landfill becomes a hazardous waste generator and the leachate is subject to all
of the hazardous waste regulations unless the landfill qualifies as a small
quantity generator. Currently a hazardous waste generator producing less than
1000 kg. per month is exempt from most requirements of the hazardous waste
regulations.
If the leachate is not a hazardous waste, it can be recycled back into the
landfill. However, if the leachate is a hazardous waste and does not qualify
under the small quantity generator exclusion, the leachate must be treated or
disposed of in a permitted hazardous waste facility or discharged into a public
sewer system.*
* RCRA amendments (May) require study and regulations to control this:
-pre-treatment program POTWS
Note; Discharge CNPDS) permits may not meet this requirement as a result.
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9441.08 (83)
OCT 2
>Hr.' N.Ci; Vasuki
General Manager
Delaware Solid Waste Authority
P.O. nox 455
Dover, Delaware 19903-0455
Dear Mr. Vaaukii
Thank you for your follow-up letter of September 30 requesting
clarification of the news item on leachate that appeared in the
American City & County magazine. Also, please accept my apologies
for not responding to your-letter of August 9 that was apparently
misplaced. . ' •
The statement that nppoarcd in the July, 1983 isaue of
American City and County magazine ia correct. Leachate from a
Municipal landfill is subject to the hazardous waste regulations.
if it is found to be hazardous by any of the hazardous waste
criteria. These criteria include ignitability/ reactivity/
" corrosivity, and toxicity. If the leachate is a hatardous waste
by any of these definitions, the landfill becomes a hazardous
waste generator and the leachate is subject to all the hazardous
waste regulations unless the landfill can qualify as a small
quantity generator. At the present tiire, a hazardous waste
generator producing less than 1000 kg. per month is exempt from
most requirements of "the hazardous waste regulations.
If the leachate is not found to be a hazardous waste, the
leachate can continue to bo recycled back into the landfill.
However, if the leachate ia a hazardous waste and does not qualify
under the small quantity generator exclusion, the leachate
must be treated or disposed'of in a permitted hazardous waste.
facility or, as you noted, discharged into a public sewer ..system...
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* "^
I hope thJfc this clarifies this issue for you. Once again>;.£
please accept my apologies for not responding earlier.
Sincerely yours,
John H. Skinner '
Director • ;
Office of Solid Waste,,
». i . j »ji j
cc: Thomas P. Eichler
Region III Administrator
WH-565E:Kent Anderson:pj:S206:382-4654:WSM:10/19/83
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