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 ------- 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. ------- 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... ------- * "^ 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 ------- |