oEPA
United States
Environmental Protection
Agency
Office o*
Solid Waste and
Emergency Response
DIRECTIVE NUMBER:
TITLE: Regulation of Wastewater Treatment Effluent from
Processes that Generate K001 and F006 Wastewater
Treatment Sludge
APPROVAL DATE: 7-25-84
EFFECTIVE DATE: 7-25-84
ORIGINATING OFFICE: office of solid waste
Q FINAL
D DRAFT
STATUS:
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VE DIRECTIVE DIRECTIVE Dl
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PART 261 SUBPART D - LISTS
DOC: 9444.10(84)
•Key Words:
Regulations:
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Wastewater Treatment, Wood Preserving
40 CFR 261.31, 261.32, 260.10, 264, 265
Regulation of Wastewater Treatment Effluent from Processes that
Generate K001 and F006 Wastewater Treatment Sludge
James H. Scarbrough, Chief, Residuals Management Branch, Air and
Waste Management Division
John H. Skinner, Director, Office of Solid Waste
#94494.10(84)
7-25-84
K001 and F006 listings include any sludges derived from the treatment of
wastewater regardless of where the sludges are formed, including a wastewater
treatment tank, filtration device, or surface impoundment. These wastewater
treatment units, with the exception of tanks that treat or store hazardous
wastewaters as part of a wastewater treatment unit as defined in
§260.10, are subject to all hazardous waste regulations.
Wastewater streams from wood preserving processes are not currently listed
as hazardous and would be subject to.regulation only if they meet one or more
of the characteristics of a hazardous waste (§261.21-261.24). Only the waste-
water treatment sludges from these processes are listed as hazardous
A wastewater that passes through a filter in a treatment system is still a
wastewater (rather than leachate) regardless of the fact that the wastewater
may pass through listed material that has accumulated in the treatment unit.
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25 Jin. J984
MEMORANDUM
SUBJECTi Regulation of tfastewater Treatment Effluent from
Processes that Generate K001 and F006 tfastevater
Treatment Sludge
FROM: John H. Skinner, Ph.D.
Director
-..- .. , Office of solid waste
• * ' • *
• -TOi - jaaes B. ficarbrough, Chief
Residuals Management Branch
Air aad Waste Management Division
This »eao ia in response to your request dated May 21, 1984,
concerning regulation of EPA gazardous Haste Ho*. K001 and POOS.
First, you requested clarification of the listings K001 and
F006 as to the scope of their coverage. These listings include
any sludges derived from the treatment of vastewaters regardless
of where the sludges are formed. Thus, if a sludge Is formed in
a vastewater treatment tank, filtration device, or surface impoundment,
it is K001 or P006 sludge. These wastewater treatment units
would be subject to all hazardous waste regulations, including
appropriate permitting standards.*
There is an exception: tanks tnat treat or store hazardous
wastewaters are exempt from the part 264 and 265 Management
standards when the tank is part of a wastewater treatment unit
as defined in 5260.10.
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'~----Too also'requested "clarification'df th« regulatory" status of
the effluents fro* a particular wood preserving facility. The
wastewater treatment train 1« illustrated schematically below:
wood preserving
Cylinder
•A*
Mechanical oil/^ater
Separator Tank
Flor
•a*
culaticn Tank
•T
*
Spray Irrigation Field
Holding Pond
Sand/Gravel Filtration Beds
The effluents from the oil/water separator tank (*A*) and the
chemical flocculation tank (*B*) are not classified as the
listed hazardous waste K001 after the listed hazardous vastewater
treatment sludges have settled out, even though some flocculated
Material is carried along with the effluent stream, when the
Agency listed wastewater treatment sludges from wood preserving
processes, the Agency differentiated between sludges which
settle out from successive treatments of process wastewaters
and the wastewater stream itself. The wastewater effluents
from these two tanks would, therefore, be subject to regulation
only if they meet one or more of the characteristics of a hazardous
waste, as set forth in $$261.21-261.24.
This facility next uses a sand filtration surface impoundment
(*C*) to treat the wastewater effluent after oil/water separation
and flocculation. The sand filter consists of two 20 x 20 x 15
ft. surface impoundments, with natural clay bottoms, and sides
constructed of preserved wood. The wastewater is added to the top
of these units and collected as an effluent from the bottom, and
sent to a holding'pond (*D*) where additional wastewater treatment
sludges are generated. Both the sand filter and the holding pond
would be subject to all hazardous waste regulations and permitting
standards since they are surface impoundments used to manage a
hazardous waste (i.e., the sludge).
The principal regulatory question presented by this sand
filtration unit is whether the wastewater that passes through the
unit loses its status as "wastewater* and becomes "leachate" because
it percolates through the listed sludge that has been trapped in
the unit. We do not believe that the passage of a contaminated
liquid (e.g., leachate, wastewater) through a filter should cause
us to redefine what that liquid is, even though the filter may change
the chemical makeup of the contaminated liquid. For purposes of our
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regulatory definition*, what comes out of a filter is the sane
thing that goes into the Jcilter* ,A vastewater that .passes through
a filter in a treatment system .is still a wastewatar. That result
is not changed by the fact that the filter happens to be a sand bed
and the wastewater emerges from the bottom rather than the top of
the treatment unit.* .
The final step in the wastewater treatment system used by the
wood preserving facility in question is a spray irrigation field
(*B*). We are currently investigating the status of this unit to
determine if it meets the definition of a land treatment unit, a
surface impoundment, or a landfill. We expect to get back to you
on this point in the near future.
t - •*
^ .. »• - ^ *..*.»
The above discussion regarding wastewater treatment units,
wastewaters, and the storage or disposal of hazardous wastewater
treatment sludges wastes is also applicable to other .facilities
generating similar wastes.
It should be noted that this approach also prevents an operator from.
placing a sand filter at the bottom of a landfill and then arguing
that the liquid emerging frcn the bottom of the unit is no longer
a'leachate. Leachate emerging from waste in a landfill remains
a leachate even after it has passed through a filter.
WH-562B/CJENKINS/pes/475-855l/7-l2-84/Disk CJllOl
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