PARTS 264-265  TSDF TECHNICAL REQUIREMENTS


Key Words:     Wastewater Treatment, TSDF

Regulations:   40 CFR 261.31, 261.32
                                                               DOC: 9480.02(85)
Subject:
               Status of Sludges in Surface Impoundments or Land Treatment
               Units When Wastewater Treatment Sludges Are Listed in
               Sections 261.31 and 261.32
Addressee:     James H. Scarbrough, Chief Residuals Managment Branch, Region IV

Originator:    John Skinner, Director, Office of Solid Waste

Source Doc:    9480.02(85)

Date:          7-17-85

Summary:

      Treatment, storage and disposal units are subject to RCRA regluations if:
they handled wastewater treatment sludges that are listed in 261.31 and 261.3?
or exhibit a characteristic; or if the wastewaters themselves are listed or
exhibit a characteristic.

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                                                            9480.02  (85)
                            JUL 17 1985             RE: WIBCJ0285
MEMORANDUM


SUBJECT:    Status of Sludges in Surface Impoundments or
	    Land Treatment Units when Waatewater Treatment
            Sludges are Liated in $261.31 fc $261.32

PROM:       John U. Skinner, Director
            Office of Solid waate

TO;         James H. Scarbrough, Chief
	         Residuals Management Branch, Region IV


     In your June 20, 1985 memorandum, you asked if waatewater
treatment sludge listings under 1261.31 or f261.32 would
apply in all situations where land disposal or storage of
the associated wastewaters was practiced.  You cited a previous
memorandum fron this office dated November 23, 1984, wherein
a determination was made that wastewatars from wood preserving
facilities treated in spray irrigation fields generated
liated K001 wastewater treatment sludges, ana that such
units are subject to the hazardous waste facility permitting
standards.

     Any pollution abatement technique such as the land
treatment, disposal, or storage of a wastewater will invariably
generate a eludge.  The mechanisms for sludge conation.
involve either precipitation, adsorption, or accumulation
of bioaass.  These units would be subject to regulation
if the associated waetewater treatment sludges are liated  in
9261.31 and 1261.32, if the sludges exhibit a characteristic,
or if the wastewaters themselves are liated or exhibit  a
LiiuiauUuitiJCBEKfl''O>!*a* unit* would therefore be subject to
cct   Regional Administrators
      Regional Branch Chiefs

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