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. ------- 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 ------- |