Frequent Questions

Can a wastewater treatment unit (WWTU) be a series of interconnected trenches or ditches?

A wastewater treatment unit (WWTU) means a device which is part of a wastewater treatment facility that is subject to regulation under either section 402 or 307(b) of the Clean Water Act; receives and treats or stores an influent wastewater that is a hazardous waste as defined in 40 CFR §261.3 of this chapter, or that generates and accumulates a wastewater treatment sludge that is a hazardous waste as defined in §261.3, or treats or stores a wastewater treatment sludge which is a hazardous waste as defined in §261.3; and meets the definition of tank or tank system in §260.10 (§260.10). 

Tank system means a hazardous waste storage or treatment tank and its associated ancillary equipment and containment system (§260.10). 

Drains, troughs, trenches, and ditches are ancillary equipment to a WWTU. Ancillary equipment to a WWTU also qualifies for the WWTU exemption. 

The following guidance documents also clarify the WWTU exemption with regard to trenches: 

Memo, McAlister to Gallagher; February 1, 1994 (RCRA Online #13653
Memo, Shapiro to Davis; May 12, 1994 (RCRA Online #13669)

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