Generally, a wastewater clarifier would be considered a wastewater treatment units (WWTU) under RCRA, as long as the unit meets the WWTU definition in §260.10.
According to §260.10, a WWTU is a device that has a discharge subject to Clean Water Act (CWA) pretreatment standards or permitting requirements under CWA §§402 or 307(b), manages hazardous wastewater or hazardous wastewater treatment sludge, and meets the definition of tank or tank system in §260.10. EPA defines a tank as a stationary device, designed to contain an accumulation of hazardous waste that is constructed primarily of non-earthen materials (e.g., wood, concrete, steel, plastic) that provide structural support (40 CFR §260.10).
Additional guidance regarding types of units that may meet the definition of WWTU is available in the following documents:
Memo, Petruska to Margiotta; June 2, 1994 (RCRA Online #11840)
Memo, Lowrance to Fisher; June 2, 1993 (RCRA Online #11749)
Memo, Williams to Kertcher; June 12, 1987 (RCRA Online #12942)
Memo, Williams to Volz; February 25, 1986 (RCRA Online #11134)
Memo, Porter to Philipp; January 2, 1986 (RCRA Online #12527)
Memo, Williams to Davis; December 24, 1985 (RCRA Online #11118)
Monthly Call Center Report Question; May 1984 (RCRA Online #12218)
In addition, further guidance on the definition of tank is available in the following documents:
Monthly Call Center Report Question; July 1996 (RCRA Online #14011)
Memo, Lehman to Blackburn; August 19, 1986 (RCRA Online #11173)
Memo, Weddle to Devine; April 8, 1983 (RCRA Online #12104)
Is a wastewater clarifier considered a wastewater treatment unit (WWTU) under RCRA?
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