Frequent Questions

Is a wastewater clarifier considered a wastewater treatment unit (WWTU) under RCRA?

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)
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