Hazardous waste generators can be allowed to legally dispose of a small amount of hazardous waste in the sanitary sewer (Publicly Owned Treatment Works, or POTW) if certain conditions are met and if proper notification is made to several agencies.
Below are come common questions Caltha receives regarding this notification.
Does the notification I make or don’t make automatically authorize my discharge of hazardous waste to the POTW?
No. Many POTWs have local or State prohibitions against the discharge to the POTW of certain wastes qualifying as hazardous. All potential dischargers should contact their POTW to verify whether or not the intended discharge is allowed, regardless of a notification.
My POTW has not heard of this notification and does not think it is needed
Some POTWs have few industrial discharges and may not be familiar with reporting requirements that apply to their industrial users. The notification of hazardous waste discharge is a federal rule that applies to industrial dischargers; industrial dischargers need to make their own determination whether or not this notification is needed.
I already submit periodic reports to my POTW. Is this notification still needed?
Yes. This is a one-time notification that helps POTWs keep track of the overall number of industrial users disposing hazardous wastes into their collection system. The notification is also sent to other agencies that do not receive these routine POTW reports
I already submit a notification under the Toxics Release Inventory (TRI) program. Is this notification still needed?
Yes. The TRI chemical list is a separate list of pollutants and reporting requirements are different.
I’m a Very Small Quantity Generator (VSQG) of hazardous waste. Am I subject to these CWA reporting requirements?
Yes. Under RCRA, VSQGs generate ≤100 kg per month of hazardous waste and ≤1 kg of acute hazardous
waste per month . The Clean Water Act does not exempt VSQGs from the one-time notification if they are discharging 15 or more kilograms of hazardous waste per month or any amount of acute hazardous waste.
Are dental or healthcare facilities subject to the reporting requirements?
Yes. According to EPA estimates, the vast majority of healthcare facilities are VSQGs (84%). Over 94% of dental
offices are VSQGs, and 94% of continuing care retirement communities are VSQGs. If a dental office
or other healthcare facility discharges more than 15 kg hazardous waste per month or any amount of acute
hazardous waste per month, they are still required to submit a one-time notification.
My hazardous waste is brought to the POTW by truck. Do the reporting requirements apply to me?
For hazardous waste brought to a POTW by truck or rail, the domestic sewage exclusion (DSE) does not apply and these wastes are fully regulated under RCRA. Therefore, the POTW would only be allowed to receive the hazardous waste if it has a RCRA permit or interim status as a treatment, storage or disposal facility (TSDF), or meets the conditions for a RCRA permit by rule for POTW. Notification requirements only apply to industrial discharges to the POTW via the sewer collection system.
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