COMPLIANCE SECTION

EPA Extends Accumulation
Time for Wastewater
Treatment Sludge from Metal Finishers

As a result of the new Common Sense Initiative being conducted by the U.S. EPA, the allowable accumulation time for hazardous waste generated from wastewater treatment in the metal finishing industry has been extended from 90 to 180 days. This extension is tied to the implementation of metals recovery and pollution prevention activities.

INTRODUCTION
On March 8, 2000, U.S. EPA promulgated final regulations that allow large quantity generators (LQGs) of hazardous waste that generate wastewater treatment sludges from metal finishing to accumulate these materials for 180 days (or 270 days in certain circumstances) without a RCRA permit. Wastewater treatment sludges from the metal finishing industry are a listed hazardous waste carrying the waste code F006. Currently LQGs can accumulate wastes (including F006) wastes for 90 days without a RCRA permit. The extended accumulation period for F006 waste is tied to special conditions and all of the current management standards.

REQUIREMENTS
The new rule requires that LQGs may store F006 waste material on-site in tanks, containers or containment buildings for 180 days (or 270 days if the generator must transport the waste 200 miles or more for metals recovery) provided that:

1. The generator has implemented pollution prevention practices related to the F006 waste stream;

2. The F006 waste is recycled by metals recovery;

3. No more than 20,000 kilograms (44,100 pounds) of waste are stored on-site at any one time; and

4. The generator complies with the applicable management standards (same as for 90 day accumulation areas).

If a generator already has pollution prevention practices in place for the F006 waste stream, they will not be required to implement additional practices. The rule is only applicable in states that do not have final authorization for implementation of the RCRA program. Because the standard is less stringent then the existing rule, states are not required to adopt this standard.

SUMMARY
The U.S. EPA has granted an extension in the allowable accumulation time from 90 to 180 days for LQG facilities that generate F006 wastes from wastewater treatment in metal finishing. If you would like more information on the revised rule, or you would like to determine its applicability to your facility, please contact Kara Pettinger or Tony Domanico at (513) 489-2255 or toll free at (800) 229-1443 or by e-mail at kmp@paynefirm.com or aid@paynefirm.com.