Information Pertaining to the
Discharge of Hazardous Waste to the Sanitary Sewer
On July 24, 1990, the Environmental Protection Agency (EPA) promulgated changes to the general
pretreatment regulations that requires Industrial Users (IUs) to submit to the POTW a notification of
hazardous wastes discharged to sewers. An Industrial User is any non-residential user that discharges
non-domestic wastewater to the City sanitary sewer system.
Notification
Any user that discharges listed or characteristic RCRA hazardous wastes to the sewer must notify the
City Pretreatment Coordinator in writing of such discharges. Listed and characteristic wastes are
described in the Code of Federal Regulations at 40 CFR Part 261 (Subparts C and D). In addition to
notifying the City, the IU must also notify the EPA Regional Waste Management Division Director and
State of Louisiana.
Waste Covered by the Notification
Any discharge to the sewer of >15kg of a RCRA hazardous waste, or a discharge of any
quantity of an acutely hazardous waste identified in 40 CFR 261;30(d) and 261.33( e), must
be reported once.
A discharge to the sewer of <15 kg of a RCRA hazardous waste during a calendar month
need not be reported, except for the acutely hazardous wastes indentified in 40 CFR
261.30(d) and 261.33 ( e). A subsequent discharge of >15 kg per calendar month, or of any
quantity of an acutely hazardous waste, must be reported once.
Pollutants already reported under 40 CFR 403.12(b),(d) and ( e) are not subject to this
notification requirement.
Notification Must Contain
1. Notification must contain the following items of Information:
Name of the hazardous waste as set forth in 40 CFR Part 261.
EPA hazardous waste number.
Type of discharge to the sewer (continuous, batch or other).
A certification that the IU has a program in place to reduce the volume and toxicity of
hazardous wastes generated to the degree it has determined to be economicaly practical.
2. If the IU discharges >100 kg of hazardous waste per calendar month to the sewer, the one-time
notification must also contain the following items of information, to the extent such information is
known and readily available to the IU.
An identification of the hazardous constituents contained in the hazardous wastes.
An estimation of the mass and concentration of such constituents in the waste stream
discharged during the calendar month in which the one-time report is made.
An estimation of the mass of constituents in the wastestream expected to be discharged
during the 12 months following the notification.
How to Count the Volume of Hazardous Waste Discharged
If a hazardous waste is mixed with a non-hazardous process or non-process waste stream and the entire
mixture is then discharged to the sewer, the volume of the entire waste stream containing hazardous
waste is considered according to the RCRA “mixture rule” in 40 CFR 261.3(a)(2)(iii).
The effect of this rule is summarized as follows:
Characteristic Wastes
These wastes are classified as hazardous because they exhibit one of the hazardous characteristics
identified in 40 CFR 261.20-261.24 (ie. They are ignitable, corrosive, reactive or toxic). If these wastes
are mixed with non-hazardous material and the mixture is then discharged to the sewer, the notificaiton
must be submitted only if the entire mixture actually discharged is >15 kg per calendar month and if the
entrire mixture discharged still exhibits the characteristic(s).
Listed Wastes
These are wastes that are classified as hazardous pursuant to being listed in 40 CFR 261.30-33. If these
listed wastes are mixed with non-hazardous materials and then discharged to the sewer, the entire
wastestream is considered hazardous and a notificaiton must be submitted. Thus only if the entire
waste stream containing the hazardous waste amounted to <15 kg per calendar month, would the
exemption discussed above apply.
When the Notification Must Be Submitted
The rules below are from the original regulations and apply to any future discharge of new pollutants,
however, return of this One Time Hazardous Waste Notification is due within 30 days of receipt of this
letter to:
Albert dela Cruz, Ph.D.
Department of Environmental Services
345 Chippewa St.
Baton Rouge, LA 70805
The notification must be submitted no later than 180 days after the discharge of a
hazardous waste.
In the case of regulations under §3001 of RCRA identifying new hazardous wastes, the
notification must be submitted within 90 days of the effective date of such regulations.
The notification need be submitted only once for each hazardous waste discharged, except
when there will be a substantial change in the volume or character of the hazardous waste
discharged (generally because of a planned change to the user’s facility or operations). In
case of such a change, the user should notify the Pretreatment Manager in advance.
The Pretreatment Manager may require such additional reporting of these substances as it
deems necessary.
Questionable Wastes
If you have any doubt about whether a mixture discharged to the sewer is hazardous, or if you do not
wish to perform any calculations which may be necessary under the mixture rule, 40 CFR 261.3 (a)(2)(iii),
then you should submit the one-time notification.
For More Information
General questions may be directed to: Albert dela Cruz, Ph.D. 225-389-5456
HAZARDOUS WASTE NOTIFICATION FORM
This form must be completed and returned by all industrial users to the address below. Under Federal
Regulation 40 CFR 403.12 (p) industrial users are required to inform the City of Baton Rouge of any
discharge into the sewer which if otherwise disposed of, would be a hazardous waste under 40 CFR 261.
Company Name:____________________________________________________________________
Address:___________________________________________________Phone #:_________________
City:__________________________________________________State:________________________
Contact Person: ________________________________________ Title: ________________________
Please complete this form by checking either box A. or box B. For either choice also complete C. below.
Material that may qualify as a hazardous waste:
A. Are known to not be discharged from this facility
Skip to and complete C. below.
B. Are known or suspected to be present in the facility discharge
Complete rest of section B. and C. below
Hazardous Waste Information: (Use additional sheets if necessary)
Indicate type of Discharge
Name of Waste
EPA Hazardous
Waste Number
Continuous
Batch
Other(Specify)
If more than 100 kilograms (220 pounds) of any hazardous waste per calendar month is discharged to
the sewer, include the following items of information for each hazardous waste, to the extent such
information is known and readily available.
Hazardous Constituent Information: (Use additional sheets if necessary)
Name of Constituents
Mass in Wastestream
Concentration in
Wastestream
Mass in Wastestream
C. I certify the above information is true and complete to the best of my knowledge. I further certify
that the company has a program in place to reduce the volume and toxicity of hazardous wastes
generated to the degree the company has determined to be economically practical.
__________________________________________ _______________
Signature of Authorized Representative Date
Send Completed Form by Date (30 days) to:
Albert dela Cruz, Ph.D., Department of Environmental Services, 345 Chippewa St. Baton Rouge, LA 70805
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