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: