Date: Fri, 19 Jul 1996 16:25:03 -0500 (CDT)
From: Christopher Rhodes
Subject: DISPOSAL OF WASTEWATER EFFLUENT FILTER PAPER
To: Compliancenet@ipc.org

IPC has received an inquiry regarding proper disposal of filter paper from final effluent filtering of pretreated wastewater. No data is available on the composition (esp metals) of the used filters, but the wastewater itself contains 0.1-0.3 ppm Cu and 0.05 ppm Pb from the PWB manufacturing operations.

If the filters have picked up metals and thus fail TCLP, then presumeably they would be RCRA hazardous waste.

Any comments, information or additional opinions on this question are welcome. Please post on Compliancenet or email Christopher Rhodes at IPC (rhodch@ipc.org).

Thank you.

Hello Everyone, This is a good Q, but it's not much different than the strip skins and photo resist sludge issue which IPC has been addressing over the past 3-4 years. Note that 70% of EPA's RCRA enforcement is on listed waste issues, so I'd say look at this one very carefully.

40 CFR 260.10 defines a sludge as "any solid, semi-solid, or liquid waste generated from a ... industrial wastewater treatment plant, ... exclusive of the treated effluent from a WWT plant." Although WWT plant is not defined, treatment as "any method, technique, or process, including neutralization, designed to change the physical, chemical of biological character of any hazardous waste ...." It is this approach to what's included in a listed waste that was brought to our attention by an EPA RCRA inspector on debris from suction strainers in WWT. Bottom line is the F006 includes more than the chemical precipitate from the metals removal reaction in WWT, based on EPA's expansive interpretation of "wastewater treatment sludges from ...".

Based on the descriptor of "filter paper from final effluent filtering of pretreated wastewater", I would say that it's an F006 waste. Although the filtrate analyzes low in constituent concentrations, there's no data provided for the chemical particulates removed by the filter paper. Even if they test non-characteristic, the listing classification still applies. I suggest that the questionner seek regulatory interpretation from his/her state authority, assuming that he/she is in a RCRA authorized state. Otherwise, he/she should seek regulatory interpretation from the regional EPA office.

Lee Wilmot
HADCO Corp
603/896-2424
HYPERLINK mailto:lwilmot@hadco.com lwilmot@hadco.com