National Pretreatment Program Hauled Waste
Hauled waste is waste transported by haulers and discharged to a publicly owned treatment works (POTW) by a conveyance other than a pipe (e.g., by truck or rail). Hauled waste might be sewage or domestic waste, or it might include non-domestic waste, or a combination of both types of waste. The term “hauled waste” merely refers to the wastes’ transportation method to the POTW.
Hauled waste might include:
- chemical toilet waste,
- domestic septage,
- ground water remediation site waste,
- grease and sand trap waste,
- restaurant grease,
- hazardous waste,
- landfill leachate,
- nonhazardous commercial and industrial (categorical and noncategorical) waste, and
- wastewater from hydrofracturing or other drilling processes.
Hauled waste can cause adverse impacts to a POTW because it is usually more concentrated than typical domestic wastewater and might not be equalized when discharged. Adverse impacts could include:
- pass through,
- sludge contamination, and
- hazards to POTW personnel.
To help prevent these adverse impacts, the POTW must adequately control the discharge of hauled waste to its treatment plant.
The discharge prohibitions listed at 40 CFR 403.5 apply to all wastes received at the POTW, including domestic and nondomestic hauled waste, regardless of delivery method. The regulation includes:
- general prohibitions against wastes that can cause pass through or interference if introduced into a POTW (40 CFR 403.5(a)) (PDF)(2 pp, 204 K),
- specific discharge prohibitions (40 CFR 403.5(b)) (PDF)(2 pp, 204 K), and
- a specific prohibition against discharge of trucked or hauled pollutants except at points designated by the POTW (40 CFR 403.5(b)(8)) (PDF)(2 pp, 204 K).
In addition to designating a discharge point, many POTWs implement other controls on the discharge of hauled waste, including:
- applying limits to nondomestic hauled waste,
- issuing permits to waste haulers,
- implementing tracking systems,
- sampling loads, and
- refusing all hauled waste.
When a POTW is applying for its NPDES permit, it is required to identify any industrial discharges the plant receives, including:
- hauled industrial wastes and industrial discharges that reach the POTW via pipe (40 CFR 122.21(j)(6)) (PDF)(33 pp, 256 K), and
- hazardous waste and site remediation or cleanup wastewater that it accepts or plans to accept by truck, rail, or dedicated pipe (40 CFR 122.21(j)(7)) (PDF)(33 pp, 256 K).
NPDES permits issued to POTWs must contain standard requirements for the permittee to notify the permitting authority when accepting any new or substantially changed waste (including hauled waste). Federal regulations require the POTW to:
- identify any new introduction of pollutants that it intends to accept (40 CFR 122.42(b)(1)) (PDF)(6 pp, 164 K),
- identify any substantial change that the new introduction of pollutants might have on the overall volume or character of the pollutants being received at the POTW (40 CFR 122.42(b)(2)) (PDF)(6 pp, 164 K), and
- report on how the quality and quantity of the new effluent being introduced into the POTW will impact the plant’s effluent volume and quality (40 CFR 122.42(b)(3)) (PDF)(6 pp, 164 K).
The POTW must report this information with adequate notice so the NPDES permitting authority has enough time to determine whether to modify the POTW’s permit to contain new permit limits or require a pretreatment program because of the effect of the new pollutants.
Categorical pretreatment standards and requirements apply to all categorically regulated wastewater received at a POTW for treatment and disposal. Regardless of how the wastewater arrived at the POTW (e.g., pipe versus being hauled and discharged), it is still subject to those standards.
These resources address identifying hauled waste received at POTWs, implementing hauled waste control programs, and assessing POTW hauled waste programs. These resources include, but are not limited to, the following:
- Guidance Manual for the Control of Waste Hauled to Publicly Owned Treatment Works -- Informs smaller POTWs, particularly those without pretreatment programs, of how to develop and implement hauled waste controls. The guidance includes case studies of successful waste hauler programs and sample forms.It discusses:
- collecting information on waste haulers,
- characterizing hauled waste received,
- evaluating potential impacts, and
- developing and implementing controls.
- Guidance Manual for the Identification of Hazardous Wastes Delivered to Publicly Owned Treatment Works by Truck, Rail, or Dedicated Pipe -- Guides EPA regions and states through identifying POTWs that receive hazardous wastes by truck, rail, or dedicated pipe, and specifies requirements to impose on the POTWs.
- CERCLA Site Discharges to POTWs Guidance Manual -- Manual for feasibility study writers, EPA remedial project managers, state officials, and POTW personnel. It provides the regulatory framework and technical and administrative guidance for evaluating remedial alternatives to discharge wastes from Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) sites to POTWs.
- RCRA Information on Hazardous Wastes to Publicly Owned Treatment Works -- Informs municipal personnel on the hazardous waste requirements of the Resource Conservation and Recovery Act (RCRA). It includes the implications of the requirements for:
- the wastewater treatment plant operated by your municipality,
- your local pretreatment program, and
- local industries served by the treatment plant.
- Strategy for Implementing RCRA Permit-By-Rule Requirements at POTWs that Accept Hazardous Waste by Truck, Rail, or Dedicated Pipe -- Outlines a strategy for implementing RCRA at POTWs that receive hazardous waste by truck, rail, or dedicated pipe.
- Guidance for Implementing RCRA Permit-by-Rule Requirements at POTWs -- Assists water management division directors in issuing RCRA permits by rule and implementing RCRA corrective action requirements at POTWs.
- Guidance Manual for Conducting RCRA Facility Assessments at Publicly Owned Treatment Works -- Guides EPA regions and states on conducting facility assessments at POTWs that receive hazardous waste by truck, rail, or dedicated pipe.