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
                                                  [log in to unmask]
     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 
([log in to unmask]).  
Thank you.  

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