What is the relationship between the CWA and RCRA regarding the management of waste-waters?
The most important thing to keep in mind is there is a natural hand off from RCRA to the CWA at the point of discharge. NPDES permitted discharges are excluded from RCRA. The collection, storage and treatment of waste- waters that are hazardous waste are not excluded processes. However, certain provisions are allowed if the collection storage and treatment occurs in a waste- water treatment unit (WWTU) as defined in 40 CFR 260.11. LDRs will never apply to NPDES permitted discharges, but they may apply to the disposal of sludge generated during the WWTU operation. The key is the design of the treatment unit, its permit status and whether ancillary equipment is truly part of the WWTU. A lot will depend on the site specific scenario.
