MIL-HDBK-1005/9A
(1) Testing should establish sludge production
rates, dewatering characteristics, volume and mass to disposal,
and hazardous or nonhazardous nature of the sludge.
(2) Perform the Toxicity Characteristic Leaching
Procedure on sludges produced by alternative physical-chemical
treatment processes before making final treatment process
selection. Use of different chemicals for treatment (such as
lime versus caustic soda) can affect the results of the TCLP and
the declaration of the sludge as a hazardous or nonhazardous
material. Refer to Title 40 CFR, Part 261.24 and amendments for
test procedure and criteria.
(3) For special treatment or waste generation
circumstances that produce hazardous wastes, consider
application to EPA for delisting of waste to nonhazardous
status. Delisting requires demonstration that the waste does
not exhibit hazardous or reactive characteristics. Proving the
waste nontoxic requires proving that the sludge could not leach
hazardous materials at harmful concentrations. Refer to Title
40 CFR, Part 260, Subpart C.
b) Disposal Requirements. Contact the State and
Federal regulatory agencies to determine restrictions that may
be applied to ultimate disposal of industrial wastewater
sludges. Limitations can be expected for handling and disposing
of metal-bearing sludges resulting from wastewater treatment
(biological or physical-chemical). Refer to the paragraphs
above for application of the TCLP to sludge generation and
disposal requirements.
c) Waste Hauler. For very small treatment
operations, utilizing a private sludge hauler may be cost-
effective. Waste hauler capabilities and qualifications should
be closely scrutinized since improper disposal of industrial
sludges will create liabilities for the Navy. The waste
generator is responsible for ultimate disposal under the RCRA.
Transportation of hazardous wastes is strictly regulated by the
RCRA. Exclusion from some RCRA requirements has been allowed
for waste generators producing less than 2,200 lb/mo. This
upper limit applies to the total mass of waste (includes water
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