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Hazardous Waste Reporting Requirements

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Section 14.08.310 D. of the City's Municipal Code prohibits the discharge of hazardous substances to the sanitary sewer. Report any discharge of this nature to the Industrial Pretreatment Program at (303) 651-8667 or the Wastewater Treatment Plant at (303) 651-8382.

Hazardous Wastes & the Sanitary Sewer

The 'domestic sewage exclusion' provides an exclusion from the hazardous waste regulations for domestic sewage and mixtures of domestic and other wastes, including hazardous waste. But, it does not provide for the uncontrolled discharge of hazardous wastes to the City sewer. In short, once hazardous wastes enter the sewer, it is not regulated under RCRA, it is regulated under the Clean Water Act, as follows:

All discharges must meet compliance with local, State and Federal regulations. A discharge of hazardous wastes is in compliance with the Colorado Hazardous Waste Regulations if:

  • The facility requests written approval from the City for the discharge;
  • The City issues a letter of authorization allowing the discharge and includes the type and quantity of the hazardous wastes discharged. This letter specifies that the discharge will not cause a violation of the pre-treatment standards or federal regulations;
  • The facility keeps the City letter on site for review during compliance inspections; and
  • The facility stays in compliance with all reporting requirements of 40 CFR 403.12 (p).
In general, the wastewater containing hazardous wastes and located in a wastewater treatment unit is exempt from the hazardous waste regulations provided that the treatment of the hazardous wastes occurs in a tank (or tank system) and the effluent of the pretreatment system is regulated under 40 CFR Part 403. This wastes (in the pretreatment system and the effluent) is regulated under the Clean Water Act under the following conditions:

  • The facility maintains a discharge permit or a zero discharge permit and meets all the local, State and Federal requirements for the discharge to the sewer.

Failure to comply with the above requirements means that the facility is disposing of hazardous wastes (and so, subject to enforcement actions by the EPA, CDPHE and City of Longmont). 

Additional Reporting Requirements

All industrial users are required to notify the City's Industrial Pretreatment Office, the Colorado Department of Health's Hazardous Materials and Waste Management Division and the EPA's Office of Ecosystems, Protection and Remediation of discharges to the sewer collection system of any substance which if otherwise disposed of, would be a hazardous waste under 40 CFR part 261.

This notification requirement applies to industries that discharge 15 kilograms (33 pounds) or more of non-acute hazardous waste or any amount of acute hazardous waste during any calendar month. This is a one-time notification. A new notification, in advance, is required for any substantial change in the volume or type of listed or characteristic hazardous waste discharge.

Notification must be in writing and include the name of the hazardous waste, the EPA hazardous waste number, and the type of discharge (continuous, batch or other). More detailed information is required if an industry discharges more than 100 kilograms (220 pounds) of an EPA listed hazardous waste in any month. Notification must take place no later than 180 days after the discharge of the listed or characteristic hazardous waste.

Permittees: These notification requirements do not apply to pollutants already reported under the self-monitoring requirements of 40 CFR 4-3.12 (b), (d) and (e).

REPORT TO:

City of Longmont
Industrial Pretreatment Program
1100 South Sherman Street
Longmont, CO 80501
phone: (303) 651-8667
or Email the IP Program

Colorado Department of Health and Environment
Hazardous Materials and Waste Management Division
4300 Cherry Creek Drive South
Denver, Colorado 80222-1530
(303) 692-3300

United States Environmental Protection Agency (USEPA)
Office of Ecosystems, Protection & Remediation
999 18th Street, Suite 500
Denver, Colorado 80202-2406
(303) 312-6312


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