15    REGULATION OF LIQUID HAULED WASTES IN LOS
ANGELES COUNTY
Suzanne S. Wienke, Project Engineer
Sanitation Districts of Los Angeles County
Whittier, CA 90607
INTRODUCTION
The County Sanitation Districts of Los Angeles County (Districts) are a group of special districts
serving the wastewater and solid waste management needs of over 4 million people and 8,500 industrial users in Los Angeles County. Most of the southern and eastern portions of Los Angeles County
as well as the Santa Clarita Valley and Lancaster/Palmdale areas to the north are included in the
Districts' service area. The City of Los Angeles separately operates their own wastewater and solid
waste management facilities. Unincorporated portions of the county which are not in the Districts' or
the City's service area are under the jurisdiction of the County Department of Public Works (DPW).
Most of the material being discharged into the Districts treatment system comes from sewer-
connected homes and businesses. However, there are areas in the Los Angeles basin which are not
served by sewers but instead use septic tanks and cesspools. Riverside and San Bernardino Counties to
the east of the Districts service area and the rapidly developing areas of northern Los Angeles County
have many homes and businesses which are not sewer-connected but instead use septic tanks or
cesspools. Periodically, these systems must be pumped out and the septage hauled away. Disposal of
septage and other types of nonhazardous liquid wastes is generally accomplished by discharge to an
accessible publicly owned treatment works (POTW).
In 1985, the Districts implemented a program to control the discharge of liquid hauled wastes to the
sewerage system at a series of designated manhole stations. Prior to 1985, trucks used the designated
dumping manholes in an uncontrolled manner which generated concerns about the potential to
discharge toxic and/or incompatible materials to the sewerage system. Uncontrolled use of the system
also lead to concerns about Districts' users subsidizing the treatment and capital costs for dischargers
outside the Districts' service area. Moreover, with the reauthorization of the Resource Conservation
and Recovery Act (RCRA), POTWs were faced with the mandate that acceptance of hazardous waste
via truck, even unknowingly, would require the POTW to comply with regulations for a Treatment,
Storage and Disposal Facility (TSDF). The significance of the RCRA regulations is discussed in more
detail below.
RCRA REGULATIONS
Currently, mixtures of domestic sewage and other wastes which commingle in the POTWs collection system prior to reaching the treatment plant are excluded from RCRA regulation under the
Domestic Sewage Exclusion. However, hazardous materials discharged to a POTW by rail, truck,
vessel or dedicated pipeline are not part of the domestic sewage exclusion and their authorized
discharge can only occur if a POTW complies with RCRA requirements for a TSDF.
The Environmental Protection Agency (EPA) recognized that POTWs are required to comply with
extensive regulations under the Clean Water Act. Consequently EPA adopted a special TSDF provision known as "permit-by-rule," D40 CFR 270.60(c), for POTWs accepting hazardous wastes by
truck, rail or dedicated pipeline. California operates the permit-by-rule similarly. These rules are less
comprehensive than those rules which apply to non-POTW TSDFs.
Under the permit-by-rule regulation, a POTW must 1) have an NPDES permit, 2) comply with that
permit, 3) obtain a RCRA ID number, 4) comply with certain manifest and reporting requirements, 5)
satisfy corrective action requirements and 6) only accept hauled wastes which meet all federal, state
and local pretreatment requirements. Many of these steps are easily accomplished, however the
manifesting and reporting requirements involve significant amounts of time and manpower on the
part of the POTW.
45th Purdue Industrial Waste Conference Proceedings, © 1991 Lewis Publishers, Inc., Chelsea, Michigan 48118.
Printed in U.S.A.
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