For small to medium-sized operations, streamlining wastewater management is an opportunity for improving profitability that’s often overlooked—especially when such wastewater contains EPA “listed” and/or “characteristic” wastes.

In fact—in the parlance of your friendly local MBA—efficient wastewater treatment has evolved into a significant “profitability component.” What he or she means is: Not only is there the in-your-face need to get the stuff out the door as efficiently and inexpensively as possible—you need to consider the sizable liabilities of getting it wrong. You know: all those EPA, state, and local regulations that tend to be strict, stricter, and strictest—-in that order.

Hazardous vs. non-hazardous wastewater

You might say untreated wastewater comes in two flavors: hazardous vs. non-hazardous. (A note from Legal: we’re in no way suggesting that you drink it.)

Making wastewater safe so that it can be returned to the environment usually involves three processes in a row that—amazingly enough—are simply called primary, secondary, and tertiary, aka (1), (2), and (3).

Treating non-hazardous wastewater is usually limited to (1) and (2), which involve:

1. Holding it in a “quiescent” basin, long enough so that heavy solids can sink while oil, grease, and lighter solids can float. If you’ve ever stored homemade soup in the fridge, you’ve seen this process up close and personal: the goods wind up on the bottom and fat winds up on the top. (BTY, your personal trainer would prefer you skim and discard the latter, right?)

2. The second step is something you definitely wouldn’t want to try in your Frigidaire. It involves introducing “beneficial” microbes into the wastewater, the kind that enjoy chowing down on dissolved and suspended biological matter. Your intestines are similarly disposed at this very moment—but you probably don’t want to think about it.

Dealing with nonhazardous wastewater typically involves the third step:

3. Here, the wastewater is disinfected chemically (or in some other way you studied in high school but don’t care to remember.) This also might be done to nonhazardous wastewater if it’s to be used to irrigate—say—a golf course that’s nearby a highly-sensitive or fragile ecosystem (think: pond, lagoon, fishing stream, local politician’s summer estate, etc.).

Emergency spill response

Bear in mind, you need to be just as diligent about avoiding a nonhazardous wastewater spill as you do a hazardous one.

As we’ve blogged about previously, per the EPA, too much of anything—no matter how harmless it might be—can be a hazardous waste if it winds up where it shouldn’t.

Got milk? Our favorite example is a great big farm-fresh tanker of the feel-good stuff.

When one of these puppies overturns and dumps its load, you have an environmental emergency, because an oil slick made of milk fat will block oxygen and sunlight just like a petroleum one—and ecologically devastate any nearby waterway.

And needless to say, the EPA will not be amused.

So even more-so than crying over spilt milk, you don’t even want to think about accidentally spilling industrial wastewater—except that you’d better, because when it happens, you need to have a plan. And as in all things involving the EPA, having access to expert advice is crucial.

More specifically, you need to establish a relationship with a company that specializes in emergency spill response—before anything bad happens. Look for companies that have a documented history of fast response times. (The best of these will usually be onsite in about two hours.)

They should also be expert in the analyses department, too. Like, if your spill involves an unknown chemical or substance, you want them to be able to figure out what it is—quickly and completely—so they can remove it the same way: quickly and completely…and per the law. This is no time to consult somebody’s brother-in-law whose kid has a minor in chemistry.

Transportation: getting it offsite

Part of your responsibilities is ensuring that the transporter you select to remove wastewater from your site (to your preferred disposal, storage, or treatment facility) meets a boatload of DOT requirements.

These minimally include specific labeling and “marking” requirements; and there are strict rules governing the kinds of containers you can use.

To guarantee safe transportation after pick-up, the best companies maintain separate fleets of specialized vehicles, one dedicated to hazardous waste; the other to the non-hazardous kind.

Also, be sure to vet any hazardous waste transport company you’re considering for its ongoing employee education and training. Rules change. And if you employ an under-qualified or “non-permitted” transporter and something goes wrong, you’re on the hook!


Remember: the way the law is written (per the Resource Conservation and Recovery Act or RCRA), you’re responsible for any hazardous waste you “generate” from “cradle-to-grave.” This includes its generation, transportation, treatment, storage, and disposal.

So it bears repeating: Expert advice is crucial.

Call PegEx at (800) 936-2311 or click here to email us.

The featured wastewater treatment image used in this blog post was taken by Senior Airman Sarah Hall-Kirchner and can be viewed here.

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