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2026-09-23
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Applicability of the WWTU Exemption to Wood Preserving Facilities
This response addresses EPA’s interpretation of the RCRA wastewater treatment unit (WWTU) exemption as applied to wood preserving facilities. EPA agrees with the state’s position that the material managed in the facility’s sumps and associated tank system does not constitute wastewater for purposes of the WWTU exemption. The response explains that, based on the information reviewed, EPA does not view the matter as indicating a broader issue with the state’s implementation of the WWTU exemption. It also notes that the facility may have a path to return to compliance through operational changes and encourages continued coordination with the state. (See RCRA Online documents No. 11020 (July 31, 1981) and No. 14472 (August 4, 2000))
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Memo
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