Characteristically hazardous waste

While a number of wastes produced at the wellsite are considered characteristic hazardous waste, some wastes fall under the nonhazardous description. The regulation of these fall under RCRA Subtitle D. Initially Subtitle D wastes were regulated to control dumping of domestic trash and city runoff. The EPA is considering promulgating regulation of certain oil and gas wastes under Subtitle D [231]. 

If a waste is generated that is a listed or characteristic, the operator must follow certain guidelines [232]. A listed hazardous waste (i.e., mercury, benzene) is considered hazardous if the concentrations in which they naturally occur are above certain limitations (40 CFR 261.31-261.33), The listed hazardous waste may not be diluted to achieve lesser concentrations and thus become non-hazardous, A characteristic hazardous waste (40 CFR 261.21-261.24) may be diluted to a nonhazardous status. 

Both listed and characteristic hazardous wastes must meet the LDR treatment standards before they are eligible for land disposal. There are, however, some unique situations that arise when dealing with characteristic wastes under the LDR program. 

There are five regulatory exemptions from the derived-from rule. The first of these derived-from rule exemptions applies to materials that are reclaimed from hazardous wastes and used beneficially. Many listed and characteristic hazardous wastes can be recycled to make new products or be processed to recover useable materials with economic value. Such products derived from recycled hazardous wastes are no longer solid wastes. Using the hazardous waste identification process discussed at the beginning of this chapter, if the materials are not solid wastes, then whether they are derived from listed wastes or whether they exhibit hazardous characteristics is irrelevant. A U.S. EPA module10 explains which residues derived from hazardous wastes cease to be wastes and qualify for this exemption. 

Toxicity characteristic maximum concentration of contaminants for the toxicity characteristic (Hazardous Waste No. D008)... 

Currently, there is much variability in the United States in establishing treatment standards for PAHs in soil and groundwater. For example, Land Disposal Restrictions (LDR) govern the placement of materials destined for any land disposal including landfill, surface impoundments, waste pits, injection wells, land treatment facilities, salt domes, underground mines or caves, and vaults or bunkers. Accordingly, treatment standards for all listed and characteristic hazardous wastes destined for land disposal have been defined (U.S. EPA, 1991) These values thus represent one potential set of treatment standards for PAHs. However, for PAHs,... 

The generator of a waste must determine if the waste is hazardous. To do this, the generator must determine if the waste is specifically listed as a hazardous waste (Article 9, CCR), and/or if it is a characteristic hazardous waste (ignitable, corrosive, toxic, reactive) (Article 11, CCR). Certain wastes are also classified as "extremely hazardous wastes." These are listed in Article 9, CCR and their characteristics are identified in Article 11, CCR. 

Molding - Nonferrous alloy castings, such as brass and bronze, contain lead that may generate wastes which are classified as characteristic hazardous waste due to EP Toxicity. 

LDRs specified in RCRA required EPA to develop treatment standards for hazardous chemical waste and established deadlines for EPA to develop treatment standards for those wastes for which treatment standards did not exist. Congress divided LDR hazardous waste into several categories solvents and dioxins California listed wastes first, second, and third listed wastes and characteristically hazardous wastes. 

Under current EPA regulations, a chemical waste is either hazardous or it is not, and there is no further classification of hazardous chemical waste with respect to the degree of hazard. Some states have defined classes of hazardous chemical waste (e.g., extremely hazardous waste) but, in practice, the requirements on management and disposal of all hazardous wastes have resulted in essentially the same approaches being used regardless of hazard. When a hazardous chemical waste is mixed with a nonhazardous solid waste, the entire waste is classified as hazardous unless the former is a characteristically hazardous waste that does not contain any listed waste and mixing with the nonhazardous waste removes the hazardous characteristic. 

There are two types of regulated hazardous waste characteristic wastes and listed wastes. A solid waste is classified as a characteristic hazardous waste if it exhibits any of the following ignitability, corrosivity, toxicity, or reactivity. A solid waste is a listed hazardous waste if it is specifically listed by the EPA or a state regulatory body based on certain criteria (40 CFR 261.11). 

One of the critical differences between characteristic hazardous wastes and listed hazardous wastes is that, under RCRA regulations, any wastes derived from the treatment, storage, or disposal of a listed hazardous waste (e.g., treatment residues or secondary wastes from storage) are themselves regulated as listed hazardous waste. In addition, any mixture of a solid waste and a listed hazardous waste is then also designated as a listed hazardous waste. The listed hazardous waste designation applies regardless of the actual hazardous characteristics of the waste. Unlike listed hazardous wastes, wastes that exhibit one or more of the RCRA characteristics are not subject to the mixture... 

In addition, petroleum refining wastes are subject to evaluation as characteristically hazardous waste, including the toxicity characteristic (40 CFR 261, Subpart C) which labels wastes "RCRA hazardous" if a measured constituent concentration exceeds a designated maximum (e.g., a benzene concentration of 0.5 mg/L). 

One of the important differences between characteristic hazardous wastes and listed hazardous wastes is that, under RCRA regulations, any wastes derived from the treatment. 

Environmental restoration activities may be conducted under a RCRA, Part B permit when RCRA hazardous wastes are involved. The RCRA hazardous wastes are identified in 40 CFR 261 and Include characteristic" hazardous wastes as defined in subpart C and "listed" hazardous wastes as defined in subpart D. The Hazardous and Solid Waste Amendment (HSWA) to RCRA includes prohibitions on land disposal of hazardous waste. Under this statute, the EPA has issued regulations (40 CFR 286) that ban the land disposal of untreated hazardous waste and has established treatment standards based on the BDAT. The way that these standards can be Involved in a CERCLA remedial action was discussed above. In addition, technical standards for environmental restoration activities conducted under a RCRA, Part B permit are given in 40 CFR 264, Including closure requirements and groundwater concentration limits (see 40 CFR 264.94). 

U.S. EPA Region 10, the Oregon Department of Environmental Quality (DEQ), and U.S. Army Environmental Center (AEC) have used these results for determining the characteristic hazardous waste status of explosives contaminated soil as a reactive waste under RCRA. The basis for the RCRA characteristic hazardous waste status is the assumed explosive reactivity of the soils if subjected to a strong initiating force or if heated under confinement (40 CFR 261.23). These results apply to explosives such as TNT, HMX, DNT, TNB, and DNB, and do not apply to initiating compounds, such as lead azide, lead styphenate, or mercury fulminate. 

Also of note for this report are the RCRA Land Disposal Restrictions (LDRs)." The LDR program was mandated by the RCRA Hazardous and Solid Waste Amendments of 1984. In essence, LDRs are treatment standards for listed and characteristic hazardous waste that must be achieved prior to land disposal. Treatment standards under the LDR program are established on the basis of the best demonstrated available technology and are therefore technology-based (as opposed to risk-based). Although LDR standards are technology-based, EPA has proposed, as part of HWIR, to cap LDR treatment standards with the HWIR risk-based levels. In this manner, treatment would not be required below those levels necessary to minimize risk to human health or the environment. 

Wastes defined as hazardous under RCRA include characteristic and listed wastes. An RCRA-defined hazardous waste is a waste that appears on one of four lists (F list, K list, U list, or P list) or exhibits at least one of four characteristics (ignitability, corrosivity, reactivity, or toxicity). Criteria for identifying characteristic hazardous wastes are included in Title 40, CFR part 261, subpart C. Listed wastes from industrial sources are itemized in 40 CFR part 261, subpart D. Other regulations that are relevant to the technology include the requirement to characterize the waste for a hazardous waste generator (40 CFR part 262.11), the requirement to determine if the hazardous waste is restricted from land disposal [40 CFR 268.7(a)], requirements for on-site storage of waste for up to 90 days [40 CFR 262.34(a)], or 40 CFR 264.553 for storage of waste in a temporary unit for up to 1 year prior to disposal. 

Finding RAP options associated with treatment of EDS neutralents, rinsates, and cleaning solutions depend on whether the waste is regulated as hazardous within the state where it is generated and, if it is, whether it is a listed hazardous waste, a characteristic hazardous waste, or both. 

In all states, the EDS neutralents could be considered characteristic hazardous wastes under RCRA. With some exceptions, a hazardous waste may only be treated, stored, or disposed of in a RCRA-permitted TSDF. In addition, any treatment technology must meet RCRA requirements, such as the Land Disposal Restrictions (LDRs) (40 CFR 268). In accordance with the LDRs, wastes must meet certain treatment standards prior to land disposal. These restrictions provide for additional protection of human health and the environment, but they add considerably to the cost and time required to treat and dispose of the waste stream. Other standards must also be met, such as those associated with treatment facihty operation and closure. 

If the neutralent is a RCRA characteristic hazardous waste, it must be treated in accordance with LDRs before being disposed of in a hazardous waste landfill. Thus, constituent levels must be reduced from those shown in Table C-1 to the treatment technology-based limits before disposal in a landfill. Again, nonstockpile agent is not a listed hazardous waste (except for phosgene), and neither ERA nor the states have specified a treatment technology or treatment limits for the disposal of stockpile or nonstockpile agents. 

Beyond solid wastes, a chemical substance may be labeled as a "hazardous waste" under RCRA if it is listed as a hazardous waste by EPA or if it is determined to be a characteristic "hazardous waste" that exhibits high ignitability, corrosivity, reactivity, or toxicity. Once a material is labeled as a hazardous waste, the material is tracked and permitted at all stages of the manufacturing, use, and disposal process. Generators of hazardous wastes are required to keep detailed records from cradle to grave of the substance to ensure unintended releases and environmental contamination do not... 

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