RCRA, Subtitle C - Hazardous Waste

P disearded aeutely hazardous eommereial ehemieal produets 

D wastes for whieh the above eodes do not apply - eonsidered hazardous only if they exhibit ignitability (I), eorrosivity (C), reaetivity (R), and/or toxieity (E/H/T). 

RCRA also addresses the transportation of hazardous waste (40 CFR 263). Any transporter of hazardous waste must also comply with the Department of Transportation (DOT) rules under the Hazardous Materials Transportation Act (HMTA) regarding proper labeling, packaging, handling, and placarding.  

Other provisions exist if the solid waste will be incinerated. 

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A material cannot be a hazardous waste if it does not meet the definition of a solid waste. Thus, wastes that are excluded from the definition of solid waste are not subject to the RCRA Subtitle C hazardous waste regulation. There are 20 exclusions from the definition of solid waste ... 

There are five classes of injection wells (Class I through V). Class I disposal wells are used for the disposal of industrial and hazardous waste streams, and may also be subject to certain RCRA, Subtitle C hazardous waste management regulations. Class II wells are defined as those wells used in conjunction with oil and gas production activities. Class III wells are defined as those wells that inject fluids ... 

A. No. Unused products, if disposed of, are not exempt, regardless of their intended use, because they have not been used and therefore are not uniquely associated with the exploration or production of oil and gas. When unused products become waste (e.g., they are disposed of), they are subject to RCRA Subtitle C hazardous waste regulations if they are listed or exhibit a hazardous characteristic. 

EPA has established an exemption from CERCLA release notification requirements for the disposal of hazardous substances at RCRA Subtitle C hazardous waste facilities. Because the disposal of wastes into permitted or interim status facilities is already documented through the RCRA manifest system, EPA believes that notification under CERCLA does not provide a significant additional benefit. 

Under the RCRA exemption, wastes intrinsically associated with the exploration and development of oil and gas do not have to follow Subtitle C regulations for disposal. Under Subtitle C, hazardous wastes must follow strict guidelines for storage, treatment, and transportation and disposal. The cost of handling materials under the Subtitle C scenario is overwhelming. Under the exemption, the operator is allowed to dispose of wellsite waste in a prudent manner and is not obliged to use licensed hazardous waste transporters and licensed Treatment, Storage, and Disposal Facilities (TSDF). 

To provide an overall perspective on how RCRA works, each of its programs—solid waste, hazardous waste, and USTs—and their interrelationships are briefly summarized here. The Subtitle D (solid waste) program is discussed prior to the Subtitle C (hazardous waste) program. Although this is alphabetically out of order, the structure is designed for better understanding by the reader. 

Hazardous waste samples are small, discrete amounts of hazardous waste that are essential to ensure accurate characterization and proper hazardous waste treatment. In order to facilitate the analysis of these materials, RCRA exempts characterization samples and treatability study samples from Subtitle C hazardous waste regulation ... 

Congress, in an attempt to promote mineral development in the United States, has exempted most hazardous wastes produced at the wellsite under the Resource Conservation and Recovery Act (RCRA) Subtitle C regulations. Hazardous wastes are listed due to inherent characteristics of ... 

Since 1980, under RCRA Subtitle C, U.S. EPA has developed a comprehensive program to ensure that hazardous waste is managed safely from the moment it is generated while it is transported, treated, or stored until the moment it is finally disposed (Figure 12.1). This cradle-to-grave management system establishes requirements for each of the following ... 

The hazardous waste identification process (as discussed in Chapter 1) describes how to determine whether a material is a solid and hazardous waste. How a material is regulated under RCRA (i.e., whether or not it is a solid and potentially a hazardous waste) when it is recycled depends on what type of material it is and what type of recycling is occurring. If the recycled material is not a solid waste, then it is not a hazardous waste and is not subject to RCRA Subtitle C requirements. However, if the material qualifies as a solid and hazardous waste, it is subject to RCRA Subtitle C jurisdiction. 

Not all hazardous wastes pose the same degree of hazard when recycled. U.S. EPA believes that wastes that may be recycled in a protective manner, or that are addressed under other environmental regulations, warrant exemptions from RCRA Subtitle C. Consequently, handlers of these materials are not subject to any hazardous waste regulations. These exempt recyclable hazardous wastes are1 2 3... 

Material is a solid waste and may be a hazardous waste subject to RCRA Subtitle C regulation... 

U.S. EPA proposed to significantly impact the RCRA hazardous waste identification process through a rulemaking effort called the Hazardous Waste Identification Rules (H WIR). The first rule, HWIR-media, was finalized on November 30,1998, and addressed contaminated media.16 The second rule, HWIR-waste, was finalized on May 16, 2001, and modified the mixture and derived-from rules, as well as the contained-in policy for listed wastes.5 Both the HWIR-media rule and the HWIR-waste rule attempt to increase flexibility in the hazardous waste identification system by providing a regulatory mechanism for certain hazardous wastes with low concentrations of hazardous constituents to exit the RCRA Subtitle C universe. 

For hazardous waste landfills, RCRA Subtitle C provides certain performance criteria for final cover systems. While RCRA does not specify minimum design requirements, U.S. EPA has issued guidance for the minimum design of these final cover systems. Figure 25.1b shows an example of an RCRA Subtitle C cover at a hazardous waste landfill.30... 

The RCRA Land Disposal Restrictions (LDR) or Land Ban program establishes treatment standards for hazardous waste that are protective of human health and the environment. Once the treatment standards have been met, the waste may be disposed in a landfill or in a surface impoundment. These treatment standards constitute the action levels when determining whether the waste is hazardous per RCRA Subtitle C and whether the treated waste can be disposed in a landfill, surface impoundment or by another land disposal method. 

Authorize states to manage the RCRA Subtitle C program, in whole or in part, within their respective borders, subject to EPA oversight Federal RCRA hazardous waste regulations are set forth in 40 CFR... 

Wastes Generated from Petroleum Refining. Petroleum refining wastes are regulated by EPA in several ways. There are approximately 150 active petroleum refineries in the United States. RCRA Subtitle C currently lists four characteristics as hazardous in 40 CFR 264.21 and. 24 and five waste categories as hazardous in 40 CFR 261.31 and. 32. When most of these wastes were listed beginning in 1980, there were 250-300 active refineries ranging in capacity from about 400,000 barrels (bbl) per day to only a few hundred bbl per day. 

Regulatory Approach to Site Remediation. Most environmental cleanup standards are derived from the provisions of CERCLA, section 121 "Cleanup Standards" or RCRA, Subtitle C entitled "Hazardous Waste Management." The implementing regulations are... 

Small quantity generators (100-1000 kg/month waste) have been regulated under RCRA, Subtitle C, since October 1986. Before then, approximately 830,000 tons of small-quantity generator hazardous wastes were disposed of in Subtitle D facilities every year. 

The act is divided into 10 subtitles (A through J) that provide EPA with the framework and authority to achieve the goals of RCRA. Provisions applicable to electrokinetic remediation are found in RCRA subtitle C, which establishes criteria for controlling hazardous waste from its point of generation to its final disposal (RCRA, 1976). 

The main portion of RCRA dealing with hazardous waste (Subtitle C) contains eight sections. 

RCRA Subtitle C landfill accepts hazardous wastes a RCRA Subtitle D landfill accepts municipal solid wastes. The committee beUeves that residual solids from the processes discussed in this report can be stabilized and pass regulatory requirements for disposal. However, treatability studies will be necessary to demonstrate this. 

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