Under RCRA Regulation

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... 

Under RCRA regulations, performance data from one incinerator can be submitted in lieu of conducting a trial burn on a second incinerator. The permit submittal to accomplish this is similar to that described above and requires the following (40 CFR 270.19(c)) ... 

Under RCRA regulations, a trial burn must be conducted prior to initial start-up and whenever a new waste stream or new operating parameter is proposed. The RCRA trial burn plan submitted for regulatory agency approval under either a permit application or permit modification application must contain the following (40 CFR 270.62) ... 

Spent caustic (3800 tons/year) is sent off-site for recovery of remaining caustic value and naphthenic acids. Most catalysts are recycled for recovery of additional activity or metals. Spent cracking catalyst (6(K) tons/year) is sent to Amoco s Whiting, Indiana, refinery for use as equilibrium catalyst. Spent ultraforming catalyst is returned to metals reclaimers to recover platinum for reuse in new catalyst. Spent desulfurization catalyst and polymer catalyst are nonhazardous and are buried in an on-site landfill. Sludges from the oil/water separator are a listed hazardous waste under RCRA regulations. They are combined with other solid wastes, such... 

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

The three primary goals of RCRA are to (1) protect human health and the environment, (2) reduce waste and conserve energy and natural resources, and (3) reduce or eliminate the generation of hazardous waste as swiftly as possible. The three main players under RCRA regulation are (1) hazardous waste generators, (2) transporters, and (3) treatment, storage, and disposal facilities (TSDFs). The following discussion briefly examines each party s roles under RCRA. 

The question of what is considered treatment under RCRA regulations has posed a dilemma for laboratory workers. RCRA regulations define treatment as "any method. .. designed to change the physical, chemical, or biological character or composition of any hazardous waste so as to neutralize such waste, or so as to recover energy or material resources from the waste, or so as to render the waste non-hazardous or less hazardous. .. " (U.S. Congress, 1978). Under RCRA, treatment, with very limited exceptions, must be permitted by EPA. 

Under the Comprehensive Environmental Response, Compensation, and LiabiHty Act (CERCLA)/RCRA regulations in effect at the end of 1986 bromine is regulated as a hazardous waste or material. Therefore, it must be disposed of in an approved hazardous waste faciHty in compliance with EPA and/or other appHcable local, state, and federal regulations and should be handled in a manner acceptable to good waste management practice. The reportable quantity is 45.4 kg for corrosivity (62). 

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]. 

The National Survey of Hazardous Waste Generators and Treatment, Storage, and Disposal Facilities Regulated Under RCRA in 1981. WEST AC, Inc., 1984. 

The major technical problem was the inability to define subsurface geohydrologic conditions with the initial data. Expertise in the area of geohydrology was clearly needed. A lack of specific analytical techniques precluded meaningful environmental and risk assessments. Cleanup efforts were complicated because poltiners are not regulated under RCRA but are regulated under state law. In the middle of the cleanup effort, the site became involved in Superfund activities, and to date this involvement has not been clarified. Project management has become very difficult because of the many players and laws involved. As a result, public confidence has been affected. 

Spent pickle liquor in the acid pickling wastewaters is listed as hazardous waste K062, regulated under RCRA, as it contains considerable residual acidity and high concentrations of dissolved iron salts.2 Exhausted pickling baths are mainly composed of nitrate (150 to 180 g/L), fluoride (60 to 80 g/L), iron (III) (30 to 45 g/L), chromium (III) (5 to 10 g/L), and nickel (II) (3 to 5 g/L). 

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. 

Once hazardous wastes are transported from a CERCLA site, they are subject to full RCRA regulation. Therefore, all transportation and TSD requirements under RCRA must be followed. This means that off-site shipments must be accompanied by a manifest. In particular, the off-site disposal of hazardous wastes can occur only at an RCRA facility in a unit in full compliance with the requirements. U.S. EPA policy requires that the disposal facility be inspected six months prior to receiving the waste. 

Many of these statutes interact closely and even overlap with RCRA. In order to avoid overregulation of industry and coordinate environmental protection laws, Congress required that U.S. EPA, when promulgating RCRA regulations, ensure consistency with and avoid duplication of regulatory provisions promulgated under other environmental statutes. 

U.S. EPA has also developed organic air emission regulations for TSDFs and LQGs under RCRA. However, these RCRA regulations have been designed to minimize, to the extent possible, any overlap with CAA regulations. 

While medical waste is not subject to federal RCRA regulation, air emissions from new and existing hospital, infectious, and medical waste incinerators are subject to New Source Performance Standards (NSPS) and emission guidelines under CAA. 

Hazardous waste identification begins with an obvious point in order for any material to be a hazardous waste, it must first be a waste. However, deciding whether an item is or is not a waste is not always easy. For example, a material (like an aluminum can) that one person discards could seem valuable to another person who recycles that material. U.S. EPA therefore developed a set of regulations to assist in determining whether a material is a waste. RCRA uses the term solid waste in place of the common term waste. Under RCRA, the term solid waste means any waste, whether it is a solid, semisolid, or liquid. The first section of the RCRA hazardous waste identification regulations focuses on the definition of solid waste. For this chapter, you need only understand in general terms the role that the definition of solid waste plays in the RCRA hazardous waste identification process. 

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