Exemption of Oil and Gas Exploration and Production Wastes from Federal Hazardous Waste Regulations
Exemption of Oil and Gas Exploration and Production Wastes from Federal Hazardous Waste Regulations Exemption of Oil and Gas Exploration and ProductionWastes from Federal This publication provides an understanding of the exemption of certain oil and gas exploration and production (E&P) wastes from regulation as hazardous wastes under Subtitle C of the Resource Conservation and Recovery Act (RCRA). The information contained in this booklet is intended to furn ish the reader with:*A basic background on the E&P …
Exempt and Non-Exempt Wastes. 9 In its 1988 regulatory determination, EPA published the following lists of wastes that were determined to be either exempt or non-exempt. These lists are provided as examples of wastes regarded as exempt and non-exempt and should not be considered to be comprehensive. The exempt waste list applies only to those wastes generated by E&P operations. Similar wastes generated by activities other than E&P operations are not covered by the exemption.
Mixing Wastes. Mixing wastes, particularly exempt and non-exempt wastes, creates additional considerations. Determining whether a mixture is an exempt or non-exempt waste requires an understanding of the nature of the wastes prior to mixing and, in some instances, might require a chemical analysis of the mixture. Whenever possible, avoid mixing non-exempt wastes with exempt wastes. If the non-exempt waste is a listed or characteristic hazardous waste, the resulting mixture might become a non-exempt waste and require management under RCRA Subtitle C regulation. Furthermore, mixing a characteristic hazardous waste with a non-hazardous or exempt waste for the purpose of rendering the hazardous waste non-hazardous or less hazardous might be considered a treatment process subject to appropriate RCRA Subtitle C hazardous waste regulation and permitting requirements. NOTE: In a policy letter dated September 25, 1997, EPA clarified that a mixture is exempt if it contains exempt oil and gas exploration and production (E&P) waste mixed with non-hazardous, non-exempt waste. Mixing exempt E&P waste with non-exempt characteristic hazardous waste, however, for the purpose of rendering the mixture non-hazardous or less hazardous, could be considered hazardous waste treatment or impermissible dilution.
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