17-05-2012, 04:52 PM
Exemption of Oil and Gas Exploration and Production Wastes from Federal Hazardous Waste Regulations
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introduction
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 furnish
the reader with:
A basic background on the E&P exemption.
Basic rules for determining the exempt or nonexempt
status of wastes.
Examples of exempt and non-exempt wastes.
Status of E&P waste mixtures.
Clarifications of several misunderstandings about
the exemption.
scope of the exemption
In December 1978, EPA proposed hazardous waste management
standards that included reduced requirements for several
types of large volume wastes. Generally, EPA believed
these large volume “special wastes” are lower in toxicity than
other wastes being regulated as hazardous waste under
RCRA. Subsequently, Congress exempted these wastes from
the RCRA Subtitle C hazardous waste regulations pending a
study and regulatory determination by EPA. In 1988, EPA
issued a regulatory determination stating that control of E&P
wastes under RCRA Subtitle C regulations is not warranted.
Hence, E&P wastes have remained exempt from Subtitle C
regulations. The RCRA Subtitle C exemption, however, did not
preclude these wastes from control under state regulations,
under the less stringent RCRA Subtitle D solid waste regulations,
or under other federal regulations. In addition,
although they are relieved from regulation as hazardous
wastes, the exemption does not mean these wastes could not
present a hazard to human health and the environment if
improperly managed.