California E P Waste/UIC Class II Fluid Regulatory Interpretation

摘要

Interpretation of the RCRA exemption for E&P wastes and the definition of a hazardous waste in California are complicated by the fact that two separate state agencies have primary authority for federal programs that regulate this waste. The Division of Oil, Gas, and Geothermal Resources received primacy from the U.S. EPA for the implementation of the Underground Injection Control Program for Class II fluids, and the Department of Toxic Substances Control received primary authority for the regulation of RCRA hazardous waste. A problem is created when an operator proposes to dispose of a fluid that is exempt from RCRA regulations and approved for disposal into a Class II well and is considered hazardous under a separate state program. This presentation will focus on the effects of these separate regulatory interpretations on a field example and the resulting interpretation of the regulations.