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 hazardousrnwaste in California are complicated by the fact that two separate state agencies havernprimary authority for federal programs that regulate this waste. The Division of Oil, Gas,rnand Geothermal Resources received primacy from the U.S. EPA for the implementationrnof the Underground Injection Control Program for Class II fluids, and the Department ofrnToxic Substances Control received primary authority for the regulation of RCRArnhazardous waste. A problem is created when an operator proposes to dispose of a fluidrnthat is exempt from RCRA regulations and approved for disposal into a Class II well andrnis considered hazardous under a separate state program. This presentation will focus onrnthe effects of these separate regulatory interpretations on a field example and thernresulting interpretation of the regulations.