Question: If I neutralize my waste, is it still hazardous? How do I dispose of it?
Answer: Let’s take a step back and first discuss waste determinations.
Under the Resource Conservation and Recovery Act (RCRA) hazardous waste generator improvements rule that was just passed, Environmental Protection Agency (EPA) made it clear that waste determinations must be made before a waste is treated.
RELATED POST: RCRA 101 Part 1 — How to Make Solid Waste Determinations
So the key question is: Before you neutralized your waste, was it considered hazardous?
RELATED POST: RCRA 101 Part 2 — How to Make Hazardous Waste Determinations
If it is considered hazardous, would it have been a listed hazardous waste or a characteristic hazardous waste?
RELATED POST: RCRA 101 Part 3 — Listed and Characteristic Wastes
If it would have been a listed hazardous waste, under the derived from rule, any wastes derived from the treatment, handling or storage of that waste are also listed hazardous wastes. So, the neutralized wastes would still need to be handled and disposed of in the same manner as the original hazardous waste regardless of whether a hazard still exists. This rule even applies to the ash that remains after a waste has been incinerated or fuels blended. Yes, the derived from rule is that stringent.
If it would have been a characteristic hazardous waste, under the mixture rule, it is only hazardous if it still exhibits the hazardous characteristic. So, if it was corrosive and you neutralized it to the point where it no longer meets the RCRA definition of corrosive, it is now just a solid waste.
Before disposing of any waste, you should check your state and local regulations as they can be more stringent than federal regulations.
Do you have any other questions about neutralizing waste? Let us know in the comments section below or shoot me an email at firstname.lastname@example.org!