RCRA Listed Mixture Rule

If the waste is listed as a hazardous waste and none of the exemption or exclusions apply then we talk about mixtures of RCRA listed wastes.

You may have heard the adage, Once a RCRA listed hazardous waste always a RCRA listed hazardous waste? A similar rule applies to mixtures that include RCRA listed hazardous waste: a waste mixture that includes a RCRA-listed hazardous waste is automatically a RCRA-listed hazardous waste and carries the listing with the mixture. The chemical concentrations in the waste are irrelevant.

RCRA listed waste mixtures are not considered a listed waste any longer if:

  • A waste that has been delisted by US EPA
  • Wastes listed solely due to a hazardous waste characteristic, and mixture does not exhibit the characteristic (such as F003 – ignitability)
  • Wastewaters containing “de minimus” concentrations of listed wastes discharged under CWA provision
  • Wastes containing minimal losses of P and U wastes due to normal handling or minor leaks
Drip swf

Click to see how the California mixture rule differs from the federal mixture rule.

Title 22 CCR §66261.3(a)(2)
Insignificant, such as minor leaks from process equipment, sample purgings, relief device discharges, rinsate from empty containers.