Law RCRA Interactions
CAA • RCRA hazardous waste combustion facilities are subject to CAA permit requirements
Air emissions from RCRA incinerators and other TSDFs must comply with applicable CAA NAAQS and emission limitations
Pollutants and sludges extracted from CAA air emission control devices are subject to RCRA hazardous waste regulations if hazardous
Hospital, infectious, and medical waste incinerators are subject to NSPS and emission guidelines under CAA
Sludges resulting from CWA wastewater treatment and pretreatment are subject to RCRA hazardous waste regulations if hazardous
Discharges from RCRA-permitted facilities must comply with the limitations set forth in NPDES permits
RCRA-regulated USTs may also be subject to CWA SPCC requirements
EPCRA • Some RCRA TSDFs must submit annual reports to EPA detailing releases of chemicals to air, land, and water
FIFRA • FIFRA controls limit the level of toxic pesticides that are produced and thereby reduce the amount of waste that needs to be managed as hazardous under RCRA FIFRA requires the registration of pesticides and disinfectants used in medical waste treatment technologies
MPRSA • MPRSA prevents waste from an RCRA generator or TSDF from being deposited into the ocean, except in accordance with a separate MPRSA permit
OSHA • RCRA hazardous waste generators and TSDFs may need to comply with OSHA training and planning standards
RCRA cleanup activities and hazardous waste operations at generator facilities and TSDFs may need to comply with HAZWOPER regulations
MCLs may be adopted by the RCRA program as cleanup standards for corrective action RCRA contains provisions parallel to SDWA that prohibit the underground injection of hazardous wastes, unless such wastes have been treated to meet their respective LDR treatment standards
TSCA • TSCA controls on the disposal methods of certain chemicals, such as PCBs, reduce the amount of waste that needs to be managed as hazardous under RCRA TSCA controls on the manufacture and use of certain chemical substances also reduce the amount of waste that needs to be managed as hazardous under RCRA
Source: Adapted from U.S. EPA, RCRA Orientation Manual, www.epa.gov/waste/inforesources/pubs/orientat/ rom1.pdf.
3. While medical waste is not subject to federal RCRA regulation, air emissions from new and existing hospital, infectious, and medical waste incinerators are subject to New Source Performance Standards (NSPS) and emission guidelines under CAA.
4. Extraction of pollutants from air emissions using CAA controls (e.g., scrubbers) can create hazardous wastes or sludges containing such wastes. Disposal of these materials must comply with RCRA.
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