Major RCRA Interactions with Other Environmental Laws

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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