RCRA Subtitle C Hazardous Waste

RCRA Subtitle C establishes a federal program to manage hazardous wastes from the moment it is generated to the moment it is finally disposed—that is, from cradle to grave.2 The objective of the Subtitle C program is to ensure that hazardous waste is handled in a manner that protects human health and the environment. To this end, there are Subtitle C regulations for the generation, transportation and treatment, storage, or disposal of hazardous wastes. In practical terms, this means regulating a large number of hazardous waste handlers. As of 1999, U.S. EPA had on record 1575 TSDFs; 17,000 transporters; and about 20,000 large quantity generators (LQGs).2

The Subtitle C program has resulted in perhaps the most comprehensive regulations U.S. EPA has ever developed. The regulations first identify the criteria to determine which solid wastes are hazardous, and then establish various requirements for the three categories of hazardous waste handlers: generators, transporters, and TSDFs. In addition, the Subtitle C regulations set technical standards for the design and safe operation of TSDFs. These standards are designed to minimize the release of hazardous waste into the environment. Furthermore, the regulations for TSDFs serve as the basis for developing and issuing the permits required by the Act for each facility. Permits are essential to making the Subtitle C regulatory program work, since it is through the permitting process that U.S. EPA or a state applies the technical standards to TSDFs.

The hazardous waste management program includes safeguards to protect human health and the environment from hazardous waste that is disposed of on the land. These safeguards are known as the LDR. RCRA also minimizes the hazards of burning hazardous waste by imposing strict standards on combustion units. Because hazardous waste management may result in spills or releases into the environment, RCRA also contains provisions governing corrective action, or the cleanup of contaminated air, groundwater, and soil.

Since waste recycling and recovery are the major components of RCRA's goals, they must be implemented consistently with proper hazardous waste management. As a result, RCRA contains provisions to ensure safe hazardous waste recycling and to facilitate the management of commonly recycled wastestreams.

The RCRA statute additionally grants U.S. EPA broad enforcement authority to require all hazardous waste management facilities to comply with the regulations. The program also contains provisions that allow U.S. EPA to authorize state governments to implement and enforce the hazardous waste regulatory program. State programs must be at least as stringent as the federal program.

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