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50 Waste Management Practices: Municipal, Hazardous, and Industrial
This expanded definition is significant with respect to hazardous wastes because approximately
95% occurs as liquids or sludges. Some hazardous wastes are specifically excluded, however, from
this definition, for example industrial point source discharges (regulated under the Clean Water Act)
and nuclear wastes (regulated under the Atomic Energy Act).
RCRA grants the U.S. EPA (and, ultimately, relevant state agencies) broad enforcement author-
ity to require all hazardous waste management facilities to comply with the regulations. The haz-
ardous waste management program is intended to ensure that hazardous waste is managed safely
from the moment it is generated to the moment it is ultimately disposed of (the “cradle to grave”
program).
For generators of hazardous waste, the Subtitle C program includes procedures for proper iden-
tification and measuring (“counting”) of hazardous waste. Under RCRA, hazardous waste genera-
tors must comply with regulations concerning recordkeeping and reporting; the labeling of wastes;
the use of appropriate containers; providing information on waste chemical composition to trans-
porters, treatment, storage and disposal facilities; and the use of a hazardous waste manifest system.
Initially, facilities generating less than 1000 kg of waste per month were exempt from the regula-
tions. The 1984 amendments to RCRA lowered this exemption to 100 kg per month. Generator
requirements are presented in Chapter 12.
Under Subtitle C, transporters of hazardous waste must comply with numerous specific operat-
ing standards. The RCRA regulations were integrated with existing Department of Transportation
regulations, which address the transport of hazardous materials. Requirements include the use of the
hazardous waste manifest system, hazard communication, appropriate waste packaging and waste
segregation, and handling incidents during transport. Details of transporter requirements appear in
Chapter 13.
The RCRA program includes standards for facilities that treat, store, or dispose of hazardous
waste. These standards include requirements for general facility management and specific haz-
ardous waste management units (e.g., landfills, incinerators). RCRA requires treatment, storage and
disposal (TSD) facility owners and operators to obtain a hazardous waste permit from the EPA or
relevant state agency. All TSD facilities are required to meet financial requirements in the event of
accidents and to close their facilities in compliance with EPA regulations.
The 1984 amendments imposed a number of new requirements on TSD facilities with the goal
of minimizing land disposal. Bulk or noncontainerized hazardous liquid wastes were prohibited
from disposal in any landfill, and severe restrictions were placed on the disposal of both hazardous
and nonhazardous liquids in hazardous waste landfills. Landfill disposal of several specific highly
hazardous wastes was phased out from 1986 to 1990. The U.S. EPA was directed to review the char-
acteristics of all wastes defined as hazardous and to determine the suitability of their disposal to
land. These safeguards became known as the land disposal restrictions (LDR). Minimum techno-
logical standards were set for new landfills and surface impoundments, for example requiring the
installation of double liners, a leachate collection system, and groundwater monitoring. In the 1984
amendments the federal government set deadlines for the closure of TSD facilities not meeting min-
imum standards.
With the understanding that the routine management of hazardous waste may result in spills or
other releases to the environment, RCRA Subtitle C contains provisions governing corrective action
for the clean-up of contaminated air, groundwater, and soil. Requirements for TSD facilities under
RCRA appear in Chapter 14.
The Subtitle C program also contains provisions that allow the U.S. EPA to authorize and finan-
cially assist state governments to implement and enforce the hazardous waste program. In order to
receive final authorization from the federal government, the state program must be equivalent to, no
less stringent than, and consistent with the federal program. As the EPA develops new regulations,
the state’s program must be reviewed to determine whether the state has the authority to enforce the
relevant requirements. In cases where states do not have authorization, they often participate in run-
ning the program under the so-called Cooperative Arrangements. The Cooperative Arrangements