Background
Congress enacted the Resource Conservation and Recovery Act (RCRA) in 1976 as an amendment to the Solid Waste Disposal Act of 1965. It was the first federal statute to address solid waste. There are several amendments to RCRA, the most important being the 1984 Hazardous and Solid Waste Amendments (HSWA). The regulations for implementing RCRA are outlined in 40 CFR 260–265. Because RCRA is a complicated law, understanding its provisions requires a great deal of interpretive guidance.
RCRA’s major goals are to reduce wastes and providing for conservation of resources. RCRA’s other goals include protecting human health and the environment from potential harm caused by improper waste disposal and (after being amended in 1984) from leaking underground storage tanks. RCRA’s management requirements for solid waste and hazardous waste can create a significant administrative and compliance burden on a campus.
In most cases, individual states implement and manage the federal RCRA program, as they do with many other federal environmental programs. State environmental protection agencies implement their RCRA programs after receiving approval from Environmental Protection Agency (EPA). Although these approved state programs operate in lieu of the federal program, EPA retains regulatory oversight over every state program. Although approved programs must provide at least equivalent protection as the federal RCRA standards, states have some flexibility with their own programs. Although no state program can be less restrictive than federal regulations, states may create more stringent requirements by law, rule, or interpretation.
RCRA gave EPA and state agencies the authority to require management of hazardous wastes from “Cradle-to-Grave.” It also set forth a framework for the management of nonhazardous solid wastes, created a comprehensive underground storage tank (UST) program, and required financial surety for cleanup of releases on operating facilities.
Generally, the RCRA program established
- the definitions of solid and hazardous wastes;
- the design and operational requirements for landfills, incinerators, USTs, etc.;
- the design, operation, and management requirements for hazardous waste handling and storage containers and structures;
- a permitting system for entities that create, manage, transport, treat, or dispose of hazardous wastes, including requirements for cleanup of any releases and financial bonding to ensure the availability of funds for possible future cleanups;
- a cradle-to-grave manifest system used to track hazardous waste; and
- the liability of the entity (such as a campus) that produces wastes.
Key Concepts
Solid Waste
“Solid waste” is the regulatory term for “garbage,” “trash,” or “refuse.” Solid wastes can be liquids, contained gasses, or solids. See Resource Conservation and Recovery Act — Solid and Hazardous Waste.
Hazardous Waste
Hazardous wastes are a specific category of solid wastes. See Resource Conservation and Recovery Act — Solid and Hazardous Waste.
Waste Streams
A waste stream or waste category refers to each type of waste a campus might generate. For example, computer wastes are one waste stream, laboratory waste solvents another.
Does this apply to my campus?
Yes. Many activities on your campus generate solid waste. Some generate hazardous waste. Campus activities that generate regulated wastes may include
- art studios,
- theater departments,
- science departments,
- research activities,
- maintenance shops and activities, and
- groundskeeping operations.
Campuses with USTs might be subject to other RCRA requirements. See Resource Conservation and Recovery Act — Underground Storage Tanks.
What do I have to do?
Ensure that solid and hazardous waste management takes place in accordance with state and federal regulatory requirements.
Ensure that your campus manages USTs in accordance with state and federal regulations.