Resource Conservation and Recovery Act

The information in this handout should serve as a brief explanation of the regulations that pertain to the Resource Conservation and Recovery Act (RCRA), for a complete guide of the rules and regulations please refer to, the Code of Federal Regulations; 40 CFR Part 260-299.

If my university is subject to RCRA, what do I need to monitor/ document?

• Evaluate the waste that your university generates. If it is hazardous, document the life cycle of the waste.
• Determine the type and amount of hazardous waste that you generate (This will serve as a guide in order to determine which rules apply to your school).
• Manage the hazardous waste in the appropriate tanks or storage containers.
• Ensure that all tanks and or storage containers are properly labeled.
• Store the on-site waste only for the allowed time frame (This is a function of the amount of waste generated).
• Maintenance and usage of the proper shipping documentation (i.e. Waste Manifests and Land Disposal Restriction forms).
• Prepare a contingency plan to use to respond to releases or fires involving hazardous wastes.
• Provide hazardous waste management training to all pertinent staff.
• Manage radioactive waste that is mixed with hazardous wastes also subjected to RCRA.

What are some of the common violations encountered at colleges and universities?

• Failure to identify hazardous waste.
• Failure to properly label tanks/ storage containers that are used with hazardous waste.
• Failure to comply with satellite accumulation requirements.
• Failure to provide required training to individuals handling hazardous waste.
• Failure to secure tanks and/ or storage containers of hazardous waste.
• Failure to update the facility’s contingency plan.
• Storing hazardous waste on a long-term basis without a permit.

Specific EPA regulations that may affect RCRA at Colleges/ Universities are listed here:

• 40 CFR Part 261 Identification and listing of hazardous waste
• 40 CFR Part 262 Standards applicable to generators of hazardous waste
• 40 CFR Part 264/265 Standards for owners and operators of hazardous waste treatment, storage and disposal.
• 40 CFR Part 266 Standards for the management of specific hazardous waste and specific types of hazardous management facilities.
• 40 CFR Part 268 Land disposal restrictions.
• 40 CFR Part 273 Standards for universal waste management.
• 40 CFR Part 279 Standards for the management of unused oil.
• 40 CFR Part 280-299 Underground storage tanks (UST)

How would this rule affect a college or university?

The first step in complying with RCRA is identifying which wastes are regulated or hazardous 40 CFR Part 261, Identification and listing of hazardous waste. This can help you identify if the waste that your college or university has generated is considered hazardous waste. All colleges/ universities generate hazardous waste ins some amount. Depending on the amount that you generate, 40 CFR Part 262, Standards applicable to generators of hazardous waste describes how long your facility can accumulate hazardous waste, the manner in which you must store it, and the records that you must produce and maintain on campus. If you store long term, treat or dispose of hazardous waste at your college or university, a permit may be required.