Under the authority of the Resource Conservation and Recovery Act (RCRA), US EPA Region 7 ordered an out of business electroplater in Cedar Falls, IA to immediately comply with RCRA regulations and cleanup hazardous waste contamination on its property (press release).

RCRA is typically known for its regulation of hazardous waste “Cradle to Grave”.

• “Cradle” being the hazardous waste generator,
• “to” being the transportation of the hazardous waste to off-site treatment, storage, or disposal, and;
• “Grave”, the final disposition of the waste, typically by application into or on the land.

Less well known is RCRA’s provisions for the remediation or cleanup of hazardous waste from active hazardous waste facilities – such as this one – both generators (ie. Cradle) and Treatment Storage and Disposal Facilities (ie. Grave).

RCRA authority however, does not extend to the remediation and cleanup of hazardous waste contamination at inactive or abandoned sites or from spills that require emergency response.  The cleanup of these sites is left to CERCLA, the Comprehensive Environmental Response, Compensation, and Liability Act; commonly called Superfund.

Whatever the Act or regulation, improper management of hazardous waste can result in significant costs in the form of agency fines and the need for cleanup.  Contact me to ensure your RCRA training and DOT HazMat Employee training is sufficient to prevent an enforcement action of this type.