Which facility must have RCRA permits?

Which facility must have RCRA permits?

• A. TSD facilities
• B. Generator facilities
• C. Recyclers of nonhazardous waste
• D. All facilities

Answer: (A)

Under RCRA, only facilities that actually treat, store, or dispose of hazardous waste must operate under a RCRA permit (or interim status if they existed before the permit program began). That’s why facilities that actively manage hazardous waste through treatment, storage, or disposal require a permit to ensure the site meets design, operating, closure, and monitoring standards. TSD facilities are precisely those that treat, store, or dispose of hazardous waste, so they must have a RCRA permit. Generators and recyclers of nonhazardous waste aren’t inherently subject to RCRA permits—the generator rules govern on-site accumulation and management, and nonhazardous waste recyclers aren’t regulated under RCRA permits unless they also handle hazardous waste. Saying all facilities must have permits is too broad.

Under RCRA, only facilities that actually treat, store, or dispose of hazardous waste must operate under a RCRA permit (or interim status if they existed before the permit program began). That’s why facilities that actively manage hazardous waste through treatment, storage, or disposal require a permit to ensure the site meets design, operating, closure, and monitoring standards.

TSD facilities are precisely those that treat, store, or dispose of hazardous waste, so they must have a RCRA permit. Generators and recyclers of nonhazardous waste aren’t inherently subject to RCRA permits—the generator rules govern on-site accumulation and management, and nonhazardous waste recyclers aren’t regulated under RCRA permits unless they also handle hazardous waste. Saying all facilities must have permits is too broad.