U P C L O S E
PWouFld DAesignaSting Hazardous Wastes Under RCRA
or
Hazardous Substances
Under CERCLA
be a BLESSING or a CURSE?
by TIM MILLER and THE CA-NV SECTION AWWA PFAS WORKGROUP
HE RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) Laws and Regulations Program is one
of the cornerstones of the United States Environmental Protection Agency’s (EPA) environmental
protection laws governing hazardous waste disposal. While the basic RCRA statutory scheme
seems simple — hazardous waste is regulated from cradle to grave — this seemingly simple mantra is
burdened with underlying regulations that some have called a mind-numbing web as they map the
path a substance must take to be waste that is hazardous.
26 SOURCE winter 2022
