RCRA Overview

The Resource Conservation and Recovery Act (RCRA) was passed by the United States Congress in 1976 to address problems caused by municipal and industrial waste. RCRA’s focus is on active and future waste facilities and covers generation, transportation, treatment, and disposal of hazardous wastes. Abandoned and historical sites are managed under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) which is also knows as Superfund (paraphrased from information at the EPA website, here and here).

RCRA waste characterization parameters include:

  • ignitibility (flashpoint);
  • corrosivity (pH);
  • reactivity (reactive cyanide & reactive sulfide);
  • toxicity characteristic leaching procedure (TCLP) pesticides;
  • TCLP herbicides;
  • TCLP volatile organic compounds (VOCs);
  • TCLP semivolatile organic compounds (TCLP SVOCs);
  • polychlorinated biphenyls (PCBs);
  • and the “RCRA 8” metals: silver, arsenic, barium, cadmium, chromium, mercury, lead, and selenium.

Other analyses such as chloride, paint filter, and total petroleum hydrocarbon (TPH) suites may also be needed depending upon site history, the waste generator or contract. TCLP Metals is also occasionally required or useful.

Analytical notes:

  • “TCLP” is not one test, but several, and though some of the sample preparation efforts may be combined, this is not possible for every method, and none of the analyses can be combined; each requires a separate method. It is important to account for this in cost estimates.
  • As shown above, reactivity is two methods, both of which are wet chemistry methods.
  • Additionally, although a large carbon range may be analyzed under a single TPH method, the information needed for specific sites requiring THP analysis usually requires one to three separate TPH methods: TPH-gasoline range organics (GRO), TPH-diesel range organics (DRO), and TPH – oil range organics (TPH-ORO). Site history can help determine which carbon ranges are needed.
  • If analysis for polynuclear aromatic hydrocarbons (PAHs) in required, this usually cannot be grouped with SVOCs, but rather, requires a selected ion monitoring (SIM) analysis. Both analyses may be listed as 8270 methods.
  • “Oil & grease” is generally no longer required.
  • There is no such method as “oil & gas”, and anyone requesting such a method usually needs TPH analyses.

RCRA suites are used on environmental projects to determine if waste is hazardous and what type of disposal is required. Some suites may be dropped if site history is well-known and documented; however, any accepting landfill must approve such measures. If such an approach seems logical, consult with the accepting landfill prior to proceeding.

CERCLA suites vary by site and are based upon site history and investigation data. CERCLA suites are formalized in a Record of Decision (ROD), which is based upon the Remedial Investigation/Feasibility Study (RI/FS).

If you need assistance determining the appropriate analytical suites for your site, please click on the contact page and send us an email for an estimate.