Question # 52

52. A RCRA subtitle C hazardous waste landfill facility in NAICS code 562212 is planning to construct a RCRA subtitle D disposal cell on-site. Is this facility subject to EPCRA section 313?
Yes. This facility is subject to EPCRA section 313. Because at least one unit at this facility is regulated by RCRA subtitle C and the facility’s operations are classified in NAICS code 562212, for the purposes of EPCRA section 313, this facility is considered to be in NAICS code 562212 (regulated under RCRA subtitle C). As such, this facility must consider all non-exempted activities at the entire facility for threshold determinations and release and other waste management reporting. The owner or operator should be sure to include any information the facility may have concerning toxic chemicals at the solid waste units of the facility as well as at the hazardous waste units.

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