Editors' Summary: This Article opens with a brief discussion of RCRA's passage and implementation; it then discusses EPA's rules for determining whether a material is a solid waste and a hazardous waste. The Article then outlines the requirements for generators and transporters of hazardous waste. The standards applicable to facilities that treat, store, or dispose of hazardous waste (TSDFs), including the specific rules and regulations for the land disposal of hazardous wastes, are also discussed, as are the standards and procedures for obtaining a TSDF permit under Subtitle C. The Subtitle C analysis ends with an explanation of the role of state hazardous waste programs in the Subtitle C regime and the provisions for federal and private enforcement of the hazardous waste regulations.

The Article next discusses the basic requirements for disposal of nonhazardous solid waste under RCRA's Subtitle D, and then outlines the newly implemented program for control of underground tanks storing oil or hazardous substances pursuant to RCRA's Subtitle I. The Article concludes with predictions concerning RCRA's reauthorization, which is expected in the 1991-1992 legislative session.