Understanding the RCRA corrective action process

The Resource Conservation and Recovery Act (RCRA) was enacted in 1976. The Hazardous and Solid Waste Amendments (HSWA) of 1984 specify “corrective action” requirements for protecting human health and the environment from environmental contamination at active hazardous waste treatment, storage, and disposal facilities. RCRA and its corrective action requirements are designed to prevent the creation of new Superfund sites by regulating and remediating active facilities. The RCRA corrective action process has four basic components: the facility assessment, facility investigation, corrective measures study, and corrective measures implementation. This article presents an overview of the RCRA corrective action process and presents four case studies from three U.S. EPA regions.     

Influences on RCRA corrective action costs for nonfederal facilities

Thousands of known hazardous waste sites across the country require remediation, with thousands more yet to be discovered, at estimated cleanup costs of billions of dollars over the next few decades. With this enormous financial burden placed on all members of society through increased prices, taxes, and lost investment opportunities, policy makers face the difficult prospect of defining cleanup standards that meet the goals of protecting human health and the environment and achieving remediation in the most cost-effective manner. Using a statistical methodology to investigate factors influencing the cost of RCRA corrective action, this article examines site characteristics that significantly affect cleanup costs and explains differences in costs among EPA's four proposed Subpart S corrective action options.     

A risk-based approach to how clean is clean

Clearly defined remedial action objectives are a key factor in successful remediation programs. Chemical-specific cleanup criteria are critical components of remedial action objectives. A common risk-based approach can be applied for developing cleanup criteria for remediations under CERCLA, RCRA, and TSCA. This approach involves four steps: identify regulatory requirements; identify chemical-specific cleanup guidelines from previous cleanups; evaluate site-specific risk considering mitigating factors for a given site; select the final cleanup criteria based on information from the first three steps. To describe this approach, this paper presents a case study on a PCB cleanup conducted under TSCA. An objective risk-based approach was used to capitalize on the flexibility built into EPA's PCB cleanup guidelines. EPA granted an exemption to the stated policy on the basis of competing risk factors using a comparative risk-assessment approach. Similarly, risk assessment can be used to take advantage of regulatory flexibility in the selection of applicable or appropriate and relevant requirements (ARARs) under CERCLA, or in the selection of media protection standards under RCRA.     

Treatment of remediation wastes in RCRA corrective action management units

This article explains new EPA regulations that provide for use of corrective action management units (CAMUs) and temporary units (TUs) as cost-effective techniques for remediating hazardous wastes at facilities undergoing RCRA corrective action and at CERCLA remediation sites. The author outlines EPA criteria for approving the use of CAMUs, discusses the benefits and limitations of using them, and recommends possible ways to improve on the CAMU concept.     

Risk assessment and accepted regulatory cleanup levels

The determination of cleanup levels at a CERCLA or RCRA site is often the single most important decision made by risk managers. This decision can have a major impact on the costs and time required for remediation, as well as on the selection of remedial technologies. The object of this article is to provide a critical review of the methods used by regulatory agencies and the regulated community to calculate chemical-specific cleanup goals for inactive hazardous waste sites, focusing on those cleanup goals that are designed to protect human health from the effects of chemicals. In addition to this analysis of historical methods that have been used, this article discusses some innovative solutions to the problem of calculating cleanup levels and presents an analysis of controversial topics related to cleanup levels currently under debate by regulatory agencies, industry, environmentalists, and legislative bodies.     

Passive Treatment Alternatives for Remediating Abandoned‐Mine Drainage

Abandoned‐mine drainage (AMD) is drainage flowing from or caused by surface mining, deep mining, or coal refuse piles that is typically highly acidic with elevated levels of dissolved metals. AMD results from the interactions of certain sulfide minerals with oxygen, water, and bacteria. Passive treatment systems have been used to remediate AMD at numerous sites throughout the United States. The theory behind passive treatment is to allow naturally occurring chemical, biological, and physical reactions that aid in AMD treatment to occur in the controlled environment of the system, not in the receiving water body. The advantages of passive treatment over active treatment include lower operation and maintenance costs, virtually no use of chemicals, and minimal energy consumption. The disadvantages are that smaller volumes of water are treated than with active systems, and discharges with high concentrations of dissolved metals and extremes of pH may have to be treated several times within one system to treat the discharge. AMD passive treatment systems include aerobic treatment systems and anaerobic treatment systems. It is estimated that it will take 50 years and between $5 billion and $15 billion to remediate all AMD problems in Pennsylvania. © 2001 John Wiley & Sons, Inc.     

Estimating the costs of corrective action at land disposal facilities

The U.S. Environmental Protection Agency (EPA) has proposed regulations that would require corrective action (e.g., soil excavation and groundwater removal and treatment) at municipal solid waste landfills (MSWLFs) and hazardous waste treatment, storage, and disposal facilities (TSDFs). This paper presents an overview of the proposed corrective action regulations, and discusses their relationship to proposed or existing closure and post-closure care regulations. The paper then presents estimated corrective action cost curves for various MSWLF scenarios defined by landfill area, average waste thickness, and the presence or absence of a clay liner. The paper finally illustrates the economic benefits of sound closure and postclosure care by comparing estimated costs of corrective action to estimated costs of closure and postclosure care at MSWLFs.     

Using uncertainty analysis to reduce costs at a pump-and-treat site

The former Nebraska Ordnance Plant site in east-central Nebraska was included on the National Priorities List because of explosives and trichloroethene contamination. The preferred groundwater remedy includes hydraulic containment of the contaminated groundwater and focused extraction of the more highly contaminated groundwater as components of the remedial action. The purpose of hydraulic containment is to stop the spread of contamination, while the more aggressive focused extraction will be used to speed up the remediation and reduce total cleanup costs. This case study illustrates how straightforward groundwater models were combined with uncertainty analysis to select a precise definition of the focused extraction areas. The purpose of the analysis was to reduce ultimate remediation costs, given the significant uncertainty associated with the estimated remediation times. The selected definition provides a basis for more sophisticated groundwater modeling, the goal of which was to locate extraction wells and define their flow rates. The batch flushing model provided the governing equations, and Monte Carlo analysis was used for the uncertainty analysis. All of the analysis was performed on a personal computer using commercially available software.     

The treatment of contaminated water at remedial wood preserving sites

Contaminated groundwater and surface water have posed a great challenge in restoring wood preserving sites to beneficial use. Often contaminated groundwater plumes extend far beyond the legal property limits, adversely impacting drinking water supplies and crop lands. To contain, treat, and/or remediate these valuable resources is an important part of restoring these impacted sites. Various options are available for remediating the groundwater and other affected media at these sites. Frequently, pump and treat technologies have been used that can provide well‐head treatment at installed extraction wells. This approach has shown to be costly and excessively time consuming. Some of the technologies used for pump and treat are granular activated carbon (GAC), biotreatment, and chemical oxidation. Other approaches use in‐situ treatment applications that include enhanced bioremediation, monitored natural attenuation (biotic and abiotic), and chemical reduction/fixation. Ultimately, it may only be feasible, economically or practicably, to use hydraulic containment systems. Depending upon site‐specific conditions, these treatment approaches can be used in various combinations to offer the best remedial action. A comparison of water treatment system costs extrapolated from the treatability studies performed on contaminated groundwater from the McCormick/Baxter Superfund site in Stockton, California, yielded operation and maintenance costs of $1.19/1,000 gal. for carbon treatment and $7.53/1,000 gal. for ultraviolet (UV) peroxidation, respectively.     

Remediation of the Radioactive Waste Landfill and Chemical Disposal Pits Sites at Sandia National Laboratories

Sandia National Laboratories' Environmental Restoration (ER) Project remediated the Radioactive Waste Landfill and Chemical Disposal Pits (RWL/CDPs) sites located in Albuquerque, New Mexico. The remediation was conducted in 1996 using conventional excavation, as well as hybrid remote robotic manipulation technology at a cost of approximately $3 million. Wastes generated included approximately 73 cubic meters (m³) of debris (including thermal batteries, spark gap tubes, radioactive sources, weapons components, and some classified material), 535 m³ of plutonium-contaminated soil, and 2,294 m³ of soil contaminated with thorium, cesium, uranium, and tritium. The remediation was successful since the project goal of risk reduction was accomplished and no injuries or negative occurrences resulted. This cleanup is one example of the Department of Energy's (DOE's) accelerated approach to environmental restoration. The remediation was performed as a voluntary corrective measure to reduce schedule and budget, compared with the traditional approach following Resource Conservation and Recovery Act (RCRA) regulations.     

Quantitative analysis of remedial approaches,costs, and time required to remediate dry cleaner sites

This article presents an analysis of remedial approaches, costs, and time required to remediate dry cleaner sites in the United States based on data compiled by the State Coalition for the Remediation of Dry Cleaners (SCRD). Trends in soil and groundwater remedy selection are identified and discussed. Median costs and the time required to remediate dry cleaner sites are presented. In addition, median costs and the duration of soil and groundwater remediation for the most widely used remedial approaches are reported. The analysis is intended to serve the needs of stakeholders, including responsible parties, consultants, regulators, and litigants, as well as real estate developers, banks, and other holders of portfolios of impacted dry cleaner sites by providing quantitative results useful for planning and transactional analysis. © 2011 Wiley Periodicals, Inc.     

Estimating Social Impacts of a Remediation Project Life Cycle With Environmental Footprint Evaluation Tools

This article presents a methodology to calculate the social cost of sustainability metrics with environmental footprint evaluation tools. Measuring the impacts of a remediation project on society is challenging because the methods by which these impacts can be measured have not been established. To perform a complete sustainability assessment of a project's life cycle, costs borne by society in terms of environmental, economic, and community impacts must be evaluated. Two knowledge gaps have been identified among the sustainability assessments currently being performed during a remediation project's life cycle: (1) lack of methodologies available to evaluate impacts on the socioeconomic aspects of remediation and (2) lack of sustainability assessments conducted during the site characterization stage. Sustainability assessments were conducted on two case studies using the methodology proposed in this article: one during the site characterization stage and the other during remedial action. The results of this study demonstrated that costs borne by society from a remediation project are significant and metric specific. This study also highlighted the benefits of conducting a sustainability assessment at the site characterization stage using environmental footprint analysis tools, cost benefit analysis, and an evaluation of costs borne by society. © 2013 Wiley Periodicals, Inc.     

Sustainable Remediation and Decision Analysis Practices at an Onshore Gas Well Site

Strategies for remediation of drilling mud wastes at a typical deep sour gas well site in the foothills of Alberta were assessed in terms of financial and social costs and benefits, in alignment with established sustainable remediation and decision analysis principles. Managers of contaminated sites containing historical drilling wastes are challenged with managing liability through several regulatory changes over time. Excavation and disposal of the contaminated soil from the site was the only means of securing regulatory release, with the nearest landfill located 150 km away. A perception exists that in many cases excavation and disposal inflicts unnecessary levels of site intrusiveness and public disturbance when other options achieving a similar risk end point may do so for lower social cost. The study tested this hypothesis to ascertain whether the currently accepted solution is the best option when the wider costs and benefits to society and the environment are included. Eight remedial strategies were assessed using cost–benefit analysis, including using environmental economics techniques to quantify social and environmental impacts. The economic model showed that methods such as capping in‐place or engineered encapsulation were superior to full excavation and disposal from financial and sustainability perspectives. Quantified external costs and benefits such as road damage, greenhouse gas emissions, public nuisance and safety, and community amenity value were influential in identifying superior options. It was demonstrated that $0.2 million of societal costs could be avoided by choosing capping over landfill disposal. This represents substantial implications when viewed in the context of this and other operators’ portfolios of hundreds of abandoned wells in the area. ©2016 Wiley Periodicals, Inc.     

Hazardous chemical site remediation through capping: Problems with long-term protection

The capping of waste management units and contaminated soils is receiving increasing attention as a low-cost method for hazardous chemical site remediation. Capping is used to prevent further groundwater pollution by existing waste management units and contaminated soils through limiting the moisture that enters the wastes. In principle, for wastes located above the water table, the construction of an impermeable cap can prevent leaching of the wastes (leachate generation) and groundwater pollution. In practice, appropriately designed and constructed RCRA caps can provide for only short-term prevention of groundwater pollution. Alternative approaches are available for capping of wastes that can be effective in preventing moisture from entering the wastes and concomitant groundwater pollution. These approaches recognize the inability of the typical RCRA cap to keep wastes dry for as long as waste constituents will be a threat and, most importantly, provide the necessary funds to effectively address all plausible worst-case scenario failures that could occur at a capped waste management unit or contaminated soil area.     

Costs of forestry best management practices in the south: A review

In response to federal and state clean water laws, forestry best management practices (BMPs) have been developed and implemented to prevent nonpoint source water pollution. Ellefson and Miles (1985) found that estimated BMP costs in the Midwest could amount to more than half of the net returns on national forest timber sales. Henly et al. (1988) found that government costs to implement forest practice rules ranged from as little as $100,000 per year in Idaho and Nevada to more than $4 million annually in California. A review of studies in the South indicates that estimated BMP costs have increased over time. Lickwar et al. (1992) estimated Southeast average costs of $12.45 per acre, $2.34 per MBF, or 2.87% of gross stumpage values based on 1987 BMPs and prices. Woodman and Cubbage (1994) estimated Georgia average BMP costs of $24.33 per acre or $3.02 per MBF for forest industry lands and $41.65 per acre or $5.39 per MBF for NIPF lands. For Virginia, Shaffer et al. (1998) estimated median BMP costs of $18.90 per acre. These moderate cost increases could be attributed to a higher level of standards in the revision of each state BMP guidelines manual, as well as moderate price inflation. BMPs such as better road construction, water bars, culverts, and broad-based dips have been most expensive so far. To date streamside zones have not been very expensive because the rules allow most of the valuable residual tees to be harvested as long as heavy equipment does not operate near the streams. However, this limitation may become much more difficult and costly – as indicated by Kluender et al. (2000) – as fewer chainsaw fellers and cable skidders are available. Stricter BMPs, such as those already adopted to implement forest certification standards in the South or those used to protect salmon habitat in the West, could prompt more expensive southern BMPs for landowners and state agencies in the future.     

Stalking the RCRA leapfrog

In the preceding article, “RCRA Leapfrog: How Statistics Shape and in Turn Are Shaped by Regulatory Mandates,” Dr. Kirk Cameron expressed his opinion on how the RCRA statistical program had developed into its current state, focusing on interactions that have occurred between regulators, geologists, regulated individuals, and a small group of professional statisticians over the past 10 to 15 years. Here, Dr. Robert Gibbons, a member of that small group, responds to some of Dr. Cameron's comments.     

An Updated Cost Study for Enhanced Sludge Washing of Radioactive Waste

This article updates previous cost savings studies conducted to evaluate the use of enhanced sludge washing (ESW) of high‐level radioactive waste at the United States Department of Energy Hanford Site. The cost savings estimate was updated using stochastic analysis based on new information from the Independent Review of Hanford High Level Waste Volume and the more recent Tank Waste Remediation System Operation and Utilization Plan. It is estimated that implementation of ESW in the tank waste remediation system (TWRS) at the Hanford Site can save approximately $4.8 billion compared to the use of an alternative, simpler water wash. The simpler water wash dissolution was found to be 85 percent as effective as the ESW dissolution. Further, the updated remediation cost estimate of $4.8 billion savings is uncertain only within ±$1.6 billion at the 95 percent confidence interval. © 2002 Wiley Periodicals, Inc.