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.     

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.     

RCRA corrective action costs: An estimating model for nonfederal facilities

This article presents an analysis of the prospective costs of RCRA corrective action for private, nonfederal facilities. Two data bases developed by Research Triangle Institute and a remedial action cost model developed by CH2M Hill provide the foundation for this work. The methodology has two components, a remedial action knowledge base and a discrete-state Monte Carlo analysis. Under base case assumptions, it is estimated that the total costs of RCRA corrective action will be $240 billion, with a 5 percent chance the costs will be less than $170 billion and a 5 percent chance the costs will be more than $377 billion.     

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.     

Policy implementation of the Republic Act (RA) No. 9003 in the Philippines: A case study of Cebu city

Municipal Solid Waste Management (MSWM) is considered to be one of the most serious environmental issues in the Philippines. The annual waste generation was estimated at 10.6 million tonnes in 2012 and this is expected to double in 2025. The Republic Act (RA) No. 9003, widely known as the Ecological Solid Waste Management Act of 2000, provides the required policy framework, institutional mechanisms and mandate to the Local Government Units (LGUs) to achieve 25% waste reduction target through establishing an integrated solid waste management plan based on the 3Rs (reduce, reuse and recycling). Although the initial impact of the LGUs is still very limited in implementing the national mandate, this article highlights the successful experiences of Cebu, the second largest city in the Philippines, in reducing its MSW generation by more than 30% in the past three years. This study also explores the implementation process, innovative actions taken by the Cebu City Government in implementing the national mandate at local level and identifies the factors that influence the policy implementation. The findings suggest that the impacts of the national mandate can be achieved if the LGUs have the high degree of political commitment, planning and development of effective local strategies in a collaborative manner to meet with local conditions, partnership building with other stakeholders, capacity development, adequate financing and incentives, and in the close monitoring and evaluation of performance.     

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.     

A Slice of Guidance Provides Some Insight to Addressing Contaminated Sediments

The U.S. Environmental Protection Agency (EPA) has issued guidance to improve cleanup risk management decisions at sites involving contaminated sediments. The guidance is titled Principles for Managing Contaminated Sediment Risks at Hazardous Waste Sites and is important because sediment cleanup decisions are often very technical and complex. While the guidance is not a step‐by‐step “how to” document, it does provide the framework for risk‐based decision making and national consistency. Although it does not answer the more technical questions associated with remediation, it will likely provide site managers with greater certainty related to their decisions and help determine what questions need to be asked for many complex issues. Additional and forthcoming EPA reports, seminars, and products will be useful in building upon this framework. This article provides an overview of the risk management principles presented in the guidance. © 2002 Wiley Periodicals, Inc.     

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.     

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.     

Understanding and Managing Indoor Air Exposure Assessments at RCRA Sites

The 2000 RCRA National Conference was conducted August 15‐17, 2000, in Washington, D.C., to allow state and federal authorities to review regulatory issues associated with the Resource Conservation and Recovery Act (RCRA) program. One of the RCRA reform issues discussed at the conference included the Government Performance and Results Act (GPRA) Environmental Indicators (EI). EIs have been designed to provide clarity in cleanup objectives and spur progress towards meeting the U.S. Environmental Protection Agency's (USEPA's) national RCRA cleanup goals. This article focuses on the human exposure indicator and, more specifically, on indoor air exposures and how to assess whether such exposure is actually occurring. While indoor air exposure can be a critical component of the human exposure scenarios, realistic predictions of the exposures are difficult to produce. This article provides an overview of the regulatory issues related to the indoor air exposure pathway. It also discusses the use of modeling in criteria development and risk evaluation and presents a case study of how the USEPA wants the modeling to occur, and an opinion of where this RCRA reform issue is heading and how to evaluate indoor air exposures.     

Exploring the motivations and obstacles of the public's garbage classification participation: evidence from Sina Weibo

Journal of Material Cycles and Waste Management - China has been implementing garbage classification to improve resource recycling for many years. Since garbage classification is essentially a...     

Prediction of greenhouse gas emissions from municipal solid waste incinerators with consideration of utilization of heat and captured CO2 in the Tokyo waterfront area

Journal of Material Cycles and Waste Management - We focused on incineration of solid waste and resource recycling, when clarifying how to achieve carbon neutrality (CN) by 2050; we describe how...     

Residential vapor‐intrusion evaluation: Long‐duration passive sampling vs. short‐duration active sampling

Sampling indoor air for potential vapor‐intrusion impacts using current standard 24‐hour sample collection methods may not adequately account for temporal variability and detect contamination best represented by long‐term sampling periods. Henry Schuver of the U.S. Environmental Protection Agency Office of Solid Waste stated at the September 2007 Air & Waste Management Association vapor‐intrusion conference that the US EPA may consider recommending longer‐term vapor sampling to achieve more accurate time‐weighted‐average detections. In November 2007, indoor air at four residences was sampled to measure trichloroethene (TCE) concentrations over short‐ and long‐duration intervals. A carefully designed investigation was conducted consisting of triplicate samplers for three different investigatory methods: dedicated 6‐liter Summa canisters (US EPA Method TO‐15), pump/sorbent tubes (US EPA Method TO‐17), and passive diffusion samplers (MDHS 80). The first two methods collected samples simultaneously for a 24‐hour period, and the third method collected samples for two weeks. Data collected using Methods TO‐15 (canisters) and TO‐17 (tubes) provided reliable short‐duration TCE concentrations that agree with prior 24‐hour sampling events in each of the residences; however, the passive diffusion samplers may provide a more representative time‐weighted measurement. The ratio of measured TCE concentrations between the canisters and tubes are consistent with previous results and as much as 28.0 μg/m³ were measured. A comparison of the sampling procedures, and findings of the three methods used in this study will be presented. © 2008 Wiley Periodicals, Inc.     

Material and energy recovery in integrated waste management system--an Italian case study on the quality of MSW data

This paper analyses the way numerical data on Municipal Solid Waste (MSW) quantities are recorded, processed and then reported for six of the most meaningful Italian Districts and shows the difficulties found during the comparison of these Districts, starting from the lack of homogeneity and the fragmentation of the data indispensable to make this critical analysis. These aspects are often ignored, but data certainty are the basis for serious MSW planning. In particular, the paper focuses on overall Source Separation Level (SSL) definition and on the influence that Special Waste (SW) assimilated to MSW has on it. An investigation was then necessary to identify new parameters in place of overall SSL. Moreover, these parameters are not only important for a waste management system performance measure, but are fundamental in order to design and check management plan and to identify possible actions to improve it.     

Recycling and reuse of industrial wastes in Taiwan

Eighteen million metric tons of industrial wastes are produced every year in Taiwan. In order to properly handle the industrial wastes, the Taiwan Environmental Protection Administration (Taiwan EPA) has set up strategic programs that include establishment of storage, treatment, and final disposal systems, establishment of a management center for industrial wastes, and promotion of recycling and reuse of industrial wastes. The Taiwan EPA has been actively promoting the recycling and reuse of industrial wastes over the years. In July 1995 the Taiwan EPA amended and promulgated the Criteria for the Industrial Waste Storage, Collection and Processing Facility, July, 1995 that added articles related to general industrial waste recycling and reuse. In June 1996 the Taiwan EPA promulgated the Non-listed General Industrial Waste Reuse Application Procedures, June, 1996, followed by the Regulations Governing the Permitting of Hazardous Industrial Waste Reuse, June 1996, setting up a full regulatory framework for governing industrial waste reuse. To broaden the recycling and reuse of general industrial wastes, the Taiwan EPA has listed 14 industrial waste items for recycling and reuse, including waste paper, waste iron, coal ash, tempered high furnace bricks (cinder), high furnace bricks (cinder), furnace transfer bricks (cinder), sweetening dregs, wood (whole/part), glass (whole/part), bleaching earth, ceramics (pottery, brick, tile and cast sand), individual metal scraps (copper, zinc, aluminum and tin), distillery grain (dregs) and plastics. As of June 1999, 99 applications for reuse of industrial wastes had been approved with 1.97 million metric tons of industrial wastes being reused.     

Stabilization and delisting of hazardous wastes: An effective approach for reducing high sludge disposal costs

Delisting (up-front or not) of hazardous waste streams (with or without stabilization or any other form of treatment) can be an effective approach for reducing high sludge disposal costs because a nonhazardous classification of the waste will alleviate the financial burden associated with the disposal costs. Facilities may petition EPA to remove individual waste streams from regulation as listed hazardous wastes under the Resource Conservation and Recovery Act (RCRA). EPA encourages the use of up-front delisting petitions because they have the advantage of allowing the applicant to know what treatment levels for constituents should be sufficient to render specific wastes nonhazardous before investing in new or modified waste treatment systems. Thus, up-front delisting allows new facilities to receive exclusions prior to generating wastes that, without upfront exclusions, would unnecessarily have been considered hazardous. On July 18, 1991, EPA proposed to use the EPA Composite Model for Landfills (EPACML) when considering delisting petitions and evaluating the impact of the petitioned waste on human health and the environment. The use of the EPACML provides consistency in delisting decisions. Further, this new model allows a two-to-three-times higher dilution than the previously used Vertical and Horizontal Spread (VHS) model. This article presents case studies from several industry sectors where stabilization and delisting were used to manage wastes in a reliable, cost-effective, and environmentally sound manner.     

Environmental policy and legal framework for controlling mercury emissions from stationary sources: a case study in Taiwan

Journal of Material Cycles and Waste Management - In recent years, the Taiwan government partnered with the U.S. Environmental Protection Agency (USEPA) Global Mercury Partnership program to follow...     

Estimating the human health risks from polychlorinated dioxins and furans in stack gas emissions from combustion units: implications of USEPA's dioxin reassessment

Shortly after promulgation of the Hazardous Waste Combustor MACT rule established regulatory limits for polychlorinated dioxins and furans (dioxins/furans) in incinerator stack gas, the US Environmental Protection Agency (USEPA) announced that facilities could still be required to demonstrate that stack emissions do not present an unacceptable risk to human health and the environment. Guidance for conducting this risk assessment activity, which was to be required under RCRA omnibus authority, was developed by the agency and released in 1998. The guidance represented an increase in complexity over previous documents developed by the agency and contains multiple chemical, fate and transport, and toxicological parameters which are to be used as default deterministic parameters in a complex series of algorithms which ultimately lead to numerical estimates of risk. As these changes were occurring, USEPA was also moving towards completion of its reassessment of dioxin. That series of documents has been the subject of considerable controversy and has, in several of its various drafts, proposed a number of changes, including modification of the existing toxic equivalency factor (TEF) approach and of the cancer potency factor of 2,3,7,8-tetachlorodibenzo-p-dioxin. At this time it is unclear what the impact of these changes will be on facilities progressing through the permitting process, because it is not intuitively obvious how changes in the risk assessment input parameters will impact the magnitude of the dioxinlfuran risk. In this paper, the receptor usually associated with the highest potential risk from dioxins/furans in a combustion risk assessment, the Subsistence Farmer, will be subjected to a sensitivity analysis to determine which of the multiple default input parameters will have the greatest influence on the potential cancer risk.     

Municipal Solid Waste Management: Institutional And Socio-economic Constraints—experience From The Mediterranean Region

Based on nine case studies of Municipal Solid Waste Management Systems in the Mediterranean region this article attempts to draw some general conclusions on the socio-economic constraints for improved solid waste management. Both policy formation, planning approach, institutional capacity, cost-effectiveness and financing models are assessed. The article points at three general findings: firstly, there is a great need for improving the planning and management capacity at the municipal level; secondly, there is an immense potential for facilitating a more cost-effective municipal solid waste planning and management through improved counselling and technical "back-stopping" from a national or regional body; thirdly, the national legislative framework for municipal solid waste management should specify policy objectives and measures which are operational and introduced in a realistic time schedule.