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.     

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.     

The decatur county landfill: One community turns over a clean sheet of paper

The Decatur County Landfill, a privately owned sanitary landfill, was shut down by Indiana officials in 1991. When the owner proved not to have the financial ability to close the site as required by law, state environmental officials turned to local businesses to remediate the landfill. In a pioneering effort at voluntary action, officials of the state, county, and city government worked in partnership with business and the local community to perform and fund closure and provide the postclosure care. This study illustrates the results that can be achieved when government and private parties work together.     

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.     

Extricating Membership as a PRP at Hazardous Waste Disposal Sites

Corporations often become potentially responsible parties (PRPs) at hazardous waste sites because of their past transportation or disposal of hazardous substances at such sites. Determining a PRP's potential liability for the assessment and cleanup of hazardous waste sites is a challenging effort and often results in disputes among other PRPs regarding appropriate allocation of response action costs to each party. Further, public companies have an obligation to report probable and reasonably estimable costs under Generally Accepted Accounting Principles (GAAP) for environmental liabilities at their current or prior hazardous waste sites. The first step in such an evaluation is to determine whether or not a PRP can extricate themselves from any association with the subject site or, alternatively, demonstrate de minimis status. This article describes the methods by which PRPs can extricate themselves from liability associated with response action costs at contaminated sites, including: evaluating a PRP's prior settlements or indemnifications with other PRPs; identifying insurance coverage or other financial assurance instruments for the disposal facility; and examining applicable statutes of limitations against when a PRP received notification from the regulatory agency. The article also presents a case study discussing how a PRP with a portfolio of 72 hazardous waste disposal sites was able to extricate itself from the majority of these sites, resulting in only four sites where the PRP was determined to be a PRP and where an associated allocable share was assigned. © 2014 Wiley Periodicals, Inc.     

Landfill reduction experience in The Netherlands

Modern waste legislation aims at resource efficiency and landfill reduction. This paper analyses more than 20 years of landfill reduction in the Netherlands. The combination of landfill regulations, landfill tax and landfill bans resulted in the desired landfill reduction, but also had negative effects. A fierce competition developed over the remaining waste to be landfilled. In 2013 the Dutch landfill industry generated €40 million of annual revenue, had €58 million annual costs and therefore incurred an annual loss of €18 million. It is not an attractive option to prematurely end business. There is a risk that Dutch landfill operators will not be able to fulfil the financial obligations for closure and aftercare. Contrary to the polluter pays principle the burden may end up with society. EU regulations prohibiting export of waste for disposal are in place. Strong differentials in landfill tax rate between nations have nevertheless resulted in transboundary shipment of waste and in non-compliance with the self-sufficiency and proximity principles. During the transformation from a disposal society to a recycling society, it is important to carefully plan required capacity and to guide the reorganisation of the landfill sector. At some point, it is no longer profitable to provide landfill services. It may be necessary for public organisations or the state to take responsibility for the continued operation of a ‘safety net’ in waste management. Regulations have created a financial incentive to pass on the burden of monitoring and controlling the impact of waste to future generations. To prevent this, it is necessary to revise regulations on aftercare and create incentives to actively stabilise landfills.     

Cost estimating of the closure/post-closure phase

The U.S. Department of Energy (DOE) is beginning major environmental restoration projects of both active and inactive sites throughout the United States. The problems at the sites include contaminated soils, groundwater and surface waters, structures, and old waste disposal areas. IT Corporation, under the direction of the Office of Independent Cost Estimating (OICE) for DOE, developed a list of environmental problems at the sites and probable cleanup technologies and techniques that could be used. Estimated unit costs were then developed for these cleanup technologies, using available data and references. Some procedures developed were common to many or all cleanup projects. These included site characterization, remedial investigation (RI), feasibility studies (FS), and the closure/post-closure phase. The article will focus on cost estimating of the closure/post-closure phase of a cleanup project. The cost data provided are for budget level or check estimates. Site-specific conditions as well as items peculiar to the environmental industry, such as governmental regulations and community relations, can influence both the cost and duration of a cleanup project.     

Costs of food waste along the value chain: Evidence from South Africa

In a previous paper (Nahman et al., 2012), the authors estimated the costs of household food waste in South Africa, based on the market value of the wasted food (edible portion only), as well as the costs of disposal to landfill. In this paper, we extend the analysis by assessing the costs of edible food waste throughout the entire food value chain, from agricultural production through to consumption at the household level. First, food waste at each stage of the value chain was quantified in physical units (tonnes) for various food commodity groups. Then, weighted average representative prices (per tonne) were estimated for each commodity group at each stage of the value chain. Finally, prices were multiplied by quantities, and the resulting values were aggregated across the value chain for all commodity groups. In this way, the total cost of food waste across the food value chain in South Africa was estimated at R61.5 billion per annum (approximately US$7.7 billion); equivalent to 2.1% of South Africa’s annual gross domestic product. The bulk of this cost arises from the processing and distribution stages of the fruit and vegetable value chain, as well as the agricultural production and distribution stages of the meat value chain. These results therefore provide an indication of where interventions aimed at reducing food waste should be targeted.     

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.     

Potential use of feebate systems to foster environmentally sound urban waste management

Waste treatment facilities are often shared among different municipalities as a means of managing wastes more efficiently. Usually, management costs are assigned to each municipality depending on the size of the population or total amount of waste produced, regardless of important environmental aspects such as per capita waste generation or achievements in composting or recycling. This paper presents a feebate (fee+rebate) system aimed to foster urban waste reduction and recovery. The proposal suggests that municipalities achieving better results in their waste management performance (from an ecological viewpoint) be recompensated with a rebate obtained from a fee charged to those municipalities that are less environmentally sound. This is a dynamic and flexible instrument that would positively encourage municipalities to reduce waste whilst increasing the recycling.     

Environmental impacts and costs of solid waste: a comparison of landfill and incineration

The methodology for evaluating the impacts and damage costs ('external costs') due to pollution from waste treatment is described and the results are presented, based on the ExternE project series of the European Commission. The damage costs of landfill and incineration of municipal solid waste are compared, with due account for energy and materials recovery, as well as possible differences in transport distance. We have not been able to quantify the total damage costs of leachates because of the complexity of the environmental pathways and of the long time horizon of some persistent pollutants, but we consider an extreme scenario to show that they are not worth worrying about in the sense that reducing the pollutants in leachates beyond current regulations would bring negligible benefit in comparison with the abatement of other sources of the same pollutants. The damage costs due to the construction of the waste treatment facility are negligible. The damage costs of waste transport, which are illustrated by an arbitrary choice of a 100 km round trip by a 16 tonne truck, are also negligible. The benefits of materials recovery make a small contribution to the total damage cost. The only significant contributions come from direct emissions (of the landfill or incinerator) and from avoided emissions due to energy recovery (from an incinerator). Damage costs for incineration range from about 4 to 21 EUR tonne waste(-1), and they are extremely dependent on the assumed scenario for energy recovery. For landfill the cost ranges from about 10 to 13 EUR tonne waste(-1); it is dominated by greenhouse gas emissions because only a fraction of the CH4 can be captured (here assumed to be 70%). Amenity costs (odour, visual impact, noise) are highly site-specific and we only cite results from a literature survey which indicates that such costs could make a significant contribution, very roughly on the order of 1 EUR tonne waste(-1).     

Phytoremediation of industrial sludge using vegetation‐assisted dewatering

With the emergence of risk‐based corrective action decisions, there is interest in the use of more natural techniques that may be as protective as the traditional removal, landfill, or capping approaches for impoundment closure. The use of phytoremediation is one of the more promising techniques. This article presents the results of a three‐year field‐pilot phytoremediation study that involved the use of plants to enhance sludge dewatering at an inactive natural gas‐cracking wastewater lagoon. The dewatering was accompanied by contaminant reduction of benzene, toluene, xylene (BTX), and naphthalene concentrations to below the cleanup goals. Meanwhile, the concentration reductions of three or more ring polynuclear aromatic hydrocarbons (PAHs) varied between 30 percent and 60 percent, except for dibenz[a,h]anthracene. The residual PAHs in the sludge are not leaching. Parallel laboratory studies suggest a reduced PAH availability and mobility in the unsaturated zone sludge. © 2002 Wiley Periodicals, Inc.     

The costs of household food waste in South Africa

Food waste is problematic for a number of reasons, including the loss of a potentially valuable food source or resource for use in other processes (e.g. energy generation or composting), wasted resources and emissions in the food supply chain, and problems associated with the disposal of organic waste to landfill. This paper quantifies the household food waste stream in South Africa, in order to draw attention to the magnitude of the problem. In addition, it estimates the economic (monetary) value of the wasted food, as well as the costs associated with disposing putrescible food waste to landfill, in order to highlight the associated costs to society. Costs associated with the loss of a potentially valuable food source are valued using a weighted average market price of the wasted food. Costs associated with the disposal of food waste to landfill are quantified based on estimates of the financial and external costs associated with landfilling. For household food waste alone, the costs to society associated with these two food-waste related problems are estimated at approximately R21.7 billion (approximately US$2.7 billion) per annum, or 0.82% of South Africa’s annual GDP. These costs are therefore significant, particularly considering that household food waste accounts for less than 4% of total food losses across the food supply chain.     

Environmental performance review and cost analysis of MSW landfilling by baling-wrapping technology versus conventional system

This paper first reviews the chemical, physical and biological processes, and the environmental performance of MSW compacted and plastic-wrapped into air-tight bales with low-density polyethylene (LDPE). The baling-wrapping process halts the short and half-term biological activity and consequently the emission of gases and leachates. It also facilitates the handling of the refuse, and considerably reduces the main environmental impacts of a landfill. The main technologies available for baling-wrapping MSW are also presented. Furthermore, a cost analysis comparing a conventional landfill (CL) without baling system versus two landfills using different baling-wrapping technologies (rectangular and cylindrical bales) is carried out. The results are presented comparatively under the conditions of construction, operation and maintenance and postclosure, as required by European Directive 1999/31. A landfill using rectangular plastic-wrapped bales (LRPB) represents an economically competitive option compared to a CL. The increased capacity of the waste disposal zone when using rectangular bales due to the high density of the bales compensates for the increased operating and maintenance (O&M) costs of the method. Landfills using cylindrical plastic-wrapped bales (LCPB's) do not fare so well, mainly because the density within the bales is lower, the cylindrical geometry of the bales does not allow such an efficient use of the space within the landfill, and the processing capacity of the machinery is lower. From the cost model, the resulting unit costs per tonne in a LRPB, a LCPB and a CL for 100,000 t/year of waste, an operation time of 15 years and a landfill depth (H) of 20 m, are 31.52, 43.36 and 31.83 /t, respectively.     

Re-thinking incentives and penalties: Economic aspects of waste management in Italy

This paper focuses on the dynamics the formation of operational costs of waste management in Italy and the effect of economic measures. Currently incentives and penalties have been internalized by the system no differently from other cost items and revenues. This has greatly influenced the system directing it towards solutions that are often distant from the real environmental objectives. Based on an analysis of disaggregated costs of collection treatment and recovery, we provide the basic elements to compose a picture of economic management in various technical–organizational scenarios.In the light of the considerations contained in the paper it is proposed, e.g. for controlled landfills, that the ecotax, currently based on weight, could be replaced by one based on the volume consumption. Likewise, for tax reduction on disposal system, instead a pre-treatment might ask an environmental balance of the overall system.The article presents a reflection on the last hidden costs associated with the consumption of goods and packaging, and how to reduce waste production is the necessary path to be followed in ecological and economic perspectives.     

Investigation of health care waste management in Binzhou District,China

In China, national regulations and standards for health care waste management were implemented in 2003. To investigate the current status of health care waste management at different levels of health care facilities (HCF) after the implementation of these regulations, one tertiary hospital, one secondary hospital, and four primary health care centers from Binzhou District were visited and 145 medical staff members and 24 cleaning personnel were interviewed.Generated medical waste totaled 1.22, 0.77, and 1.17 kg/bed/day in tertiary, secondary, and primary HCF, respectively. The amount of medical waste generated in primary health care centers was much higher than that in secondary hospitals, which may be attributed to general waste being mixed with medical waste. This study found that the level of the HCF, responsibility for medical waste management in departments and wards, educational background and training experience can be factors that determine medical staff members’ knowledge of health care waste management policy. Regular training programs and sufficient provision of protective measures are urgently needed to improve occupational safety for cleaning personnel. Financing and administrative monitoring by local authorities is needed to improve handling practices and the implementation of off-site centralized disposal in primary health care centers.     

Work safety in waste treatment

Accident risks in waste treatment were studied at five sanitary landfills, two plants using mainly manual sorting and one incineration plant in southern Finland. Work hazards were detected by means of safety analysis. In addition, accident statistics were used. Work safety problems were found at all work stages. At the sanitary landfills, the major safety problems were posed by operation of the compactor or other machinery and by hazardous wastes. In waste sorting, common problems are odour and dust, lacerations and back injuries. Falling into the waste compactor or paper silos may cause fatal injury and its probability was also high. The highest noise level measured was 97 dB(A). In waste incineration, the most serious hazards were caused by fires, clogging of the funnels and cleaning of the grate. Most deficiencies in work safety can be remedied at a moderate price. The corrective measures involve technical solutions, working methods, supervision, training and occupational health services. The accident rates for workers in the four waste treatment plants were slightly lower than the average for industry.     

Solid health care waste management status at health care centers in the West Bank – Palestinian Territory

Health care waste is considered a major public health hazard. The objective of this study was to assess health care waste management (HCWM) practices currently employed at health care centers (HCCs) in the West Bank – Palestinian Territory. Survey data on solid health care waste (SHCW) were analyzed for generated quantities, collection, separation, treatment, transportation, and final disposal. Estimated 4720.7 m³ (288.1 tons) of SHCW are generated monthly by the HCCs in the West Bank. This study concluded that: (i) current HCWM practices do not meet HCWM standards recommended by the World Health Organization (WHO) or adapted by developed countries, and (ii) immediate attention should be directed towards improvement of HCWM facilities and development of effective legislation. To improve the HCWM in the West Bank, a national policy should be implemented, comprising a comprehensive plan of action and providing environmentally sound and reliable technological measures.