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.     

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.     

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.     

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.     

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.     

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.     

RCRA leapfrog: How statistics shape and in turn are shaped by regulatory mandates

During the past ten years, a statistical program applicable to RCRA groundwater monitoring data has been developed with input from regulators, geologists, regulated individuals, and a small group of professional statisticians. At first driven by the RCRA regulations, the evolution of the statistical program now often influences changes in regulatory requirements, which in turn affect opinions on the best statistical approach for addressing the requirements. This article describes that evolution and the issues that have emerged over the years. In the following article, Dr. Robert Gibbons, another of the professional statisticians involved in the debate, responds to comments made in this article.     

Estimating waste transfer station delays using GPS

This paper examines the use of on-board global positioning system (GPS) data recorders as a method to collect field data on the movements of solid waste collection vehicles at transfer stations. The movements of five waste collection vehicles using four different transfer facilities were compared over a period of 1 year. The spatial data were analyzed using geofences to determine the amount of time each truck spent on each of four activities: queuing for access to the weigh scale, sitting on the weigh scale, queuing for access to the tipping floor, and unloading waste. The study found that queuing delays can be identified and measured using GPS data. The average time at a facility for all trucks was 16.4min per visit, with a standard deviation of 14.3min. Time at the facility ranged between 2 and 111min per visit and the distribution of time at the facility was positively skewed. Multi-compartment vehicles (co-collection and recycling trucks) spent significantly more time at unloading facilities. There were also significant differences in the length and the location of the queues at different facilities. At one facility, the longest delays were encountered while waiting for the weigh scale, at two facilities trucks experienced delays in obtaining access to the tipping floor, while at the fourth facility no significant delays developed.     

Underwater treatment of lead-contaminated sediment

The sediment associated with the reconstruction of a bridge pier was classifiable as hazardous by the Toxicity Characteristic Leaching Procedure (TCLP), due to elevated concentrations of lead. However, RCRA regulations do not classify the sediment as hazardous unless it is moved. RMT designed an in-situ, underwater treatment process to render the sediment nonhazardous, using phosphate-based chemistry before dredging. Subsequent sediment management was conducted without the additional regulatory requirements and costs associated with managing hazardous waste.     

A Systematic Approach to the Evaluation of RCRA Disposal Facilities Under Future Climate‐Induced Events

The ability of near‐surface disposal facility cover designs to meet percolation performance criteria can be influenced by naturally occurring climatic mechanisms as well as anthropogenic forcing. This study was conducted to determine the effect of climate‐induced events on percolation based, probabilistic distributions derived from historical climate data. Water balance predictions were evaluated using the HELP model, employing several variations of degradation in a traditional RCRA disposal facility cover design over a 100‐year simulation period. Results demonstrated that changes in precipitation and temperature can influence performance. The analysis also revealed that when both precipitation and temperature are increased, warmer temperatures tend to offset some of the impact from greater precipitation. ©2015 Wiley Periodicals, Inc.     

Energy recovery and greenhouse gas reduction potential from food waste in Japan

Waste-to-energy is one effective waste management approach for a sustainable society. The purpose of this study was to clarify the potential for energy recovery and greenhouse gas (GHG) reduction that could be achieved by introducing anaerobic digestion (AD) facilities in the process of reconstructing aging incineration facilities in Japan. Using statistical data from 1068 incineration facilities, four future scenarios were considered and compared with the current situation. As results, compared with the current situation the amount of electricity generated could increase by 60 % in 2030, by combining AD facilities for food waste with new, high-efficiency incineration facilities for remaining municipal solid waste (MSW). From a life cycle perspective, net energy recovery in 2030 was approximately three times greater than in 2011, and GHG emission could be reduced by 27 %. The introduction of AD facilities is attractive for small authorities, which currently treat <100 t/day of MSW through incineration facilities without energy recovery. An AD facility is also beneficial for large authorities. On the contrary, in middle-scale authorities that treat 100–299 t/day of MSW, the reconstruction of incineration facilities to include electricity production capabilities requires careful consideration, because it will significantly influence energy recovery and GHG reduction effects.     

Monitoring parameters and statistics: A land treatment unit monitoring case study

Statistical evaluation procedures for monitoring data at facilities permitted under the Resource Conservation and Recovery Act (RCRA) are frequently established before monitoring begins. Selecting the statistical method before background data have been collected often leads to the use of statistical procedures that are inappropriate for the actual monitoring data. Such was the case for unsaturated zone monitoring at a permitted land treatment unit in the Gulf Coast area of Texas. Due to the large number of “not detected” results in the background database for lysimeters, statistical evaluation procedures specified in the original RCRA permit yielded an artificially low standard deviation, resulting in background values that were strongly biased on the low side. An alternate statistical procedure based on probability plots was developed and was accepted by the state environmental regulatory agency. This technique, which has wide applicability for many types of environmental monitoring data, significantly reduced the chasing of false positives, thus saving potentially expensive investigations and remediations.     

Industrial storm water pollution prevention: Effectiveness and limitations of source controls in the transportation industry

Industrial activities that are sources of pollutants in storm water runoff at typical facilities of the transportation industry are identified by site investigations at five facilities. This research then evaluates pollution prevention measures implemented to reduce those pollutants, as required by storm water regulations under the U.S. Clean Water Act. Activities that potentially generate storm water pollutants, particular to facilities of this industry, include: vehicle maintenance; vehicle fueling; vehicle washing; and activities on paved access roads and vehicle storage areas. Activities common to this industry, but also found in other industries, include: storage and handling of process materials and wastes; operation of industrial equipment located outdoors or exposed to storm water; and design and operation of site drainage facilities. Most control measures cited in the compliance documents of the facilities in the case studies were not developed specifically for storm water pollution prevention, but serve to reduce storm water pollutants as part of compliance with regulations for hazardous waste, wastewater, worker safety, or other purposes. Most identified control measures were operational practices or employee procedures, rather than structural facility modifications or devices to remove pollutants. Implementation of such measures is difficult to enforce or verify by regulatory agencies, and evidence at the case study facilities suggests that measures described similarly at different facilities are unevenly implemented and unequally effective at controlling storm water pollutants.     

Control of volatile organic compound emissions at a landfill site in New York: A community perspective

This paper presents a case study of a Long Island. New York, landfill where methane and VOC gases were migrating off-site. The municipally owned and operated Port Washington Landfill located adjacent to residential housing was opened in 1974 and was placed on the U.S. EPA Superfund (rehabilitation) list in 1982 because of odour complaints. Community concerns have focused on combustible gases, odour control, and exposure to trace contaminants. A comprehensive data base and corrective action program was initiated to determine: (1) the extent of off-site volatile organic compounds (VOC) migration; (2) measures to control migration and emissions; and (3) impacts on VOC concentrations under residential areas. Full data reports and monthly interpretations have been provided to the citizenry. Results to date indicate that start-up and operation of the extraction system have significantly reduced off-site VOC concentrations.     

Behavior of PAHs from sewage sludge incinerators in Korea

Although production of sewage sludge increases every year, its proper treatment has only been recently raised as a new issue, as current landfill and ocean dumping arrangements are expected to become increasingly difficult to manage in the future. The Korean Ministry of Environment plans to diversify its processing facilities and expand its processing systems by 2011, with the purpose of processing all sludge produced in Korea. According to this plan, incineration (including incineration of municipal wastes) will process 30% of the entire sewage sludge throughout the country in 2011. This study reviews the characteristics of PAH, which is one of the organic substances found in sewage sludge during the incinerating process. The total amount of PAH produced from sewage sludge incineration was found to be 6.103 mg/kg on average, and investigation performed on 16 PAHs of inlets and outlets of the air control devices at five full-scale incineration facilities showed that concentrations of the PAHs on the inlet and on the outlet ranged from 3.926 to 925.748 microg/m(3) and from 1.153 to 189.449 microg/m(3), respectively. In the case of the incineration facility fed with municipal waste (95%) and sewage sludge (5%), the total of the PAH emissions concentration was higher than that found at the incineration facilities used exclusively to treat sewage. The combustion of waste vinyl and plastics contained in municipal waste fed into the facility might contribute to the high levels of PAHs in the stack gas. However more investigation is needed on the production mechanism of PAHs at different operating conditions of the incineration facilities, such as the types of waste, and other relevant factors.     

A knowledge acquisition process to analyse operational problems in solid waste management facilities.

The available expertise on managing and operating solid waste management (SWM) facilities varies among countries and among types of facilities. Few experts are willing to record their experience, while few researchers systematically investigate the chains of events that could trigger operational failures in a facility; expertise acquisition and dissemination, in SWM, is neither popular nor easy, despite the great need for it. This paper presents a knowledge acquisition process aimed at capturing, codifying and expanding reliable expertise and propagating it to non-experts. The knowledge engineer (KE), the person performing the acquisition, must identify the events (or causes) that could trigger a failure, determine whether a specific event could trigger more than one failure, and establish how various events are related among themselves and how they are linked to specific operational problems. The proposed process, which utilizes logic diagrams (fault trees) widely used in system safety and reliability analyses, was used for the analysis of 24 common landfill operational problems. The acquired knowledge led to the development of a web-based expert system (Landfill Operation Management Advisor, http://loma.civil.duth.gr), which estimates the occurrence possibility of operational problems, provides advice and suggests solutions.     

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.     

Solid waste facilities location using of analytical network process and data envelopment analysis approaches

Selection of the appropriate site for solid waste facilities is a complex problem and requires an extensive evaluation process, because it is very difficult to develop a selection criterion that can precisely describe the preference of one location over another. Therefore selection of these sites can be viewed as a multiple criteria decision-making or multiple attributes decision-making problem. For this purpose, we propose a technique that can effectively take managerial preferences and subjective data into consideration, along with quantitative factors. The tool proposed here relies on the use of the analytical network process (ANP) and to help integrate managerial evaluations into a more quantitatively based decision tool, data envelopment analysis (DEA) is applied. In this paper, a location selection procedure is presented to construct an undesirable facility applying ANP and DEA approaches in two stages. In the first stage ANP approach is used, results of this stage are inputs for the second stage. In this stage, DEA is applied to select the best location. Finally, to illustrate the proposed framework, at "Results and discussion" section, a total of four undesirable facility locations are evaluated.     

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.