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.     

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.     

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.     

Cleanup levels for dioxin-contaminated soils

EPA's use of a 1 part per billion (ppb) level for dioxin contamination in residential soils is shown to be too high and not protective of public health. It was derived in a 1984 cancer risk assessment by another federal agency, but it is inconsistent with risk-based levels of 2 to 4 parts per trillion (ppt) obtained by using EPA's standard risk assessment methods. EPA has called the 1 ppb level a policy-based level, which correctly distinguishes it from a risk or health-based cleanup standard. The 1984 assessment is shown in this article to have considerable shortcomings. For over a decade, dioxins have been left in soils at levels posing health risks and sometimes at levels that EPA is legally required to address. Moreover, noncancer effects have been ignored, but recent work has shown them to support action at low ppt levels. To protect public health, be consistent with current scientific knowledge and other EPA policies, reduce confusion in the environmental management community, and be responsive to public demands for stringent dioxin cleanups, new EPA policy guidance for dioxin soil cleanups is needed, and key elements are presented in this article. In an ad hoc fashion, EPA Region 4 has recently used a 200 ppt dioxin cleanup level for residential soil, acknowledged to correspond to a one-in-ten-thousand cancer risk, at two Superfund sites, which environmental professionals should be aware of. This suggests a shift in EPA policy.     

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.     

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.     

Case study: Conducting an accelerated cleanup at a superfund site in a mixed residential and industrial area

This article presents a case study of an accelerated cleanup conducted by EPA at the Adams Plating Company (APC) Superfund site near Lansing, Michigan. The APC site remediation was a Superfund EPA-lead project under the remedial program in Region 5. An accelerated cleanup was possible at the APC site by consistently identifying, evaluating, and implementing opportunities to streamline the remedial investigation (RI) and remedial design (RD) process. Streamlining opportunities were discovered and implemented in both the technical and administrative aspects of the project. Streamlining components used to accelerate the remedial process included: (1) extensive use of field screening techniques during the Phase II RI; (2) a focused feasibility study (FS) that evaluated only practical alternatives; (3) maintaining project momentum by initiating the RD concurrent with the issuance of the Record of Decision (ROD); (4) a highly accelerated RD with limited predesign work; (5) elimination of the transition period between RD and remedial action (RA) project phases; (6) frequent and effective communication, coordination, and cooperation between all parties involved (EPA, Michigan Department of Natural Resources (MDNR), technical contractor, PRC Environmental Management, Inc. (PRC), and the public); (7) maintaining a consistent project team throughout project duration; and (8) the setting of aggressive project goals.     

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.     

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.     

Simultaneous determination of volatile and semivolatile organic compounds in soil

A microscale solvent extraction (MSE) method was developed for the simultaneous determination of volatile organic compounds (VOCs) and semivolatile organic compounds (SVOCs) in soil. Tests of precision, recovery, and comparability to other Environmental Protection Agency (EPA) methods have been completed, and the MSE method compares well to Soxhlet and sonication extraction. Based on these validation data, EPA has assigned number 3570 to this method. Method 3570 has several advantages, including reduced use of solvent and soil sample, generating much less laboratory waste. Laboratory space and labor requirements are reduced as compared to many other sample preparation methods. Consequently, Method 3570 can provide comparable chemical data at less cost or environmental impact.     

Look at groundwater quality to set VOC cleanup levels

In 1981, the Arizona Department of Health Services (ADHS) discovered groundwater contamination by solvents and chromium at the Phoenix Goodyear Airport (PGA), just outside the city of Phoenix. ADHS and the U.S. EPA sampled the site for the next two years, finding that eighteen of their wells were contaminated with trichloroethene (TCE), six exceeding ADHS's action level of five micrograms per liter (μg/l). In 1983, the PGA site was added to the National Priorities List, and, in 1984, EPA began a $3 million remedial investigation, focusing on soils and groundwater. This article discusses how that investigation inspired the authors to develop a stream-lined evaluation method for PGA's volatile organic compounds (VOCs), the process for establishing VOC cleanup levels, and the $26 million of remediation work needed to be done at the site. The heart of this effort is a computer program called VLEACH, loosely standing for VOC-LEACHing, which anticipates the influence of VOCs on PGA's groundwater, even as remediation proceeds.     

Modeling natural attenuation of petroleum hydrocarbon contamination using alternate electron acceptors: Case study comparing bioplume iii with BIOSCREEN

Natural attenuation holds great promise as a cost‐effective means of remedying groundwater contamination at petroleum spill sites: this is particularly true at sites with sufficient background concentrations of alternate electron acceptors (nitrate and/or sulfate). The study reported in this article compared the results of a new Environmental Protection Agency (EPA) numerical model (BIOPLUME III) with an updated EPA analytical model (BIOSCREEN Version 1.4) used to predict natural attenuation at an underground fuel spill site in Oklahoma. High background sulfate concentrations were shown to result in unrealistic predictions from both BIOSCREEN and BIOPLUME III. BIOSCREEN could be easily used with a data set not significantly enlarged from that used in a routine leaking fuel tank investigation. BIOPLUME III was much more difficult to use and did not yield reliable results. Results of this study indicate that the additional complexity of the BIOPLUME III model is not justified for simple sites.     

Effects of cosolvency in the fate and transport of PCBs in soil

Under the purview of EPA's Remedial Engineering Management (REM III) Superfund contract, a CERCLA RI/FS was performed at the Pinettes Salvage Yard site located in Washburn, Maine (EPA Region I). The purpose of the RI/FS was to fully characterize the nature, extent, and fate and transport of PCB contamination resulting from an alleged surface spill of transformer dielectric fluid containing Arochlor 1260 (a polychlorinated biphenyl) and various volatile and semivolatile organic constituents. The RI/FS was performed subsequent to both an immediate removal action (IRA) and a deletion remedial investigation (DRI) performed by EPA contractors. Results of both efforts indicated that the site was unsuitable for deletion from the National Priorities List (NPL) because the site soils contained elevated levels of PCBs. This article presents a case history of the extensive field investigations performed to characterize the contaminant source and evaluate the fate and transport of PCBs in site soils. These investigations included on-site mobile laboratory gas chromatograph (GC) analytical techniques for PCBs and targeted volatile and semivolatile organic compounds; confirmatory Contact Laboratory Program (CLP) laboratory analyses of soils, sediments, surface water, and groundwater samples; statistical analyses and correlation of field mobile laboratory GC data with CLP laboratory analytical results; and an evaluation of the potential effects of cosolvency in the fate and transport of PCBs in subsurface soils.     

Use of open-path FTIR spectroscopy to address air monitoring needs during site remediations

Although open-path Fourier-transform infrared (FTIR) spectroscopy has been an Environmental Protection Agency (EPA) Toxic Organic Compendium Method since 1996, it has been underutilized as a means to assess exposure to gaseous contaminants during the remediation of hazardous waste sites. This might be considered surprising in light of the many benefits that proper application of this technology can offer. In this article, we provide an overview of the technology and the principle of operation, describe the nature of the data generated, discuss the benefits associated with the technology's use in site clean-up, present emission-rate estimation techniques, and examine the reasons why it has not gained more support over the years. Finally, we present a case study in which the technology was used to drive an 11-month emergency removal action under the direction of the U.S. Environmental Protection Agency.     

Solidification/stabilization for remediation of wood preserving sites: Treatment for dioxins,PCP, creosote,and metals

This article discusses the use of solidification/stabilization (S/S) to treat soils contaminated with organic and inorganic chemicals at wood preserving sites. Solidification is defined for this article as making a material into a freestanding solid. Stabilization is defined as making the contaminants of concern nonmobile as determined from a leaching test. S/S then combines both properties. For more information on S/S in general the reader should refer to other publications (Connors, J.R. [1990]). Chemical fixation and solidification of hazardous wastes. New York: Van Nostrand Reinhold; US Environmental Protection Agency. [1993a]. Engineering bulletin solidification/stabilization of organics and inorganics (EPA/540/S‐92/015); Wiles, C.C. [1989]. Solidification and stabilization technology. In H.M. Freeman [Ed.], Standard handbook of hazardous waste treatment and disposal. New York: McGraw Hill) as this article addresses only wood preserving sites and assumes basic knowledge of S/S processes. For a more general discussion of wood preserving sites and some other remedial options, the reader may wish to refer to a previous EPA publication (US Environmental Protection Agency. [1992a]. Contaminants and remedial options at wood preserving sites [EPA/600/R‐92/182]). This article includes data from the successful remediation of a site with mixed organic/inorganic contaminants, remediation of a site with organic contaminants, and detailed treatability study results from four sites for which successful formulations were developed. Included are pre‐ and post‐treatment soil characterization data, site vaines. ileizdot‐ names (in some cases), treatment formulas used (generic aridproprietary), costs, recommendations, and citatioiis to inore detailed refer‐ en ces. The data presen ted iiidica te that dioxins, pentachlorophepi 01 (PCP), creosote, polycyclic aromatic hydrocarbom (PAHsI, and metals can be treated at moderate cost by the use of S/S techuologp.     

Activity and Use Limitations applied to Risk‐Based Corrective Action—A checklist for efficacy

Activity and Use Limitations (AULs) comprise both institutional controls and engineering controls. AULs, when properly implemented, are valuable tools in the risk‐based corrective action arsenal. However, the proponent of AULs must evaluate their life‐cycle costs and the short‐term and long‐term effectiveness of the AULs to protect human health and the environment. This article describes the various types of AULS and provides a checklist for evaluating the efficacy of the proposed AULs. © 2002 Wiley Periodicals, Inc.     

Development of a site‐specific cleanup goal for PAHs in soil based on anthropogenic background levels

During removal of an industrial landfill in Folsom, California, fill material was excavated and processed through a mechanical screening plant to segregate soil from construction and demolition debris. The segregated soil was stockpiled and analyzed for a wide range of chemical groups to determine if the soil could be backfilled on‐site. The analytical results indicated many of the stockpiles had concentrations of polycyclic aromatic hydrocarbons (PAHs) that exceeded US EPA Regional Screening Levels, and a large quantity of soil was initially classified as requiring off‐site disposal at considerable cost. Because PAHs are ubiquitous in urban settings and the landfill did not contain a significant source of PAHs, development of a site‐specific PAH cleanup goal was proposed to regulators. Cal/EPA guidance for using on‐site data to develop a background threshold for metals was applied to the development of the PAH cleanup goal. The Cal/EPA approach involves demonstrating whether the data belong to a single population or multiple populations based on data distribution tests and probability plots. This article explains the statistical and graphical methods that were used to demonstrate that the Cal/EPA approach was valid for PAHs and that the calculated cleanup level was consistent with published anthropogenic background levels of PAHs in California and across the United States. The site‐specific PAH cleanup goal enabled most of the soil to be backfilled on‐site, saving about $227,000 in transportation and disposal costs, and regulators subsequently approved unrestricted future use of the property. © 2010 Wiley Periodicals, Inc.     

Recycling rates of waste home appliances in Taiwan

The objective of this study is to provide a calculation of recycling rates of waste home appliances in Taiwan, for the EPA to amend these rates in order to increase the recycling efficiency. The recycling rate is calculated by a formula according to the statistical results obtained through: (1) an estimation of domestic use of home appliances using time series analysis with multiplicative seasonal ARIMA model, (2) a further estimation of generated waste home appliances based upon the estimated domestic use and the corresponding distribution of lifetime span, and (3) a cost analysis of recycling home appliances based on a sampling survey with stratified systematic sampling conducted among collectors and a survey on five recycling plants of waste home appliances. The suggested recycling rates in this study finally used by the EPA show that all of the recycling rates have increased compared with the rates in previous years. This study also implies that amending the recycling rates may only solve some recycling problems temporarily; however, the recycling system of waste home appliances in Taiwan has to be reformed to increase the recycling efficiency for the long term.