Vapor-Phase Biofilters Show Promise for Treating High VOC Emissions.


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Evaluating the Feasibility of Natural Attenuation
Using natural attenuation to remediate organic compounds in groundwater has gained popularity. In some cases, this process can reduce contaminant levels to below risk-based corrective action criteria or regulatory standards without implementing additional remedial action alternatives. However, it is often difficult to prove that natural attenuation is capable of reducing contamination to acceptable levels. The article discusses a recently developed protocol that may be useful for determining the feasibility and effectiveness of natural attenuation in remediating ground water contaminated with chlorinated aliphatic hydrocarbons.

First Commercial Explosives-Only Incinerator Begins Operation
The first incinerator accepting only explosive material began commercial operation in March 1995. The incinerator, located in Joplin, Mo., is owned and operated by ICI Explosives Environmental Company. ICI's facility offers incineration as an alternative to open burning/open detonation for eliminating hazardous explosives. Using technology developed by the U.S. Army, the ICI facility is the only commercial incinerator in the United States that regularly accepts DOT hazard Class 1.1 materials. Currently, the facility can effectively treat Class 1.1-1.6 explosives and other reactive wastes. See the article for design parameters and other information on the incinerator.

Speedier Site Characterization Using Cone Penetrometry
New advances in characterization and sampling technologies coupled with cone penetrometry provide improved site characterization and sampling capabilities. The new technologies include a permeable membrane sensor, an optical screening tool, and a site characterization and analysis penetrometer system. These new technologies are discussed in the article.

Surfactants Cost-Effectively Increase Efficiency of DNAPL Pump-and-Treat Systems
Groundwater restoration at contaminated sites is a primary objective of both the RCRA corrective action and Superfund programs. Dense non-aqueous-phase liquids (DNAPLs) are prevalent at sites subject to these programs. Because of their dense nature, DNAPLs cannot be easily remediated by standard pump-and-treat methods. However, specific use of certain surfactants has been shown to increase the efficiency of pump-and-treat systems at DNAPL-contaminated sites. In the article, a study of the technical and economic feasibility of using such surfactants at DNAPL-contaminated sites is given.

Treating High VOC Emissions With Vapor-Phase Biofilters
Since the passage of the Clean Air Act Amendments of 1990, there has been renewed interest in developing biofilters to control large volumes of offgas with relatively low contaminant levels. Recent research indicates that a new vapor-phase biofiltration method is effective at destroying high concentrations of VOCs and does not produce the hazardous by-products associated with other VOC control technologies (e.g., thermal destruction and catalytic oxidation). Performance results of a vapor-phase biofilter in various industrial processes are presented in the article.

Immunoassay Test Kits Are Useful Field Screening Tools
Immunoassay test methods can cost-effectively and rapidly analyze soil and groundwater samples for various contaminants. Consequently, the number of samples that must be sent to a laboratory is significantly reduced, and potential construction delays at a contaminated site due to slow turnaround times for laboratory analysis are minimized. Case studies in which immunoassay tests were used to analyze soil for chlordane, DDT, polycyclic aromatic hydrocarbons, and total petroleum hydrocarbons are discussed.

Technical Impracticability Waivers Provide Relief From Unattainable Remediation Goals
Restoring contaminated groundwater to meet drinking water standards is often required at RCRA corrective action and Superfund sites. However, due to the limited number of available treatment technologies, reaching these goals at some sites may be impractical. For these sites, EPA can grant a 'technical impracticability' waiver allowing the establishment of revised cleanup standards that are attainable and still protective of human health and the environment. The article explains the process of applying for a waiver and discusses a site where technical impracticability was used to justify alternative cleanup levels.

Bioremediation Treatment Technologies
Bioremediation can be an efficient and cost-effective treatment technology for the removal of hazardous waste from contaminated ground water, landfill leachate, soil, and wastewater. Various bioremediation techniques have been developed and have met with varying degrees of success. The article summarizes information on bioremediation technologies that was provided to participants at a recent EPA technology transfer seminar.

Regulatory Issues

Scoping Study Identifies Potential Gaps in Hazardous Waste Characteristics
EPA has conducted a scoping study to determine if the current RCRA hazardous waste characteristics (i.e., ignitability, corrosivity, reactivity, and toxicity) are adequate to protect human health and the environment. According to the November 15, 1996 study, the characteristics are not as protective as they should be in several key areas. For instance, the groundwater models used to calculate the toxicity characteristic (TC) regulatory levels appear to be less conservative than new techniques. In addition, the TC may need to be expanded to reduce risks posed by direct inhalation and the surface-water and indirect pathways. Furthermore, increased protection of ecological receptors may be warranted. Various potential gaps in the ignitability, corrosivity, and reactivity characteristics were identified as well. The study results will be evaluated by EPA to determine if the characteristics need to be expanded, new characteristics need to be created, or further research on these issues needs to be conducted.

Hazardous Waste Management Requirements for Generators
The complexity and costs of complying with the RCRA hazardous waste regulatory requirements depend significantly on the amount of hazardous waste generated. Therefore, we thought it might be useful to summarize the different management requirements for conditionally exempt small quantity generators, small quantity generators, and large quantity generators. For the article, we relied on regulatory text in Parts 261 and 262 and reviewed two recent EPA documents: Understanding the Hazardous Waste Rules--A Handbook for Small Businesses--1996 Update, and Hazardous Waste Requirements for Large Quantity Generators.

Progress of RCRA Subtitle C Tracked
Since 1992, EPA's Office of Solid Waste has been tracking certain indicators to measure the progress of the RCRA hazardous waste program. These indicators are designed to measure the Agency's success in encouraging waste minimization, promoting safe management of hazardous waste, and cleaning up contamination under the corrective action program. A recent report updates the RCRA environmental indicators based mainly on 1989 and 1991 EPA biennial reporting data. Based on its findings, the RCRA Subtitle C program appears to be heading in the right direction. The report is discussed in the article.

Update on Project XL Pilot Program
As part of its response to President Clinton's plan for 'reinventing environmental regulation,' EPA has established a program known as Project XL (which is short for eXcellence and Leadership). The idea behind this program is to allow a facility (or an entire industry) to be regulated under less stringent, more flexible environmental regulations in return for that facility (or industry) committing to produce greater environmental benefits than would have been attained through full compliance with existing regulations. To date, EPA has received more than 50 proposals--13 have been selected for project development and two have been granted final project agreement status and are in the implementation stage.

Superfund Reform Actions
EPA recently announced four Superfund program reforms which are intended to limit litigation and increase community participation. The four reforms include: 1) new guidelines designed to protect small waste contributors (i.e., de micromis parties), 2) a new orphan share compensation policy, 3) the establishment of interest-bearing, site-specific special accounts, and 4) the appointment of a Superfund ombudsman in each of the ten EPA regions. See the article for more information.

Transporting Hazardous Waste Through Canada
Shipments of hazardous waste that travel through Canada must meet Canadian regulatory requirements. The example illustrates the requirements for highway or marine waste shipments that pass through Canadian territory.

RCRA Regulatory Scorecard
EPA has published its semiannual regulatory agenda. An updated 'Scorecard' briefly summarizes the RCRA rules that EPA has 1) announced but not proposed, 2) proposed but not finalized, and 3) finalized or withdrawn. The Scorecard gives the affected parts in the Code of Federal Regulations, the scheduled dates when the Agency anticipates taking action on the rules, and any applicable legal deadlines. We have also included references to articles in The Hazardous Waste Consultant that review past actions on these rules.

Regulatory Compliance Calendar
To aid our readers in the never-ending struggle to remain in compliance with EPA's ever-changing regulations, we are publishing a regulatory compliance calendar. The calendar presents information on RCRA, CERCLA, and EPCRA regulations that become effective in the future. In addition, regulations issued under the Toxic Substances Control Act that deal with PCBs also will be included. For each entry, the calendar provides the effective date, compliance date, applicability information, a summary of the requirement, the Code of Federal Regulations and Federal Register references, and the issue of The Hazardous Waste Consultant in which we analyzed the action.

Legal Issues

CERCLA Can be Applied Retroactively
The liability of responsible parties under CERCLA for actions that occurred prior to enactment of the statute is a hotly contested issue. A May 9, 1996 decision issued by the U.S. District Court for the District of Nevada has found that past court rulings allowing retroactive application of CERCLA liability remain viable despite a recent U.S. Supreme Court ruling concerning statute retroactivity. The litigation involves the liability of Atlantic Richfield Company for allegedly dumping hazardous materials at a Henderson, Nev. site before CERCLA was enacted in 1980. The case, State of Nevada et al. vs. United States et al., is discussed in the article.

Voluntary Soil Cleanup May Be Covered Under CGL Policy
The Washington State Supreme Court has reversed a lower court's denial of insurance coverage under comprehensive general liability (CGL) policies for a voluntary soil cleanup performed by a home heating oil company (Olds-Olympic, Inc. vs. Commercial Union Insurance Company et al.). The lower court jury had found that 'occurrences' at the site did cause groundwater damage but concluded that the company did not have a legal obligation to perform the soil cleanup. Consequently, there was no CGL coverage. The state Supreme Court found that the jury had not been provided enough information on exactly what constitutes a legal obligation to clean up groundwater contamination under Washington law.

Two Key Provisions of NRDA Regulations Invalidated
The U.S. Court of Appeals for the District of Columbia has invalidated two key provisions of the Department of Interior's (DOI's) natural resources damage assessment (NRDA) Type B regulations (Kennecott Utah Copper Corporation vs. U.S. Department of the Interior). The first requirement, concerning the determination of the statue of limitations for assessing natural resource damages, was revoked because the court found that DOI was relying on an unreasonable interpretation of CERCLA. The second provision, which involves the definition of 'services,' was rejected because the language of the rule was inconsistent. As discussed in the article, the appellate court also affirmed a district court's denial of procedural challenges made by various groups regarding DOI's finalization of the Type B regulations.

Appeals Court Affirms Third-Party Defense Against CERCLA Liability
A federal district court's ruling that the current owner of contaminated property is not liable for remediation costs as a potentially responsible party under CERCLA has been upheld by the U.S. Court of Appeals for the Second Circuit (State of New York et al. vs. Lashins Arcade Co. et al.). The court found that the current owner is entitled to a third-party defense because the contamination was the result of actions taken by third-parties that have no contractual relationship with the current owner. In addition, the company had exercised the due care necessary to support a third-party defense.

EPA Fails to Prove Used Foundry Sand Is a Solid Waste
In 1992, NIBCO, Inc. of Nacogdoches, Texas was fined more than $2 million for violations of RCRA and Texas environmental regulations for alleged mismanagement of hazardous waste. The company, however, asserts that the used foundry sand in question is a by-product of its production process and not a solid waste. Recently, an administrative law judge partially granted EPA's request for accelerated decisions on the charges, but the judge noted that the issue of whether the foundry sand is a solid waste could not be decided during a ruling on summary judgment. The Agency was denied its request to strike the affirmative defenses raised by NIBCO, with the exception of the defense that questioned the constitutionality of RCRA. Details of the case, In the matter of NIBCO, Inc., Nacogdoches Division, are covered in the article.

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