2011Addendum: An Assessment of 

Environmental Problems Associated with Recycling of 

Hazardous Secondary Materials

June 30, 2011

 

U.S. Environmental Protection Agency

Office of Resource Conservation and Recovery



DISCLAIMER

Mention of trade names, products or services in this document does not
convey, and should not be interpreted to convey, official EPA approval,
endorsement, or recommendation, or lack thereof.

ACKNOWLEDGEMENTS

This addendum was funded and managed by the U.S. Environmental
Protection Agency. Data collection and presentation were conducted by
ICF International under contract to the Environmental Protection Agency.

Staff members of the Recycling and Generator Branch, Office of Resource
Conservation and Recovery, EPA Headquarters were responsible for
providing objectives of the addendum, reviewing the methodology, helping
to identify cases for further investigation, reviewing draft write-ups
and drafting portions of the study. The EPA Work Assignment Manager was
Amanda Geldard. 

EPA was responsible for identifying potential cases, including those
submitted through public comment as part of the Definition of Solid
Waste Rulemaking process. Staff of ICF International were responsible
for investigating potential cases, assembling relevant information,
contacting persons with knowledge of selected cases, and drafting
descriptions of each case. 



2011 Addendum: An Assessment of Environmental Problems Associated with

Recycling of Hazardous Secondary Materials

I. Introduction

In January 2007, U.S. Environmental Protection Agency (EPA) published  
HYPERLINK "http://www.regulations.gov/" \l
"!documentDetail;D=EPA-HQ-RCRA-2002-0031-0355"  An Assessment of
Environmental Problems Associated with Recycling of Hazardous Secondary
Materials  (also know as the “environmental problems study” or
“study”).  This study was conducted as part of EPA’s effort to
revise the current “definition of solid waste” under the Resource
Conservation and Recovery Act (RCRA), as it pertains to recycling of
hazardous wastes and other hazardous secondary materials. In particular,
the information in this study was compiled to assist the Agency in
making decisions as to the scope and substance of these regulatory
revisions. Since the study was published in 2007, EPA has continued to
assess new reports of environmental problems associated with the
recycling of hazardous secondary materials. A first   HYPERLINK
"http://www.regulations.gov/" \l
"!documentDetail;D=EPA-HQ-RCRA-2002-0031-0601"  addendum to the study 
was published in July 2008. This 2011 Addendum is EPA’s second update
to the study.  

II. Scope of the Study

The general goal of the study is to identify and characterize cases of
environmental damage that have been attributed to some type of hazardous
material recycling activity, and that are relevant for the purpose of
evaluating the impacts of the DSW rulemaking effort. In this 2011
Addendum, EPA evaluated nine potential damage cases that were identified
after the 2008 DSW final rule was published.

III. Methodology

The nine potential damage cases were collected from news media and from
recent enforcement cases that were forwarded to us by state and EPA
regional staff. For this addendum, we did not conduct a general search
for additional damage cases and instead only evaluated those that have
been brought to our attention since we published the last addendum to
the study in 2008.

EPA used the same methodology to evaluate the nine potential damage
cases as we used for the 2007 environmental problems study and its 2008
addendum. Detailed information regarding EPA’s methodology can be
found in the   HYPERLINK "http://www.regulations.gov/" \l
"!documentDetail;D=EPA-HQ-RCRA-2002-0031-0355"  2007 Environmental
Problems Study . 

IV. Summary 

Of the nine potential damage cases considered, five are determined to be
new recycling damage cases fit to be included in this second addendum to
the study. Additionally, one potential damage case was already included
in the 2007 study and we are providing an update to this damage case in
this Addendum. 

This Addendum includes the following Appendices: 

Appendix I: Additional Damage Cases from Recycling of Hazardous
Secondary Materials This 2011 Addendum adds five new damage case sites
and one update to a damage case included in the 2007 study. These damage
cases were found to meet the scope of the original environmental
problems study. A summary of the additional damage cases and individual
profiles are located in the Addendum’s Appendix I.

Appendix II: Additional Sites Considered But Not Included in the Damage
Case Analysis  

In preparing the 2011 Addendum, EPA identified and reviewed three
additional, potential damage cases, but decided they would not be
included in the environmental problems study because the damage in each
case was determined to be unrelated to recycling of hazardous secondary
materials. The Addendum’s Appendix II contains a summary of sites
considered but not included in the study.

Appendix III: Analysis of Recycling Damage Case Facilities that Are Also
Intermediate Facilities The analysis identified a total of two
intermediate facilities out of seven included in the 2011 addendum. 
Although these facilities are intermediate facilities, both also manage
some waste on site. EPA used the same methodology for determining
intermediate facilities as we did in the   HYPERLINK
"http://www.regulations.gov/" \l
"!documentDetail;D=EPA-HQ-RCRA-2002-0031-0601"  2008 addendum . The 2011
Addendum’s Appendix III includes a table of these intermediate
facilities. 

	 

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