Disposal of Waste
The management and disposal of wastes is an enormous public health issue facing our nation. The problem we now face is that the nation's primary waste handling and disposal law, the Resource Conservation and Recovery Act (RCRA), is broken and in need of repair.
The RCRA has spawned needlessly complex regulations. There is little incentive to minimize waste or engage in beneficial reuse or recycling, because even when the material is rendered safe it is still considered a "hazardous waste" subject to all RCRA requirements. Under the present restrictive waste classification scheme, there are many wastes, such as contaminated soils, that are high volume but low in toxicity. Yet under current law these must be disposed of as hazardous wastes. A risk-based approach would bring common sense to the program and ensure safe disposal without handling the material as hazardous waste.
This type of traditional cleanup to original pristine conditions reaches a point of diminishing returns, so that even huge additional outlays of money provide insignificant benefits to public health. Many states recognize this and have adopted a new Risk Based Corrective Action (RBCA) approach for cleanup of leaking underground tanks and other contaminated sites.Where CITGO Stands
The states are now leading the way in innovative cleanup strategies and are forcing incremental reform in advance of a complete federal RCRA rewrite. CITGO has joined several states in supporting a modification to RCRA that would allow the management of wastes outside the hazardous waste regulation. The management of these wastes should be determined based on public health risks and should allow landfill and land treatment disposal options. Savings on disposal costs will occur if the Environmental Protection Agency (EPA) and Congress follow through with current proposals and reform RCRA.
CITGO supports changes to RCRA that encourage the use of risk analysis in waste decision making. CITGO also supports the incorporation of risk analysis into all state and federal cleanup programs. Before any new RCRA legislation is developed, our country would realize the most benefit if the EPA pursued a partnership with all stakeholders and achieved a consensus on how RCRA should be rewritten.