THE HISTORY & PHILOSOPHY OF THE RCRA METHODS PROGRAM

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1 THE HISTORY & PHILOSOPHY OF THE RCRA METHODS PROGRAM An Old Man s Memory & Perspective By David Friedman August 5, 2013

2 Overview of Presentation The Resource Conservation and Recovery Act (RCRA) as it impacts environmental methodology; History of RCRA methods program; History of Test Methods for Evaluating Solid Waste (SW-846); History of the National Environmental Monitoring Conference (NEMC); Viewpoint on lessons learned from 40 years in the business.

3 Resource Conservation & Recovery Act Enacted in 1976 Initiated EPA hazardous waste program Defined solid to include liquids and gases In 1976, most RCRA solids were wastewaters First problem was what is a hazardous waste Methods Program began with defining hazardous waste characteristics

4 Hazardous Waste Characteristics Hazardous waste means a solid waste, or combination of solid wastes, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may (a) cause, or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness; or (b) pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed.

5 Hazardous Waste Characteristics EPA was to develop and promulgate criteria for identifying the characteristics of hazardous waste, and for listing hazardous waste, which should be subject to the provisions of this subchapter, taking into account toxicity, persistence, and degradability in nature, potential for accumulation in tissue, and other related factors such as flammability, corrosiveness, and other hazardous characteristics.

6 Hazardous Waste Characteristics In 1976, we started work to turn the statutory definition into specific sets of waste properties that one could use to determine if a particular waste was regulated. The four characteristics that were eventually adopted were: Ignitability, Corrosivity, Reactivity & Toxicity by reason of toxic chemical leachability

7 Test Methods for the Evaluation of Solid Waste (Sw-846) Characteristics are defined in terms of measurable waste properties. Publishing the properties and thresholds led to the request that EPA tell the regulated community how to measure the properties. For method defined parameters that was obvious. For non method defined parameters that was not so obvious.

8 Test Methods for the Evaluation of Solid Waste (SW-846) As a result of urgings of the regulated community, development of SW-846 began. Purpose was to serve as guidance for chemists on possible analytical approach to consider not as collection of required methods. Required methods for use in method defined parameters were incorporated into regulations.

9 Test Methods for the Evaluation of Solid Waste (SW-846) First edition was developed by group from program, EPA Regional laboratories, and states to prevent running afoul of FACA. Most methods lifted from other EPA programs and adapted to RCRA program needs. First edition took only a few weeks to compile and issue. Organization of methods due to complexity of RCRA materials.

10 Growth of SW-846 The technology innovation community asked that we incorporate their new technologies into SW-846. As long as they demonstrated that the technology worked on real world RCRA samples, we elected to do so since it meant that new technologies could obtain faster acceptance by the environmental community.

11 Growth of SW-846 While initially SW-846 was published in hard copy by GPO, it soon became too costly. Then, we made it available thru the NTIS Finally, EPA had to just publish it on-line. Since 1985, the SW-846 program has been led first by Gail Hansen and currently Kim Kirkland.

12 National Environmental Monitoring Conference (NEMC) Started in 1984 as the Waste Testing and Quality Assurance Symposium (WTQA). Purpose was to serve as a forum for all sectors of our community to get together and share new of upcoming activities and actions, problems that people are encountering, and possible solutions to those problems in a nonregulatory environment. Idea came from Bill Telliard s Norfolk Conference.

13 National Environmental Monitoring Conference (NEMC) Held in Washington to make it easy for EPA officials to participate. Held in middle of summer because no one wants to come to DC in summer and hotels are much cheaper. About 1500 folks came to first conference. For many years, I relied on Gail Hansen to handle most of organizational details.

14 Lessons Learned EPA should never have issued prescriptive or required testing methods. EPA should establish monitoring and data quality requirements and leave it to the monitoring community to select or develop appropriate testing methodology.

15 Lessons Learned It is no secret that for many years I have felt very strongly that EPA should move away from a system of prescribing methods and move to one where EPA establishes monitoring Data Quality Objectives and leave it up to the monitoring community to do whatever is necessary to meet the DQOs. Measuring requirements should never be established without first determining that they can be met using current technology

16 Acknowledgements and Thanks I want to acknowledge the tremendous debt that we owe to a number of key EPA staff without whom the program would not have been successful. These include: Ollie Fordham,Gail Hansen, Todd Kimmell, Kim Kirkland, Barry Lesnik,James Poppiti, Florence Richardson, Charles Sellers, and Shen-yi Yang. To Lara Autry and Jerry Parr for their work in keeping the NEMC alive and for making it so successful.

17 Contact Information David Friedman David Friedman Consulting LLC Rippon Lodge Drive Fairfax, VA