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Treatment and Disposal Services
Ensuring Long Term Liability Protection
The treatment facility that we access was designed and constructed to meet the stringent standards of the Resource
Conservation and Recovery Act (RCRA). The RCRA requirements for construction, operating and monitoring facilities like this one were created by Congress to specifically address concerns about long-term
protection.
Requirements for redundant protective systems in cell design, for treatment of wastes prior to disposal and for monitoring and financial assurance programs were put in place to form overlapping and complimentary levels of protection. In fact, the sole purpose of an RCRA permitted treatment and disposal facility is to maximize long term protection of the environment and surrounding communities. As a result, RCRA facilities are specifically and exclusively designed and operated for this purpose. When it comes to long-term liability protection, there is no comparison.
Ensuring long-term liability protection requires two parts.
The first is to design and construct a facility which provides multiple and redundant levels of protection. The second part of the equation is to operate the facility in such a way as to prevent the creation of future liabilities, including a commitment to constantly identify potential regulatory or environmental concerns and immediately resolve them. This facility has operated in compliance with these regulatory requirements since the inception of the RCRA program.
Siting Requirements: This facility
underwent seven years of permitting, public and regulatory hearings and exhaustive scientific reviews to obtain a final permit. This review confirmed the exceptional nature of the facility's geologic
characteristics, which include up to 100 feet of high density, low permeability clay deposits. In fact, these clay deposits have permeability factors that are equivalent to approximately 1-2 feet of movement
every few thousand years. The siting and permitting process was an endorsement of the facility design by the controlling regulatory agencies.
State-of-the-Art Design: Receiving
and treatment processes are totally enclosed with air pollution control systems in place to prevent emissions.
Landfills are designed with redundant protective systems, including two synthetic liners, a leachate collection system to quickly remove precipitation, and a leak detection system to provide early warning of potential anomalies in the system. Landfill caps also include a synthetic liner to prevent infiltration of precipitation.
Strict Acceptance Procedures: Waste materials are treated to reduce the mobility of hazardous constituents. All received waste is tested to confirm its identification prior to acceptance. This facility has two Ohio EPA inspectors at the site full time to monitor operations and offer regulatory guidance. Ohio
EPA approves every waste material accepted by the facility.
Extensive Monitoring Systems: This
facility maintains 117 groundwater wells around the perimeter of the facility which monitor three different geologic zones. Ten air stations monitor particulate emission levels.
Corrective Action/Past Practices: Nearly
all industrial facilities have areas of past practice where industrial activity took place prior to the regulations. This facility's past practice areas were limited to solid waste disposal activity, which is
currently being addressed by the company. The company will resolve these issues: once resolved no other past practice issues are known to exist at the facility. It is important to note that no past industrial processes took place at the facility.
Closure and Post-Closure Trust Funds: RCRA
requires that facilities provide for adequate funds to close and monitor for 30 years all past units.
This facility has fully funded its closure and post-closure trust funds in cash. This funding requirement is an important part of the RCRA commitment to ensure long-term protection.
Perpetual Care Trust Fund: In
addition to the above funds, this facility has established an additional fund to monitor and maintain the facility "in perpetuity".
The combined closure, post-closure and perpetual care trust fund has nearly 37 million dollars in cash, and will grow to hundreds of millions of dollars before it becomes necessary to use it. For example, in just 20 years the fund balance will exceed 100 million dollars.
This facility is an example of what was intended under RCRA – to protect human health and the environment while providing
for secure treatment and disposal of industrial wastes.
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