Archive for the ‘Solid Waste’ Category

MIT Study Weighs In On Nuclear Storage

Photo by Janine Forbes, some rights reserved

On the 25th anniversary of the Chernobyl disaster, and in the immediate wake of the nuclear crisis at the Daiichi plant in Fukushima following the Japanese tsunami and earthquake, the Massachusetts Institute of Technology published a new study, led by MIT Research Scientist Charles W. Forsberg, that advocates for the storing of used nuclear fuel for potential future reuse as opposed to reprocessing it, which can be seen as more environmentally dangerous.

The process of reprocessing nuclear waste, in which the used fuels are combed through and leftover plutonium and other valuable minerals are chemically separated, was originally proposed in the 1960’s, when plutonium was used solely for weapons. In the 1970’s, the United States government decided that the risks that came along with reprocessing were too great, and decided to instead begin disposing of nuclear waste in vastly deep underground repositories where it would be sanctioned off and out of the way. Since the rise of nuclear power, however, the process has been suggested as a way to increase efficiency and waste at nuclear plants by cycling plutonium directly back into thermal reactors. A more in-depth look at how reprocessing works can be found in the BBC archives, while an extensive rundown of the public safety concerns and scientific and economic downsides that come with nuclear reprocessing can be found on the website for the Union of Concerned Scientists.

In recent weeks, in the wake of the tragedy in Japan, reprocessing again has been suggested by American advocates who believe that reprocessed plutonium could then be substituted for uranium. However, as is suggested in Forsberg’s study, the global supply of uranium is very healthy, with ten times as much uranium surplussed as would be needed to fuel ten times the number of reactors currently on earth for 100 years. An alternative, the study suggests, would be to store used nuclear waste in centralized, high-grade concrete silos located in areas with small population density, where they would still be available for reuse (as opposed to disposing the waste underground) but would avoid any of the safety and health hazards that come with reprocessing.

Recycled Content Doesn’t Have to Be Boring

If, like me, you grew up in Seattle, you probably recycle without thinking. To not recycle is blasphemous. It’s also against the law.

Recycling: It's easy to do.

But that’s Seattle. Surprisingly, the EPA is not in a position to establish federal regulations mandating recycling. The EPA publishes information, guidance and provides technical support to encourage recycling programs, but, ultimately, it is up to state and local governments to regulate recycling of municipal solid waste. Currently the most the EPA offers, regulation-wise, is a recommendation to states that “source separation, recycling and resource conservation should be utilized whenever technically and economically feasible.” (40 CFR 256.31)

Some governments offer refunds for recycled beverage containers, others ban the disposal of recyclable items into landfills, while others simply set recycling goals for their state or city. Given that recycling programs vary from place to place, you should always review the rules and restrictions of your own municipality before tossing a given item into the recycling bin. Even products that are stamped with the ubiquitous recycling symbol are not necessarily accepted at all facilities.

Ah, the recycling or “three-chasing-arrows” symbol. Ever wonder about it? The original design was envisioned in 1970 by USC student Gary Anderson in response to a contest sponsored by the Container Corporation of America. The symbol is not trademarked, but its use is regulated by the Federal Trade Commission (FTC).

And that’s where the federal government steps in with regards to recycling. The FTC’s Green Guide addresses environmental advertising and marketing practices, and it specifically calls out recycling symbols. The clause on recyclability states, “A product or package should not be marketed as recyclable unless it can be collected, separated or otherwise recovered from the solid waste stream for reuse, or in the manufacture or assembly of another package or product, through an established recycling program can be substantiated, the claim should be qualified to indicate what portions are recyclable.” They give the following example:


A nationally marketed 8 oz. plastic cottage-cheese container displays the Society of the Plastics Industry (SPI) code (which consists of a design of arrows in a triangular shape containing a number and abbreviation identifying the component plastic resin) on the front label of the container, in close proximity to the product name and logo. The manufacturer’s conspicuous use of the SPI code in this manner constitutes a recyclability claim. Unless recycling facilities for this container are available to a substantial majority of consumers or communities, the claim should be qualified to disclose the limited availability of recycling programs for the container.

The SPI code that the FTC refers to is part of the SPI resin identification coding system, which was developed by the Society of the Plastics Industry in 1988 and is placed on plastic products to identify the polymer type and to help separate the different types for purposes of recycling. According to SPI, the code was not developed to be an indicator of “recyclability,” though certain polymer types are more widely recyclable in certain areas.

SPI codes are used internationally, though that hasn’t stopped some countries from developing their own versions of the recycling symbol. Below I offer some choice selections.

The Green Dot

The trademarked Green Dot is used in Europe to convey producer responsibility and efficient packaging waste management, though doesn’t have any bearing on whether the product itself is recyclable.

Japanese symbol for recyclable paper

Japanese recycling symbols use two or three of the familiar chasing arrows, though the shape these arrows form can vary according to the type of recyclable material.

A Taiwanese recycling symbol

This neon green Taiwanese recycling symbol is guaranteed to catch your eye.

And perhaps I’m just feeling patriotic, but it’s hard to argue that this US federal recycling logo isn’t the most regal of them all:

Is the EPA’s Regulatory Impact Analysis of the Coal Ash Rule Flawed?

Just over two years has passed since the Kingston, TN coal ash spill, but according to the Environmental Integrity Project (EIP), federal proposals to regulate coal ash dumps are still “being held up by concerns that stricter standards would depress markets for coal-ash recycling.”

Aerial view of Kingston ash slide. Photo by Tennessee Valley Authority. Some rights reserved.

In December of 2008, more than 1 billion gallons of coal ash slurry gushed from the TVA Kingston Fossil Plant’s broken dike and destroyed several houses before pouring into the Emory and Clinch Rivers, killing numerous fish and polluting drinking water in the area.

Coal ash (also Coal Combustion Residuals or CCR), which is made up of byproducts of the combustion of coal at power plants, is currently considered an “exempt waste” under the Resource Conservation and Recovery Act (RCRA, 42 USC 6901 et seq). But even the EPA acknowledges that the ash contains “contaminants like mercury, cadmium and arsenic associated with cancer and various other serious health effects.”

In the aftermath of the spill, realizing that “without proper protections, the contaminants in coal can leach into groundwater and often migrate to drinking water sources, posing significant health public concerns,” the EPA began the process of regulating coal ash disposal.

On June 21, 2010, the EPA published the Coal Combustion Residuals Proposed Rule, which sought public comment on two possible approaches for regulation under RCRA. Regulation under Subtitle C (40 CFR Parts 260-279) would treat coal ash as a hazardous waste, while regulation under Subtitle D (40 CFR Parts 239-258) would treat it as only solid waste (see the key differences between the options here). Needless to say, utilities are gunning for the less strict – and therefore less costly – option under Subtitle D.

Yesterday, however, EIP published a scathing press release, in which it accused the EPA of grossly overestimating the value of coal ash recycling in the Regulatory Impact Analysis for the proposed rule. While most environmentalists applaud the reuse of coal ash to make products such as concrete, cement, or wallboard, EIP is concerned that the overstated benefits could end up “stacking the deck in favor of the weaker regulatory option favored by industry,” as the EPA’s analysis implies that the higher costs of the stricter regulation may cause roadblocks to recycling the ash.

EIP worked along with Earthjustice and the Stockholm Environment Institute to re-evaluate the estimates in the EPA’s Regulatory Impact Analysis. You can read their report here.

Danger in the Air in Afghanistan and Iraq (and it’s not what you think)

Photo by Greg Henshall. Some rights reserved.

About two weeks ago, the GAO released a report scolding the Department of Defense (DOD) on their enforcement of burn pit operations procedures and solid waste management. The GAO initially was asked to report on “(1) extent of open pit burning in Afghanistan and Iraq, and whether the military has followed its guidance; (2) alternatives to burn pits, and whether the military has examined them; and (3) extent of efforts to monitor air quality and potential health impacts.” Their conclusion? DOD needs to improve “adherence” to guidance on burn pit operations and waste management, as well as consider alternatives to current procedures.

According to the DOD, soldiers in Afghanistan and Iraq each generate about 10 pounds of solid waste per day. The efficiency of the process means that most of this waste is burned in open pits, despite the abundant smoke and other emissions associated with the practice. DOD and the U.S. Central Command (CENTCOM) have only recently provided specific guidance and policies on the management of these burn pits. GAO investigators found that many burn pits inspected were failing to comply with the published guidelines – burn pit operators routinely burned items that are now prohibited (such as plastics and aerosol cans) and failed to monitor or document emissions from the pits. Additionally, burn pits were often used for stretches of time that exceeded recommendations (it is suggested that burn pits be replaced incinerators when practical).

As the GAO points out, U.S. environmental protection laws do not normally apply overseas. Therefore, the military has developed its own policies and guidelines for the management of solid waste during military operations. In September of 2009, CENTCOM published Regulation 200-2, which finally detailed “minimal acceptable standards for solid waste disposal” and burn pit operations. In March of 2010, DOD issued Memorandum 09-032, which prohibited “the disposal of covered waste in open-air burn pits during contingency operations except when no alternative disposal method is feasible.” Following the guidance wouldn’t just eliminate the more toxic elements in resulting emissions – it would ideally prevent some of the pollution altogether. The DOD memo was to be incorporated into DOD Instruction 4715.5, which established general environmental standards “for protection of human health and the environment at DoD installations in foreign countries.” (A complementary DOD guidance document on the environmental compliance standards is available here.)

What happens when you fail to follow the directions? According to the EPA, the kind of particle pollution produced by open pit burning is associated with the following health problems: “irritation of the airways, coughing, or difficulty breathing; decreased lung function; aggravated asthma; development of chronic bronchitis; irregular heartbeat; nonfatal heart attacks; and premature death in people with heart or lung disease.”

The GAO reports that “some veterans returning from both conflicts have reported pulmonary and respiratory ailments, among other health concerns, that they attribute to burn pit emissions.” To date, more than 200 current and former servicemembers have joined together for a class action suit against Kellogg, Brown, and Root (KBR), one of the contractors hired to provide burn pit services in Iraq. They allege that exposure to air pollutants due to the contractor’s negligent management of burn pit operations has resulted in serious health problems. The MDL Docket Report for the case can be found here. The District Court for the District of Maryland has published an Order and a Memorandum Opinion on the case (In re KBR Burn Pit Litigation, RWT-09-2083). KBR has responded to the accusations online with “Facts About Burn Pit Litigation.”

The GAO report concluded with six recommendations for helping the DOD adhere to “relevant guidance on burn pit operations and waste management.” When given a chance to review the draft report, the DOD concurred with almost all of the GAO recommendations, and explained the ways in which they hope to improve operations. One hopes these improvements can help prevent at least some of the perils of war.

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