## 2011 Addendum: An Assessment of

Environm ental Problem s Associated with Recycling of

Hazardous Secondary Materials

June 30, 2011

U.S. Environmental Protection Agency Office of Resource Conservation and Recovery- 1
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DISCLAIMER Mention of trade names, products or services in this document does not convey , and should not be interpreted to convey , official EPA app roval, endorsement, or recommendation, or lack thereof.

ACKNOWLEDGEMENTS This addendum was funded and managed b y the U.S. Environmental Protection Agency . Data collection and presentation were conducted b y IC F 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 p roviding objectives of the addendum , reviewing the methodology , helping to identify ca ses for further investigation, reviewing draft write
- ups and drafting portions of the study . The EPA Work Assignment Manager wa s 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 case s , assembling relevant information, contacting persons with knowledge of selected cases, and drafting descriptions of each cas e .- 2
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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 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 effo rt to revise the current “definition of solid waste” under the Resource Conservation and Recovery

Act (RCRA), as it pertains to recy cling 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 secon dary materials. A first addendum to the study was published in July 2008. Th is 2011 Addendum is EPA’s second update to the study
. II. Scope of the Study The general goal of th e study is to identify and characterize cases of environmental damage that have been attributed to some ty pe of hazardous material recycling activit y, and that are relevant for the purpose of evaluating the impacts of th e DSW rulemaking e ffort. 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 th at 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 e valuated 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 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 sec ond addendum to the study . Additionally , one potential damage case was alread y included in the 2007 study and we are providing an update to this damage case in this Addendum. This Addendum includes the following Appendices :- 3
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Appendix I : Additional Damag e Cases from Recycling of Hazardous Secondary Materials This 2011 Addendum adds five new damage case site s 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 a dditional damage case s and individual profiles are located in the Addendum’s Appendix I. Appendix II : Additional Sites Considered But Not Included in the Damage Case Anal ys is In preparing the 20 11 Addendum, EPA identified and revi ewed 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 recy cling of hazardous secondary materials
. The Addendum ’s Appendix II contains a summary of sites considered but not included in the study
. Appendix III : Anal ys is of Recy cling Damage Case F acilities that Are Also Intermediate Facilities The anal ys is identified a total of two intermediate facilities out of seven included in the 2011 addendum
. Although these facilities are intermediate facilities, both a lso manage some waste on site. EPA used the same methodology for determining intermediate facilities as we did in the 2008 addendum
. The 2011 Addendum’s Appendix III includes a table of these intermediate facilities.