2011Addendum: An Assessment of 

Environmental Problems Associated with Recycling of 

Hazardous Secondary Materials

June 30, 2011

 

U.S. Environmental Protection Agency

Office of Resource Conservation and Recovery
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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 approval, endorsement, or recommendation, or lack 

thereof.

ACKNOWLEDGEMENTS

This addendum was funded and managed by the U.S. Environmental Protection Agency. Data 

collection and presentation were conducted by ICF 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 providing objectives of the addendum, 

reviewing the methodology, helping to identify cases for further investigation, reviewing draft 

write-ups and drafting portions of the study. The EPA Work Assignment Manager was 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 cases, assembling relevant information, contacting 

persons with knowledge of selected cases, and drafting descriptions of each case.
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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 effort to revise the current “definition of solid waste” under the Resource Conservation 

and Recovery Act (RCRA), as it pertains to recycling 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 secondary materials. A first addendum to 

the study was published in July 2008. This 2011 Addendum is EPA’s second update to the study. 

II. Scope of the Study

The general goal of the study is to identify and characterize cases of environmental 

damage that have been attributed to some type of hazardous material recycling activity, and that

are relevant for the purpose of evaluating the impacts of the DSW rulemaking effort. 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 that 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 evaluated 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 second addendum to the study. Additionally, one potential 

damage case was already included in the 2007 study and we are providing an update to this

damage case in this Addendum. 

This Addendum includes the following Appendices:
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Appendix I: Additional Damage Cases from Recycling of Hazardous Secondary Materials

This 2011 Addendum adds five new damage case sites 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 additional damage cases and individual

profiles are located in the Addendum’s Appendix I.

Appendix II: Additional Sites Considered But Not Included in the Damage Case Analysis 

In preparing the 2011 Addendum, EPA identified and reviewed 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 recycling of hazardous 

secondary materials. The Addendum’s Appendix II contains a summary of sites considered 

but not included in the study.

Appendix III: Analysis of Recycling Damage Case Facilities that Are Also Intermediate

Facilities The analysis identified a total of two intermediate facilities out of seven included in 

the 2011 addendum. Although these facilities are intermediate facilities, both also 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.