EPA Could Further Ensure the Safe Operation of On-Site Incinerators

RCED-97-43: Published: Mar 5, 1997. Publicly Released: Mar 17, 1997.

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Pursuant to a congressional request, GAO reviewed the Environmental Protection Agency's (EPA) use of incineration at Superfund sites, focusing on: (1) what safeguards EPA uses to promote the safe operation of incinerators at these sites; and (2) whether EPA has fully implemented its planned system of safeguards.

GAO noted that: (1) EPA relies upon four main methods to promote the safe operation of incinerators used at Superfund sites; (2) these methods are: (a) required site-specific standards for an incinerator's emissions and performance; (b) engineering safety features built into the incinerator's systems; (c) air monitoring to measure the incinerator's emissions; and (d) on-site observation of the incinerator's operations; (3) EPA sets standards after it studies each site's characteristics; (4) each incinerator is designed with safety features intended to stop its operation if it fails to meet the specified operating conditions; (5) air monitors are placed in the incinerator's stack and around the site's perimeter to measure the incinerator's emissions; (6) at the three Superfund sites with ongoing incineration projects at the time of GAO's review, EPA had arranged for 24-hour, on-site oversight from either the U.S. Army Corps of Engineers or a state government to ensure that the incinerator was operating properly; (7) in addition to the four methods discussed above, EPA managers intended to use two other techniques, inspections and applications of lessons learned, to encourage safe operations, but neither was fully implemented; (8) EPA has not used inspectors from its hazardous waste incinerator inspection program to evaluate the operations of all Superfund incinerators as it required in a 1991 directive; (9) only one of the three incinerators GAO visited had received such an inspection; (10) EPA regional staff responsible for hazardous waste incinerator inspections were unaware that the Superfund incinerators were supposed to be inspected, and EPA headquarters officials were unaware that the inspections were not occurring; (11) EPA managers did not follow through on their intention to systematically apply the lessons learned from incineration at one site to other sites; (12) they had intended to prepare documents describing problems and solutions at each incineration project for use in designing and operating other projects and to hold periodic conference calls with the managers from incineration sites to discuss issues of common interest; (13) both of these methods of transferring information were dropped for various reasons; (14) GAO found that the lessons learned from the problems experienced at the sites GAO visited could benefit other sites; and (15) EPA headquarters officials told GAO that they encouraged Superfund project managers to share their experiences with incineration but had not facilitated this exchange in a structured way.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: Although EPA will not publish a single document consolidating site-specific requirements, it has drafted a letter to regional staff advising them to use Resource Conservation and Recovery Act (RCRA) inspectors for on-site incinerators at Superfund sites. The letter is expected to be issued soon.

    Recommendation: To provide further assurance that incinerators at Superfund sites are being operated safely, the Administrator, EPA, should implement the agency's guidance for having the Resource Conservation and Recovery Act hazardous waste incinerator inspectors evaluate Superfund incinerators, including the development of a single document specifying site-specific operating requirements and procedures for these incinerators.

    Agency Affected: Environmental Protection Agency

  2. Status: Closed - Implemented

    Comments: In September 1997, EPA held a national conference of regional officials involved with on-site incineration at Superfund sites to discuss lessons learned. EPA is planning to hold another such conference in the future but has not yet scheduled a date. The minutes of the September 1997 conference, which were distributed to attendees, discuss lessons learned from on-site projects. Also, guidance documents on incineration were produced based on the conference.

    Recommendation: To provide further assurance that incinerators at Superfund sites are being operated safely, the Administrator, EPA, should document the lessons learned about safe operation from the experiences of each Superfund site where incineration is used and institute a systematic process to share this information at other sites where incinerators are used.

    Agency Affected: Environmental Protection Agency


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