Breath of Clarity

Discussion Comment: RCRA Corrective Action Sites

Original Post by Joey Durr:

For my cleanup research I chose Clean Harbors Environmental Services Inc (EPA RCRA ID: OHD000724153) in Cleveland, Ohio. I decided to choose this cleanup because it is close to home, but also because Cleveland hasn’t historically had the best record of keeping a clean environment. I’m sure most of you have heard of the Cuyahoga River Fire in 1969 that prompted the creation of the Clean Water Act. Although it did not directly cause the formation of the EPA, this fire brought attention to the great need for a governing body to protect our environment. Thus the EPA was formed in 1970. (Fun fact: The most popular brewery in Cleveland makes a pale ale called Burning River and yes, it is good)

Although this specific cleanup does not involve the River Fire incident, I wanted to take a deeper dive into a more recent cleanup in Cleveland to see how the areas’ environmental efforts have changed. Clean Harbors Environmental Services Inc is an indutrial wastewater treatment facility. The site was originally assessed in 1990 to determine if there were releases of hazardous waste that may be harmful to human or environmental health (CA050). In 2006, both human exposures and groundwater contamination were deemed controlled.

Something that caught my attention is that it took 18 years for a cleanup solution to be implemented, according to the site. This is due in part to the site being referred to CERCLA, or some other non-RCRA authority in 1995 (CA210). This didn’t mean that RCRA was no longer authorized to work on the site, but that they would no longer actively monitor the site for a potential cleanup situation. It is not clear on the site what happened from 1995 to 2006 and why the RCRA was given back authority over this cleanup. But in 2006, a solution for cleanup was selected (CA400). After the selection, the site says that the cleanup solution was implemented in 2008 (CA550). I find it interesting that human exposures and groundwater contamination are deemed controlled when the cleanup is ‘selected’ and not ‘implemented’.

For this cleanup, the site says that institutional(CA 772) and engineering(CA 770) controls were both used. Institutional controls include government, permits, and property. In these instances, it looks like the EPA was trying to protect people from accessing certain land to protect them from hazardous wastes. Engineering controls for this cleanup include groundwater and non-groundwater. Groundwater engineering is designed to treat and control the water while non-groundwater can be as simple as barriers restricting access to certain areas.

My impressions of the website was that it does a pretty good job of informing users for some cases, but a lot of cases are lacking information. I specifically chose this case because it was one of the more detailed ones. I also wish that the site would go into greater detail of the specific actions taken to clean up certain areas and the progress made. However, I think the site does do a good job of explaining issues and actions on a ground level. Having almost zero experience in Environmental law, I was still able to easily understand everything on the website with the occasional need for further research. I would definitely use this site in a professional capacity because it is a credible source that details the corrective actions taken by the EPA to clean up a location. Something that I really wanted to know in greater detail was the original environmental issue. Why was this location first investigated and eventually cleaned up? I think it’d be helpful for the public to know specifically what their risk of exposure is.


The note about the River Fire in the Clean Harbors Environmental Services Inc case emphasizes the importance of including background events in the profile as doing so connects the community members to the full story which is a major trend lacking across sites. It’s interesting the site with a severe incident catalyzing the Clean Water Act and EPA formation is the one with a detailed description relative to the other locations listed by this source. Further, a potential reason for delaying cleanup completion may be the lack of organization between cleanup entities (RCRA and CERCLA) changing over. We can apply this logic to all the other cases we observe taking a long time to fully investigate. Perhaps, by understanding the reasons for transferring cleanup control amongst various groups, we can address a gap in process in order to decrease the duration needed to restore a given area. I still go back to the major theme in that it would be preferred not to assume the reasons for delay and rather have that information be directly stated in the profile.

The inconsistency of information volume between the cases brings opportunity for the RCRA to improve upon the standardization of cleanup protocol. By placing time constraints on the amount of time between steps, we can creatively enhance communicating progress to the public. Insofar as the EPA efficiently posts updates, community members may increasingly track cleanups. Activity at sites is going to build the public’s support for the projects. To generate support for remediation projects, The RCRA Enforcement and Compliance Reports from ECHO need to include the exact local agency that leads actions. That way, accountability instigates the organizations to deliver. I wish the site went into detail regarding the specific cleanup actions implemented. ECHO did list compliance monitoring types. However, the link doesn’t have one-click definitions for that section and is generally not written for the community member audience. Joey brings into focus a crucial value of simplifying information. We need to thoroughly teach the local people about these issues in a way that is accessible within their knowledge base.