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Vision 2020: More Needed in Materials Reuse and...

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Vision 2020: More Needed in Materials Reuse and Recycling to Avoid Land Contamination Deyi Hou Parsons Corporation, Walnut Creek, California, United States

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he human society has been increasingly consuming natural resources. Humans have used more resources in the past 50 years than they did in all previous history. The global ecological footprint has exceeded the world biocapacity by 50% as of 2007.1 This astonishing human consumption rate is bound to increase as world leaders estimate that, over the first half of the 21st century, world population will grow 50% and global energy and materials use will grow 300%.2 The United States (U.S.), at the center of the stage, hosts less than 5% of the world’s population, but consumed approximately one-third of the world’s total material output in 1970 through 1995. With this consumption rate being seen as unsustainable, the U.S. government and domestic interest groups have started many efforts in moving toward more sustainable industrial practices. One of the focuses of the U.S. Environmental Protection Agency (USEPA) is the conversion of the current “waste management” framework to a more sustainable “materials management” framework, as proposed by the USEPA’s Vision 2020 paper.3 The U.S. economy has produced heavy contamination to the soil and groundwater on its lands, largely by hazardous waste generated through industrial activities over the past century. The USEPA estimated that 294,000 hazardous waste sites4 would still need remediation after decades of intensive cleanup efforts. Many of these contaminated sites are transgenerational: the pollution was caused by parent generations and the cleanup r 2011 American Chemical Society

burden is placed on the current and future generations. Knowing what happened in the past, an inquiring mind may wonder whether current industrial activities in the U.S. may carry cleanup burdens into the future generations. This can well be the case for a number of reasons: (1) current standard industrial practices do not completely prevent ongoing land contamination; (2) the major U.S. industrial facilities are releasing billions of pounds of toxic chemicals into the environment each year (e.g., 3.37 billion pounds in 20095); and (3) the U.S. industry largely depends on raw and intermediate materials that are manufactured in other countries where environmental stewardship is relatively poor. In addition, due to the complexity of humannature systems and immensity of scientific unknowns, it is reasonable to expect that more man-made chemicals that have not been well studied (thus not categorized as being “hazardous”) will be found to be causes of environmental deterioration in the future. This article argues that the shift of focus from “waste management” to “materials management” may result in land contamination if no well-designed regulatory policies are in place. A strong desire for waste reduction in “materials management”, when combined with a lack of well-designed regulatory standards and guidance, may lead to the reuse/recycling of hazardous materials at locations and for the type of usage for which they were not originally designed. Such inappropriate handling of potentially hazardous materials and waste can cause land contamination that requires tremendous efforts in cleanup. One example is the recycling of concrete. In the U.S., there are no federal standards and rarely state standards on the testing and reuse of concrete. The State of New Jersey is one of such states in the forefront of environmental stewardship. The Department of Environmental Protection (DEP) of New Jersey provides guidance for characterization of concrete and clean material certification for recycling. While such guidance can provide much clarity regarding how abandoned building materials shall be characterized and handled, it could also lead to unintended consequence when not appropriately used. Based on the New Jersey DEP guidance, concrete materials containing contamination below DEP’s Residential Direct Contact Soil Remediation Standards (RDCSRS) is authorized for direct unrestricted use on- or off-site. Although the RDCSRS may be protective of human health against direct contact, it may not be sufficient in providing protection to groundwater and surface water as drinking water sources. Taking Endrin (an organochloride insecticide) as an example, its RDCSRS is 23 mg/kg, similar to USEPA’s Regional Screening Level (RSL) for residential soil contact (18 mg/kg). However, the RDCSRS Published: July 08, 2011 6227

dx.doi.org/10.1021/es202079y | Environ. Sci. Technol. 2011, 45, 6227–6228

Environmental Science & Technology

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’ REFERENCES (1) Living Planet Report 2010: Biodiversity, Biocapacity and Development; World Wildlife Fund: Washington, DC, October 2010. (2) Sustainable Materials Management: The Road Ahead; U.S. Environmental Protection Agency: Washington, DC, June 2009. (3) Beyond RCRA  Waste and materials Management in the Year 2020; EPA530-R-02-009; U.S. Environmental Protection Agency: Washington, DC, 2002. (4) Cleaning Up the Nation’s Waste Sites: Markets and Technology Trends, 2004 ed.; EPA 542-R-04-015; U.S. Environmental Protection Agency: Washington, DC, September 2004. (5) 2009 Toxics Release Inventory National Analysis Overview; U.S. Environmental Protection Agency: Washington, DC, December 16, 2010.

Figure 1. Lag between old and new regulations has two effects: (1) company selects for less pollution prevention based on old limit, and (2) remediation cost curve is shifted upward due to pollutant migration. The combined effect is a dramatic increase in total cost (from AA0 D0 DBA to A00 A0 D0 DCC00 A00 ).

for Endrin is nearly 300 times the RSL for protection of groundwater (0.081 mg/kg). In other words, if an old concrete foundation contains Endrin at levels slightly less than RDCSRS and is used as fill material after being crushed (typical industrial practice), it can pose a serious risk to clean groundwater underneath the site. Even though the DEP apparently has no intention of leaving groundwater unprotected, in reality, the guidance may provide a basis for industrial practitioners to recycle materials in such a way that long-term environmental negativity outweighs the benefits of recycling practice. To better protect the environment, more research efforts must be invested in the study of long-term effects of material reuse and recycling. In comparison with manufacturing, reuse/recycling often are conducted at much smaller scale and in a decentralized manner. Consequently companies often lack incentives to study long-term effects, both benefits and liabilities, associated with such activities. In some occasions, industrial associations may take initiatives to conduct these studies. In many other cases, the government must step in to fund related research, as well as to turn research results into regulatory standards and guidance. Policy makers must also better understand how industries behave and make decisions regarding both pollution prevention and contamination remediation. There is often a lag period between regulating pollution prevention and regulating remediation, which leads to less investment in pollution prevention and later more required remediation. Such a temporal lag can dramatically increase the total cost associated with reducing the same amount of pollution (see Figure 1). Taking historical lessons into account, I recommend that governments invest more resources into the research and policymaking on materials reuse and recycling, as the U.S. and other countries are shifting from “waste management” to “materials management”. If well-designed regulations and policies are not established, or if these regulations and policies are not well enforced, a sustainable goal can potentially turn into unsustainable practices, and our future generation’s welfare could be jeopardized.

’ AUTHOR INFORMATION Corresponding Author

Phone: 510 316-5018; e-mail: [email protected]. 6228

dx.doi.org/10.1021/es202079y |Environ. Sci. Technol. 2011, 45, 6227–6228