Envirosafe Services of Ohio, Inc, (ESOI) was designed and constructed to meet the stringent standards of the Resource Conservation and Recovery Act (RCRA). The RCRA requirements for constructing, operating and monitoring facilities like Envirosafe were created by Congress to specifically address concerns about long-term protection. Requirements for redundant protective systems in cell designs, for treatment of waste prior to disposal, and for monitoring and financial assurance programs were put in place to form overlapping and complementary levels of protection. RCRA permitted landfills are machines that are designed and built to produce long-term liability protection. In fact, the sole purpose of a RCRA permitted treatment and disposal facility is to maximize long-term protection of the environment and the surrounding communities. As a result, RCRA facilities are specifically and exclusively designed and operated for this purpose. When it comes too long-term liability protection there is no comparison.
Ensuring long-term liability requires two parts. The first is to design and construct a facility, which provides multiple redundant levels of protection. The second part of the equation is to operate the facility in such a way to prevent the creation of future liabilities, including commitment to constantly identify potential regulatory or environmental concerns and immediately resolve them. Envirosafe has operated its facility in compliance with these regulatory requirements since the inception of the RCRA program.
Envirosafe manages liability through careful, direct, and purposeful implementation of the permit. Envirosafe under went 7 years of permitting, public, and regulatory hearings, and exhaustive scientific reviews to obtain a final permit. This review confirmed the exceptional nature of the facility’s geologic characteristics, which include up to 100 feet of high density, low permeability clay deposits.
The facility’s receiving and treatment processes are totally enclosed with air pollution control systems in place to prevent emissions. Landfills are designed with redundant protective systems, including two synthetic liners, a leachate collection system to quickly remove precipitation, and a leak detection system to provide early warning of potential anomalies in the system. Landfill caps also include a synthetic liner to prevent infiltration of precipitation.
Strict Acceptance Procedures
Envirosafe’s strict acceptance procedures further supports its commitment to ensuring long-term liability protection. All wastes undergo a stringent approval process which includes thorough technical evaluations. All wastes are tested to confirm its identification prior to acceptance. Wastes requiring treatment are treated to reduce the mobility of hazardous constituents.
Envirosafe maintains 132 groundwater monitoring wells around the perimeter of the facility, which monitor three different geologic zones.
Corrective Action/Past Practices
Nearly all industrial facilities have areas of past practices where industrial activity took place prior to the regulations. Envirosafe’s past practice areas were limited to solid waste disposal activity, which is currently being addressed by the company through a RCRA Corrective Action Program (CAP). The company will resolve these issues, once resolved, no other past practice issues are known to exist at the facility.
Closure, Post-Closure, & Perpetual Care Trust Funds
RCRA requires that facilities estimate the cost and provide adequate financial assurance for the closure and post closure care all RCRA permitted units. Envirosafe established trust funds for this purpose and has fully funded its closure and post-closure cost estimates in cash. As part of RCRA corrective action, Envirosafe has also estimated and provided financial assurance through the trust funds for all past practice units where corrective measures are required. This funding requirement is an important part of the RCRA commitment to ensure long-term protection.
In addition to the above regulatory required funding, Envirosafe provides additional financial assurance in the post closure trust fund to monitor and maintain the facility "in perpetuity". The combined closure, post-closure, corrective measures, and perpetual care trust fund has 54 million dollars in cash, and will grow to hundreds of millions of dollars. The fund balance is forecasted to exceed 100 million dollars in just 20 years.
The Envirosafe facility is an example of what was intended under RCRA – to protect human health and the environment while providing for secure treatment and disposal of industrial wastes.