Page 105 - Pipeline Pigging Technology

Pipeline Pigging Technology

remediation, it is very difficult to identify the portion of the waste put in by
any one entity. In such instances, pipeline companies sometimes are believed
to have "deep pockets" and may be asked to pay more than their fair share
toward any clean-up activities.
CERCLA also may play a role at abandoned or surplused facilities which,
due to the presence of some hazardous substance, may be deemed as NPL
sites. Historically, instances of the pipeline industry's involvement in this
situation are rare; however, abandoned manufactured gas plants and hydro-
carbon processing plants are beginning to attract the attention of CERCLA
regulators.
EPA also has used the imminent and substantial endangerment provision
of CERCLA to address situations that fall outside the scope of other environ-
mental laws. EPA frequently has invoked this provision of CERCLA in dealing
with pipeline companies faced with historic polychlorinated biphenyl (PCB)
contamination. By using this provision of CERCLA as a "catch-all" category,
EPA has had jurisdiction in many instances in which its authority under other
laws could be questioned.

RESOURCE CONSERVATION AND RECOVERY
ACT (RCRA)

Synopsis: RCRA regulates the handling of hazardous waste at actively-
operating facilities, and is intended to provide for the environmentally-sound
disposal of waste materials. RCRA, in part, was developed to address those
wastes generated as the result of CWA and CAA passage.
During the early 1970s, much attention was given to removing contami-
nants from air and water discharges and disposing of these contaminants as
solid wastes. Unfortunately, many of these contaminants removed from air or
water disposal were improperly disposed, and seeped back into the environ-
ment. It was determined that the improper disposal of these waste products
- as well as the disposal of other non-regulated waste products - was resulting
in a great deal of environmental damage.
RCRA was passed on 21st October, 1976, replacing the Solid Waste
Disposal Act. It took EPA nearly six years to develop a near-complete set of
regulations and, as promulgated today, RCRA is one of the nation's largest and
most controversial regulatory programmes.
Subtitle C of RCRA addresses:

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