GeosyntheticsMagazine.com | April 20, 2012

U.S. House Transportation Committee Subchairmen John Duncan (R-Tenn.) and Frank LoBiondo (R-N.J.) received their Friend of GMA awards from Boyd Ramsey, GMA executive council chair, and Andrew Aho, GMA managing director. The presentations took place April 17 during GMA’s annual Lobby Day in Washington, D.C.

GeosyntheticsMagazine.com | April 10, 2012

By Ron Bygness

Environmental and public health groups filed a lawsuit April 5 to compel the U.S. Environmental Protection Agency (EPA) to complete its rulemaking on coal ash. A court order could hold the agency to a specific date for issuing a final rule on coal ash.

Coal ash is a byproduct of burning coal to generate electricity. Coal-ash holding ponds are largely unregulated and unlined, including the use of geosynthetic liners (geomembranes or geosynthetic clay liners) for safety.

Environmentalists have called for more-strenuous regulations, particularly since a December 2008 disaster when a containment site in Kingston, Tenn., burst open and flooded 300 acres with coal-ash sludge. That impoundment failure resulted in a multi-year cleanup costing more than $1.2 billion.

Another spill occurred in 2011 in Oak Creek, Wis., near Milwaukee, where a power company’s coal-ash containment pond collapsed and the byproduct sludge slid into Lake Michigan.

The containment facilities in Tennessee and Wisconsin were not lined.

The April 5 lawsuit is intended to force the EPA to complete its rulemaking on coal ash (Appalachian Voices v. Jackson, D.D.C., docket number unavailable, 4/5/12). The lawsuit, filed in U.S. District Court for the District of Columbia, asks the court to set deadlines for the EPA to review and revise coal-ash regulations.

The EPA issued a proposed rule in May 2010 that outlined two options for regulating coal ash. But the agency has not yet issued a final rule, maintaining that it expects to do so by the end of the year. A court order could hold the agency to a specific date.

Earthjustice, representing a coalition of 11 groups, said the EPA has violated section 2002(b) of the Resource Conservation and Recovery Act (RCRA) by not reviewing and revising coal-ash regulations every three years.

The EPA process is intended to determine whether to regulate coal ash as a special waste under Subtitle C of the RCRA, subjecting it to hazardous waste regulations; or as non-hazardous waste—such as municipal solid waste—under Subtitle D, leaving regulation authority with the states.

That proposed rule received more than 450,000 public comments, according to EPA. The Geosynthetic Materials Association (GMA) offered professional testimony regarding geosynthetic lining technologies at eight of these public hearings, which were conducted across the country in 2009–2010.

The environmental-group coalition first filed a notice of intent to sue in January. Among the plaintiffs in the current lawsuit are Appalachian Voices, the Chesapeake Climate Action Network, the Environmental Integrity Project, Physicians for Social Responsibility, and the Sierra Club.

The Utility Solid Waste Activities Group (USWAG) has criticized the Earthjustice lawsuit. Litigation could prevent the EPA from crafting an effective rule and could result in bad public policy, according to the USWAG, an organization that addresses waste issues on behalf of the electric utility industry.

Sen. John Hoeven (R-N.D.) and Sen. Kent Conrad (D-N.D.) introduced legislation last October that would prevent the EPA from regulating coal ash as a hazardous waste and give primary oversight of the material to the states. Companion legislation from Rep. David McKinley (R-W.Va.) passed the House in October, 2011.

Ron Bygness is the editor of Geosynthetics magazine.

The annual “Call for IFAI board candidates” from the Industrial Fabrics Association International was sent to the association’s voting membership on Monday, April 9. Applications are due May 28, 2012.

In June, the IFAI board’s Leadership Development Committee meets to consider the qualifications of the candidates. In July, the association’s membership is notified of committee’s recommendations.

Election results are announced at the 2012 IFAI Expo Americas, Nov. 7–9 in Boston.

IFAI members are encouraged to recommend candidates for the board:

Cherie M. Schmit
Executive Assistant to the President
Industrial Fabrics Association International
1801 County Road B. West
Roseville, Minnesota 55113
U.S.A.
Ph: +1 651 225 6985
Fax: +1 651 225 6977

U.S. Rep. Paul Broun (R-Ga.,10th) toured the new Crown Resources facilities in Toccoa, Ga. in March, following a town hall meeting at North Georgia Technical College. With Broun (right) are, l-r: Monica Christensen, Crown’s director of human resources; Keith Gardner, vice president of sales; and Monte Thomas, owner and president. Toccoa is in Stephens County in far northeastern Georgia, near the South Carolina border.

Source: Toccoa Record

By Andrew Aho

Geotextile manufacturers participating in public roadway applications are enrolling in a new program that requires a quality audit of their manufacturing facilities and their QA/QC processes. And, for the first time, it requires printing of the manufacturers’ name or identification number on the geotextile.

The American Association of State Highway and Transportation Officials (AASHTO) provides testing of materials used in roadway construction on behalf of its members—the state departments of transportation. AASHTO’s National Transportation Product Evaluation Program (NTPEP) was developed to eliminate duplicative testing that could have been done by the DOTs. Its expansion now includes the audits and geotextile printing. Geotextiles that meet the testing and auditing requirements are listed on the NTPEP website. State DOTs can check the list to make sure that the geotextiles they are considering for their projects meet specifications.

NTPEP tests both geotextiles—the GTX program—and also geosynthetics used for reinforcement—the REGEO program—which is designed for geogrids and other geosynthetic materials used in reinforcement applications. The GTX program is managed by a committee chaired by Tony Allen of Washington state DOT and includes members from other state DOTs. GMA has two industry representatives participating on the GTX committee: Brian Whitaker of Fiberweb and Davis Taylor of Thrace-LINQ.

The new audit program has its roots in GMA’s desire to improve the quality of materials purchased by state DOTs. GMA approached NTPEP to develop an audit and geotextile printing program similar to the program NTPEP created with the Plastic Pipe Institute. The plastic pipe program brought assurances to the DOTs regarding quality of the pipe produced by manufacturers. It has been extremely successful and is a contributing factor of the tremendous growth of that industry.

Several state DOTs indicated they wanted to create their own audit/printing programs for geotextiles. They needed a simplified process to identify the prime manufacturer of the geotextiles used in their projects.

GMA welcomed a national program to circumvent having a hodgepodge of individual state programs. GMA worked with NTPEP to develop the geotextile printing and labeling that would resolve the DOTs’ concerns about tracing materials to the prime manufactures and also a more efficient way of determining if the geotextiles meet the specs for DOT projects.

Manufacturers who supply geotextiles to Quebec, Scandinavia, and the EU have had to meet similar audit and geotextile printing requirements for years.

“The exciting improvements to the NTPEP program are all focused around increased assurance,” said John Henderson, past chair of GMA’s executive council. “The improved program brings assurance that the geosynthetics used by regulatory agencies are produced and tested to high quality standards. The new printing and labeling standards provide assurance to the regulators and end users that the products that are specified are indeed the products that will be shipped to and installed at the project site. In addition, this new standard elevates geosynthetics to the same or higher standard as traditional construction materials, which will greatly increase the acceptance of these revolutionary materials,” Henderson said.

One area of concern is whether the program should be modified as it relates to private label companies. The new program also includes private label companies, but the audit requirements are less that those required of a prime manufacturer. All private label products are labeled at the manufacturers’ facilities. If a private label company is sourcing at an NTPEP-audited manufacturer, it is the manufacturer that is printing its code and label on the geotextiles. This process eliminates the concern of the DOTs regarding tracing products to the prime manufacturer.

GMA will work with NTPEP in 2012 to help it fine-tune the audit process to make sure that this program works both for the industry and its customers, the DOTs. GMA believes that NTPEP has taken a necessary step to assure the DOTs that the products they are testing and qualifying will meet their needs.

Andrew Aho is the managing director of the Geosynthetic Materials Association (GMA).

GeosyntheticsMagazine.com | February 15, 2012

The Geosynthetic Materials Association (GMA) announced in a Feb. 13 press release a new Member Scholarship award that provides tuition expenses at an accredited college, university, or technical school. Scholarship recipients are selected on the basis of academic achievement, community service, and interest in a career path that includes the development, specification or application of technical textiles.

The release noted that to qualify for the GMA Member Scholarship, applicants must be employed by or related to an employee of a GMA member company.

The GMA scholarship is offered under the umbrella of the Industrial Fabrics Foundation (IFF) scholarships that provide access to education for industry employees, their family members, and future employees. Donations from individuals, corporations, and other organizations support the IFF and its scholarship program.

The IFF is a 501(c)3 nonprofit organization dedicated to furthering education and research in specialty fabrics.

The application deadline for the 2012 GMA scholarship is May 18, 2012.

Selection criteria: This $1,000 scholarship award provides tuition expenses at an accredited college, university or technical school. Scholarship recipients are selected on the basis of academic achievement, community service and interest in a career path which includes the development, specification or application of technical textiles. To qualify for the GMA Member Scholarship award, applicants must be employed by or related to an employee of a Geosynthetic Materials Association (GMA) member company. The scholarship will apply to the 2012–13 academic year and will be paid directly to the student’s school for fall semester tuition.

To qualify for the scholarship, an applicant must:

• be an employee or related to an employee of a GMA member company.
• be pursuing a degree in an accredited college, university or technical school.
• show successful academic achievement.
• demonstrate leadership in school and community.
• relate work experience and history.
• indicate a financial need.
• complete the scholarship application and return to the IFF office with required support documents.

Deadline: Scholarship application and three (3) reference letters must be received on or before May 18, 2012. Reference letters should comment on the applicant’s character and potential for leadership and for making a significant contribution as a future employee. Letters of reference must be from:

• representative of the member company with which applicant is affiliated.
• high school, college, university, or technical school advisor.
• a person (not a relative) who has known the applicant for at least three years.

Mail to:
Industrial Fabrics Foundation
Attn: Ruth Stephens, Managing Director
1801 County Road B. West
Roseville, MN 55113

Electronic submission to (PDF format only, in one file, using applicant’s name as title): rastephens@ifai.com

Questions: Contact Ruth Stephens via phone: +1 651 225 6545, fax: +1 651 631 9334, or email: rastephens@ifai.com

By Andrew Aho

The geosynthetics industry has long sought a federal study of the cost-and-benefits of geosynthetic materials in roadway systems.

Numerous industry and academic studies, papers, and articles regarding the cost-benefit of geosynthetics have been produced during the last three decades. However, federal government validation has been missing.

GMA proposed a federal study that would look at the current body of data and develop a consensus or consolidation of the myriad studies. GMA’s lobbying team took up the issue in 2009, seeking a method for the study to be both funded and conducted by the federal government.

When Congress banned the use of “earmarks,” our lobbying team took a different approach. Discussions with the House Transportation Committee resulted in a sensible idea—last fall, two members of Congress sent a letter to the U.S. Government Accountability Office (GAO), asking that office to conduct the study.

It is our expectation that the report will be effective and positive in demonstrating how the use of geosynthetic materials can improve the quality of infrastructure while reducing maintenance costs, increasing longevity, and simultaneously increasing the overall effectiveness of the taxpayer’s dollar.

We expect that the completed report will be instrumental in motivating the Federal Department of Transportation, state DOTs, and other entities to use the most modern and cost-effective methods in their construction and infrastructure projects and will benefit their constituencies, our country, and our industry.

The coauthors of the letter were Rep. John Duncan (R-Tenn.) and Rep. Frank LoBiondo (R-N.J.), both members of the House Committee on Transportation and Infrastructure. Rep. Duncan also serves as chairman of the Subcommittee on Highways and Transit, and Rep. LoBiondo is chairman of the Subcommittee on Coast Guard and Maritime Transportation.

The letter from Duncan and LoBiondo to the GAO highlighted the data available to complete a cost-benefit study:

Because there is ample academic, industry, and state department of transportation information publicly available that the GAO can use to complete the study, the study should incorporate existing research and data concerning the use of innovative materials in payment systems, such as the addition of geosynthetic materials in pavement systems.
(Oct. 13, 2011, Duncan/LoBiondo letter to GAO)

GMA compiled data for the study by reaching out to the geosynthetic industry for case studies, peer reviewed papers, and other documents that demonstrate the cost-benefit of using geosynthetic materials in roadways. The collection of data was then shared with both the GAO and the staff of the House Transportation Committee.

We anticipate the positive results this spring.

Andrew Aho is the Managing Director of Geosynthetic Materials Association (GMA).

By Ron Bygness

A coalition of environmental groups is suing the U.S. Environmental Protection Agency (EPA) with the goal of speeding new safeguards for coal-ash disposal.

In its lawsuit, the coalition claims the EPA has declined for decades to enact regulations to declare coal ash as hazardous waste or to update testing methods.

If the EPA declares coal ash a hazardous waste, it would lead to new clean-up costs for electric companies that store the byproduct in holding ponds near the power plants.

Coal ash is a byproduct of burning coal to generate electricity. The coal-ash holding ponds are largely unregulated, including the use of geosynthetic liners (geomembranes) for safety.

Environmentalists have called for more-strenuous regulations, particularly since a December 2008 disaster when a containment site in Kingston, Tenn., burst open and flooded 300 acres with coal-ash sludge. That impoundment failure resulted in a multi-year cleanup costing more than $1.2 billion.

Another coal-ash spill occurred in 2011 in Oak Creek, Wis., near Milwaukee, where a power company’s containment pond collapsed and the byproduct sludge slid into Lake Michigan.

Ron Bygness is the editor of Geosynthetics magazine

GMA’s position consistent

The position of the Geosynthetic Materials Association (GMA) has been a consistent lobby for the lining of coal-ash containment sites. The use of composite liner systems will achieve the EPA mission to protect human health and the environment.

While coal ash does contain heavy metals, it lacks the traditional characteristics of hazardous materials: radioactivity, or the presence of infectious medical waste.

In the opinion of our trade association, coal ash can be properly stored using “subtitle D” regulations, a non-hazardous solid-waste designation with composite liner systems.

—Andrew Aho, GMA managing director

Northern California:

March 6-7, 2012

Hilton Garden Inn Roseville
1951 Taylor Road
Roseville, California
Register here for the Northern California Short Course

Southern California:

March 8-9, 2012

(Meeting space donated by Leighton & Associates)
17781 Cowan
Irvine, California
Register here for the Southern California Short Course

The 1.5-day (9 PDHs) short course “Geosynthetics in Roadways” provides training on the appropriate, cost-effective use of geosynthetics in roadway applications. The course examines the use of geotextiles, geogrids, and edge drains in pavement structures. Filtration, drainage, roadway separation, roadway reinforcement, roadway subgrade improvement, and pavement overlay applications are addressed. Although this training focuses on roadways, the content is applicable to other areas of geosynthetic applications.

Bob Holtz, Ph.D., P.E., D.GE, is a professor emeritus at the University of Washington. He has taught numerous short courses and given many presentations at seminars and conferences, both in the U.S. and abroad. His research and publications are geosynthetics, soil improvement, foundations, and soil properties. He is author, co-author, or editor of 23 books and book chapters, including Introduction to Geotechnical Engineering, 2nd Edition, as well as more than 270 technical papers, discussions, reviews, and major reports.

L. David Suits, MSCE , has more than 35 years of experience in geosynthetics and geosynthetics testing. He is currently the executive director of the North American Geosynthetics Society. He is retired from the New York state DOT where he was the Soils Engineering Laboratory Supervisor overseeing all testing and approval of geosynthetics for use by the department. He is author/co-author of more than 30 papers, numerous articles, and textbook chapters on geosynthetics. He is currently one of the members of the team that teaches the NHI/FHWA Designing with Geosynthetics course.

Outcomes

The outcomes for this short course are an understanding of the types of geosynthetics available for providing economical solutions for geotechnical engineering problems.

Who should attend?

The workshop is intended for engineers or technical staff who design roadways and would like to gain a greater understanding of the use of geosynthetics in roadway applications. The course is open to anyone who uses geosynthetics.

Brought to you by the North American Geosynthetics Society (NAGS), a chapter of the International Geosynthetic Society (IGS) and the Geosynthetic Materials Association (GMA), a division of the Industrial Fabrics Association International (IFAI).

Corporate sponsors: Northern California is sponsored by Reed & Graham ; Southern California is sponsored by Thrace/LINQ .

By Andrew Aho

At our meeting on Jan. 23, 2012, we will welcome the newest member of the GMA Executive Council—Crown Resources of Toccoa, Ga.

A manufacturer of woven and nonwoven geotextiles, Crown is led by industry veterans, Monte Thomas and Keith Gardner. We look forward to their expertise, ideas, and energy.

Join me in welcoming Monte, Keith, and the Crown Resources team to GMA’s Executive Council.

Andrew Aho is the managing director of the Geosynthetic Materials Association (GMA).

The next Lobby Day in Washington, D.C., organized by the Geosynthetic Materials Association (GMA), is set for Tuesday, April 17.

A GMA-members dinner and program are scheduled for Monday evening, April 16. Congressional and agency visits will be April 17.

GMA has made arrangements with the Lombardy Hotel for a rate of $209 (plus tax)—reference “IFAI rate” when booking your room.

It will be an interesting time to be in Washington, D.C. We look forward to seeing you there!

Andrew Aho
Managing Director
Geosynthetic Materials Association
651 225 6907 office
651 485 4011 cell
amaho@ifai.com

GeosyntheticsMagazine.com | October 25, 2011

ROSEVILLE, MINN. Oct. 25, 2011—The Geosynthetic Materials Association (GMA) has announced that two members of Congress have sent a letter to the U.S. Government Accountability Office (GAO), asking that office to conduct a study regarding geosynthetic materials in roadway systems.

The coauthors of the letter are Rep. John Duncan (R-Tenn.) and Rep. Frank LoBiondo (R-N.J.), both members of the House Transportation and Infrastructure Committee. Rep. Duncan also serves as chairman of the Subcommittee on Highways and Transit, and Rep. LoBiondo serves as chairman of the Subcommittee on Coast Guard and Maritime Transportation.

The geosynthetics industry has long sought a federal study of the cost-benefits of geosynthetic materials as separators and interlayers in pavement systems. “There have been a number of academic and industry case studies that indicate the positive benefits of using geosynthetics in road building,” said GMA managing director Andrew Aho. “We believe this study will provide federal government validation of the benefits of geosynthetics in the nation’s roadways.”

The letter from Duncan and LoBiondo to the GAO highlights the data available to complete the study:

“Because there is ample academic, industry, and state department of transportation information publicly available that the GAO can use to complete the study, the study should incorporate existing research and data concerning the use of innovative materials in payment systems, such as the addition of geosynthetic materials in pavement systems.”
(Oct. 13, 2011, Duncan/LoBiondo letter to GAO)

“We believe this study will ultimately increase the use of geosynthetic materials in transportation systems,” Aho said. “This is a significant step forward for the industry.”

The Geosynthetic Materials Association represents 80 member companies that manufacture, distribute, fabricate, and install geosynthetic materials. GMA is a division of the Industrial Fabrics Association International, based in Roseville, Minn. GMA research notes that the geosynthetics industry employs 12,000 people in the U.S. and adds $2.1 billion annually to the U.S. economy.

Editor’s note: A geosynthetics breakthrough at the federal level was accomplished Oct. 13 when a letter from Congressmen John Duncan and Frank LoBiondo was sent to the Government Accountability Office (GAO) requesting a study to investigate “costs and benefits of incorporating innovative materials in pavements … such as the addition of geosynthetic materials in pavement systems.” This long-standing issue has been championed by the Geosynthetic Materials Association (GMA) and its members.

Following is an Oct. 14 letter from GMA managing director, Andrew Aho.

–Ron Bygness

Dear GMA members,

We are pleased to announce that we have made significant progress on one of our key issues. As you know, we have been diligently working on getting a federal study completed on the cost benefits of geosynthetics in roadways. Yesterday, two members of the U.S. Congress asked the Government Accountability Office (GAO) to conduct our study.

Please see official letter from Congressmen Duncan and LoBiondo.

This is a significant achievement for our government relations program. We believe the successful study will provide federal government validation of the benefits of geosynthetics in pavement systems.

Many GMA members have participated in this effort by providing resources and by attending the various lobby day activities in Washington, D.C. We want to thank the GMA membership for the support moving this issue forward.

Andrew Aho
Managing Director
Geosynthetic Materials Association
651 225 6907 office
651 485 4011 cell

The Geosynthetic Materials Association (GMA) has launched a new website to better serve its members and the geosynthetics industry as a whole.

The new site features:

• news feeds from GMA’s official publication—Geosynthetics magazine.
• downloadable education and engineering resources.
• an industry events calendar.
• a revamped bookstore link.
• links to geosynthetics interest groups and service providers.

Non-members can now join GMA online and renewals for current members are easy to complete on the site.

The site’s navigation and search capabilities make it an essential resource for geosynthetics industry professionals.

Check out the new GMA website at www.gmanow.com.

Source: GMA

GeosyntheticsMagazine.com | August 15, 2011

Presented by: North American Geosynthetics Society / Geosynthetic Materials Association

This 1.5-day/9 professional development hours (PDHs) short course provides training on the appropriate, cost-effective use of geosynthetic materials in roadway applications.

The course examines the use of geotextiles, geogrids, and edge drains in pavement structures. Geosynthetic applications for filtration, drainage, roadway separation, roadway reinforcement, roadway subgrade improvement, and pavement overlays are also addressed.

Instructors: Barry Christopher, Ph.D., P.E., is an independent geotechnical engineering consultant. David Suits, MSCE, is the executive director of the North American Geosynthetics Society (NAGS).

Schedule: Oct. 20 (8 a.m.–5 p.m.)
Oct. 21 (7:30 a.m.–Noon)
Continental breakfasts (2), breaks, and lunch (1) provided

Registration: View the online registration form

GeosyntheticsMagazine.com | August 15, 2011

Presented by: North American Geosynthetics Society / Geosynthetic Materials Association

This 1.5-day/9 professional development hours (PDHs) short course provides training on the appropriate, cost-effective use of geosynthetic materials in roadway applications.

The course examines the use of geotextiles, geogrids, and edge drains in pavement structures. Geosynthetic applications for filtration, drainage, roadway separation, roadway reinforcement, roadway subgrade improvement, and pavement overlays are also addressed.

Instructors: Barry Christopher, Ph.D., P.E., is an independent geotechnical engineering consultant. David Suits, MSCE, is the executive director of the North American Geosynthetics Society (NAGS).

Schedule: Nov. 26 (8 a.m.–5 p.m.)
Nov. 29 (7:30 a.m.–Noon)
Continental breakfasts (2), breaks, and lunch (1) provided

Registration: View the online registration form

Geosynthetics | August 2011

By Andrew Aho

Geosynthetic materials as separators and interlayers in roadways study

GMA’s request for congressional funding of a cost-benefit study of geosynthetics as separators and interlayers in roads continues to gain momentum.

We are currently pursuing a dual track for the implementation of the Separation Study through both the transportation reauthorization bill and through a personal request from a congressional office. We have made great progress advocating the study in the U.S. House and Senate through meetings with transportation leadership and their staff members.

To date, we have secured more than 25 letters of support from GMA members directed to House and Senate Transportation leadership in support of GMA’s request. We will continue to advocate for the study during our Lobby Day meetings in September.

Coal ash waste disposal

On June 8, we had meetings with:

• (a) the White House Council on Environmental Quality,
• (b) Utility Solid Waste Activities Group (USWAG), and
• (c) several legislative offices, regarding this issue.

One of our takeaways from those meetings was the probability that the Environmental Protection Agency (EPA) will not rule on coal ash until after the 2012 U.S. elections.

GMA has testified and provided written comments on the EPA’s proposals. However, the utilities, recycling industry, and GMA would like the issue resolved much sooner through legislation.

On June 28 and July 18, GMA had the opportunity to participate in an Edison Electric Institute/USWAG conference call on the topic of recent action in the House of Representatives on coal ash legislation known as the McKinley bill.

The push for a legislative solution to the coal ash waste issue has been motivated by concerns that the EPA will classify coal ash as hazardous waste when it completes the rulemaking process. In addition, the EPA is moving slowly in the rulemaking process and both the electric utilities and the beneficial-use (recycling) industry want regulatory certainty regarding coal ash disposal.

McKinley bill

The original McKinley bill was introduced as an amendment to HR1 (an appropriations bill) and it banned the EPA from using federal funds to regulate coal ash as hazardous waste.

This bill has been completely rewritten with a more thoughtful approach that has a good chance to receive sufficient bipartisan support to pass the House and, potentially, the Senate (although that hurdle is much higher). The new bill would regulate coal ash as solid (non-hazardous) waste, allow for state permitting and control and, if passed, provide the utilities more regulatory certainty.

Here are the details:

• The bill that came out of the House Energy & Commerce Committee of HR 2273 (coal ash legislation) is sponsored by Rep. David McKinley (R-W.V.). This bill amended Rep. McKinley’s previous version of the bill HR 1391.
• A quick description of the purpose of HR 2273: to amend Subtitle D of the Solid Waste Disposal Act to facilitate recovery and beneficial use, and provide for the proper management and disposal, of materials generated by the combustion of coal and other fossil fuels. With HR 2273, House Republicans attempted to write a more widely palatable bill related to coal ash classification, management, and beneficial re-use. The previous bill took a harsh stance that simply exempted coal ash from a hazardous classification, but did not offer alternatives or solutions for how to manage coal ash under such a classification.
• HR 2273 would allow states to manage coal ash sites through permits to coal ash producers (while notifying the EPA that they are doing so). If state specifications are not met, then the EPA would take control and manage the site to its standards. This bill would maintain the current definition for coal ash under Subtitle D, non-hazardous.

If this bill gets bipartisan support in the House (as it did in the House Energy & Commerce Committee), it is possible that the Senate would be willing to approve it, particularly if the power/energy industry is successful in mobilizing support across party lines.

The bill is generally consistent with GMA’s position on the coal ash issue. We will be prepared to support it during our Lobby Day meetings in September in the House, if need be, and especially in the Senate where we have strong relationships.

Andrew Aho is the Managing Director of Geosynthetic Materials Association (GMA).

GMA’s Geogrid Focus Group met March 15, 2011, during Geo-Frontiers in Dallas. The group is developing a table of values for biaxial geogrids for use in subgrade stabilization applications. The reason for this effort is to provide specifiers of state, county/municipal and commercial projects with information that will allow them to more easily specify geogrids for subgrade stabilization applications. The AASHTO M288 geotextile specification is a tool that makes it easier for specifiers to use geotextiles. The goal for this project is to develop a similar specification for geogrids.

The values table will include the different manufacturing types of biaxial geogrids by strength class and the corresponding product values for each strength class.

“We understand that this process will be difficult to work through because of the variety of products on the market. However, we feel this is an important project that will help grow the geogrid market,” said Andrew Aho, GMA’s managing director.

GeosyntheticsMagazine.com | May 5, 2011

Martin Whitmer & Rudy Barry (Whitmer & Worrall)
Jimmy Kemp (Kemp Partners)

1) Transportation Update:
Transportation Reauthorization Bill Status
GMA Separation & Interlayer Study
Congressional Progress (Martin Whitmer / Rudy Barry)

• Currently GMA has 14 Letters of Support directed toward House Transportation & Infrastructure (T&I) leadership for the Geosynthetic Separation and Interlayer Study. We are working to get two additional letters from constituents of Rep. Jimmy Duncan (R–2nd Tenn.), Chairman of Highways & Transit Subcommittee. We have made great progress on the House side, and will also have additional GMA congressional champions weigh in with the House T&I Committee when the time is right.
• A working draft of the bill is currently working its way through the House. GMA is beginning to target Senate champions on the Environment & Public Works Committee (EPW).
• Timing of the bill: The Surface Transportation Extension Act of 2011, extended programs through the end of fiscal year 2011 and was signed into law on March 4, 2011. The new working draft of the transportation reauthorization bill is currently making its way through the House. The bill needs to have serious momentum by Labor Day for likelihood of passing in the 112th Congress.

2) Water Resources Development Act (WRDA) Update:
WRDA bill status – Progress related to Senate policy language strategy (Jimmy Kemp)

• GMA has been working extensively with Sen. John Barasso (R-Wyo.) and his Senate Environment & Public Works (EPW) Committee staff. We have supplied Sen. Barasso’s staff with GMA’s legislative language and Wyoming constituent information – per their request.
• The Senate EPW Committee has imposed a June 6 deadline for any WRDA project requests from members of Congress.
• GMA Member companies and lobbying team will meet with the Senate EPW Committee in early May.

GMA WRDA Language:
The committee is aware that the use of geosynthetic materials has expanded into nearly all areas of civil, geotechnical, environmental, coastal, and hydraulic engineering. As such, the use of geosynthetic materials in water resource projects is of interest to Congress as we look to increase efficiency, performance and lifespans of infrastructure. The committee encourages the Corps of Engineers and the Bureau of Reclamation to pursue the potential for geosynthetic technologies and applications in water resource and related projects.

3) EPA / Coal Ash Regulation Update:
Regulation enactment update – Status of H.R. 1391
Martin Whitmer/Jimmy Kemp/Rudy Barry)

• Late 2011 (early 2012 possible) ruling expected. EPA is sifting through 100,000+ comments and continuing to work with congressional, industry, and environmental groups working to exert their influence on the regulation. The EPA is trying to determine if coal ash will be classified as solid waste or hazardous waste. Both designations would require geosynthetics liner systems.
• Work to date: GMA submitted two formal comments to the EPA through regulations.gov; attended eight public hearings throughout the country and submitted physical comments at those hearings as well. GMA successfully worked to get a letter from a bipartisan group of Congress reps urging the EPA to consider mandating the use of geosynthetics at coal ash sites.
• Recent legislation: On April 6, 2011, Rep. David McKinley (R-1st W.Va.) introduced H.R. 1391, to “prohibit the EPA from regulating coal combustion byproducts as hazardous waste under Subtitle C of the Solid Waste Disposal Act, and for other purposes.” The bill immediately had 33 co-sponsors. We spoke to senior legislative staff in the House related to this bill. Their take was that this bill is a political statement in opposition to the EPA categorizing coal ash as a hazardous waste—and also a serious piece of legislation—but only in the House of Representatives. If the bill was to pass the House, there would be a small chance of it passing in the Senate. The introduction of this bill does highlight that this issue is still very important to Members of Congress and their constituents as the EPA considers regulation.

4) Future Washington, D.C. visit in September 2011:
Continue support in the House/Senate related to Transportation Reauthorization Bill. By September, we will have a good idea of the progress of this bill. A WRDA bill update/strategy progress will take place as well. Please look for an announcement of the dates of the next Lobby Day.

By Boyd Ramsey and Andrew Aho

The Geosynthetic Materials Association (GMA) participated in a public listening session held by the U.S. Environmental Protection Agency (EPA) March 30, 2011.

The session was held in Albuquerque, N.M., and addressed the topic of vapor migration as a component of the selection and evaluation process for Superfund sites and the National Priorities List. Specific information can be found on the EPA website.

The comments offered reflected the written opinions that GMA has previously submitted to the EPA docket. As with coal ash, GMA stressed that its members offer materials that can be efficiently and effectively used to address this issue and provide solutions to improve public health and the environment. The core of the message is summarized here in text taken from the written submittal to EPA.

GMA recommends the inclusion of vapor intrusion as a consideration for the hazard ranking system for CERLA (Comprehensive Environmental Response, Compensation and Liabilities Act)/NPL (National Priorities List). It is our organization’s—and our respective members’—experience and judgment that vapor intrusion and the corresponding dispersal of harmful and hazardous materials is a danger to public health and the environment.

GMA member companies, in fact, supply materials that perform as vapor barriers and containment membranes and are regularly used to prevent or control the movement of vapors through soil subgrades, foundations, slab structures, and buildings.

In addition to the official GMA presentation to EPA officials at this hearing, there was opportunity to expand the range of GMA contacts with the EPA staff members, discuss other topics and issues face-to-face, and further identify GMA as a source for solutions to EPA issues and concerns.

A ruling on changes within the Superfund selection process is expected before the end of the year.

Boyd Ramsey, chief engineer at GSE’s North American headquarters in Houston, is chair of GMA’s Executive Council. Andrew Aho is the managing director of GMA.

Boyd Ramsey of GSE was named chair of GMA’s Executive Council at the group’s annual meeting March 15 during Geo-Frontiers in Dallas.

Ramsey, chief engineer at GSE’s North American headquarters in Houston, succeeds TenCate’s John Henderson, who had served two consecutive two-year terms, the maximum allowed by GMA’s bylaws.

Ramsey is a geosynthetics industry and GMA veteran who has long been active in supporting GMA’s initiatives, including education and government relations.

GeosyntheticsMagazine.com | January 31, 2011

Editor’s note: The following statement was presented by GMA managing director Andrew Aho to the Geosynthetics Committee at the Transportation Research Board’s 90^th Annual Meeting Jan. 25 in Washington, D.C.

Mr. Chairman, thank you for giving me a few minutes on your agenda to share with your committee an important Geosynthetic Materials Association initiative that we have been working on with our government relations team.

I am Andrew Aho, managing director of GMA. As you may know, GMA has a robust government relations program and we have had a full-time presence here in Washington for the past five years. Please allow me to introduce some of our lobbying team that is with us tonight: Martin Whitmer, Jimmy Kemp, and Rudy Barry.

These gentlemen, the members of GMA, and I am sure all of you have been anticipating a new effort by Congress in developing a comprehensive Transportation Authorization Bill. The process of continuing resolutions has been frustrating to us all. During the time of continuing resolutions, our team has been very busy and successful with other issues important to the geosynthetic industry.

One major issue we have been working on is that of requiring that coal ash waste facilities be lined with geosynthetic materials—a composite liner system that would help protect groundwater and prevent a coal ash spill as [occurred in December] 2008 in Kingston, Tenn.

GMA was out front with that issue, working with members of Congress and the EPA to ensure that geosynthetics is part of the solution to the coal ash waste issue. We secured letters from members of Congress urging the EPA to require geosynthetic liners, we had members of Congress asking geosynthetic related questions at congressional hearings, and we also testified at eight EPA hearings on the issue, and we provided written and oral comments on the issue.

We also worked closely with a congressional office to draft legislation requiring liners at coal ash sites—legislation that could have been introduced should the EPA not go in our direction.

We are now confident that when the final rule is established this year that a composite liner system will be required at all coal ash waste sites. When implemented, we expect this rule will add more that $350 million to the geosynthetic market.

We are now prepared for a similar effort with the Transportation Authorization Bill.

GMA agrees with this [TRB] committee that a cost benefit study of using geotextiles as separators in roadways is the number one research need in the industry. We have taken your research needs statement and modified it slightly and we added a new component—we will not only seek funding for the separation study, but also for a cost benefit study of pavements incorporating geosynthetic interlayers. We are taking this approach because of conversations our team has had with Chairman John Mica and the staff of the House Transportation Committee—and our separation study initiative reflects the new Chairman’s priorities for the 112^th Congress.

The chairman has indicated that the focus of the transportation bill will be finding ways to get more benefit for dollars spent. This means there will be a greater focus on maintenance of roadways.

We will be working with congressional staff to design a request that will have the best chance of success. We will also need the support of the people on this committee and the friends of the committee. In the next few weeks we will be hosting a conference call, and that time we can discuss the particular details of our proposal and field more specific questions. However, both the separation piece and the interlayer piece reflect the past research needs statements made by this committee.

GMA also encourages this committee to continue efforts through TRB/AASHTO process to secure funding for your research needs. At the same time we will be pursuing a parallel track to secure funding through congress.

We look forward to working with all of you in this effort. In the near future, please look for an invitation to join our conference call to discuss the details of our proposal. Mr. Chairman, thank you for the opportunity to share with the committee.

Ron Bygness is the editor of Geosynthetics. Andrew Aho is the managing director of the Geosynthetic Materials Association.

FROM: Kemp Partners / Whitmer & Worrall (KPWW)

SUBJECT: 2010 Election Briefing

DATE: 11/10/10 2010 Election Briefing

This document is intended to provide a snapshot of the Congressional elections that took place Nov. 2, 2010. It also provides insight into changes that will be taking place in relevant Congressional committees and insight into upcoming legislative initiatives for the 112th Congress.

House Transportation & Infrastructure Committee / Senate Environment & Public Works Committee

As the leadership of the Transportation and Infrastructure Committee changes, the Committee’s top priority of passing a surface transportation reauthorization bill will remain unchanged. At the same time, the likely chairman of the Republican-led panel, John L. Mica of Florida, is expected to propose a transportation policy that differs in important ways from the draft produced in 2009 by current Chairman James L. Oberstar (D-Minn.).

On the Senate side there will likely be no change in the leadership. We expect that Sen. Barbara Boxer (D-Calif.) will continue as Chairman and Sen. James Inhofe (R-Okla.) as Ranking Member. These committees will be working to complete a new transportation reauthorization bill and Water Resources Development Act (WRDA) in the new Congress.

Coal Ash

Currently, the EPA comment period for the proposed coal ash regulation—HAZARDOUS AND SOLID WASTE MANAGEMENT SYSTEM; IDENTIFICATION AND LISTING OF SPECIAL WASTES; DISPOSAL OF COAL COMBUSTION RESIDUALS FROM ELECTRIC UTILITIES—is open through Nov. 19, 2010. It is projected that a final decision on the regulation may not come for at least one year after the comment period has closed.

We believe that if a non-hazardous designation is chosen, [then] Congress and its new Republican majority in the House will not force the EPA’s hand to make any changes to, or repeal, the ruling. Should the EPA classify coal ash a hazardous material we believe Congress will react negatively and plot a course to reverse the decision. GMA has currently positioned itself very well for this issue through constant communication with Capitol Hill, a signed letter from three Members of Congress to EPA Administrator Lisa Jackson highlighting the value of geosynthetics related to this issue, and official comments submitted to the EPA regarding the proposed regulation. As the new Congress convenes and committee assignments are distributed, GMA will immediately work to educate new Members of Congress on the issue, GMA’s role to-date related to the issue, and its importance to the geosynthetic industry.

2012 Farm Bill

The “Farm Bill” is the major agricultural and food policy tool of the federal government. The current Farm Bill—the Food, Conservation, and Energy Act of 2008—is set to expire in 2012. In an attempt to avoid the delays in passage that have characterized consideration of previous Farm Bills, Representative Collin Peterson (D-Minn.), Chairman of the House Committee on Agriculture, began work early on the legislation, starting this past spring with a series of “listening sessions” across the country to take the pulse of stakeholders. The Senate also began hearings early in the summer in preparation for the 2012 Farm Bill. Representative Frank Lucas (R-Okla.) is expected to assume the chairmanship of the House Agriculture Committee. Although the Democrats retained control of the Senate, the Senate Agriculture Committee will also have new leadership, as Sen. Blanche Lincoln (D-Ark.) was defeated by Republican John Boozman. Senator Debbie Stabenow (D-Mich.) is viewed as the likely successor as Chairman. Consideration of the bill is expected to start shortly after the 112th Congress convenes.

Updated by Ron Bygness, editor of Geosynthetics magazine, and Andrew Aho, executive director of the Geosynthetic Materials Association (GMA).

September 29, 2010

Mr. Steven Souders
Office of Resource Conservation and Recovery
United States Environmental Protection Agency
5304P
Washington, DC 20460

40 CFR Parts 257, 261, 264 et al.
Hazardous and Solid Waste Management System; Identification and Listing of Special Wastes; Disposal of Coal Combustion Residuals From Electric Utilities; Proposed Rule Docket ID No. EPA-HQ-RCRA-2009-0640

Additional information on Environmental Protection and Structural Integrity with Geosynthetic Systems

Introduction

In response to the recent publication of the Notice of Proposed Rule Making Hazardous and Solid Waste Management System; Identification and Listing of Special Wastes; Disposal of Coal Combustion Residuals From Electric Utilities; Proposed Rule, related to the care, separation and storage of coal combustion residuals (CCRs) GMA offers the following additional comments and information (including attached appendices):

GMA again compliments the EPA for the statements and inclination to require geosynthetic lined facilities designed to protect the groundwater from potential contamination. GMA again recommends that the regulations put forth require the use of a composite liner system (geomembrane and geosynthetic clay liner) as this system has been demonstrated (by EPA) to be the most effective barrier methodology, regardless of the classification of the materials (hazardous, non-hazardous or designated for beneficial re-use). This submittal supplements the previous GMA submission dated August 12, 2010 and contains additional references to EPA reports and studies as well as test data generated, using EPA protocols that support the effectiveness of composite liner systems and their components.

Statement of EPA request(s)

In 75 FR 35202, EPA solicits comment on whether the Subtitle D (i.e., municipal solid waste) option should allow facilities to use an alternative design for new disposal units, so long as the owner or operator demonstrates that CCR constituent concentrations are not exceeded at the relevant point of compliance. Additionally, in 75 FR 35203, EPA states interest in receiving data and information that demonstrates whether an alternative liner would be equally protective. Similarly, in 75 FR 35175 and 75 FR 35222, EPA solicits comment with supporting information and data on whether the Subtitle C option should also provide for alternative liner designs based on a specific performance standard. The prescriptive liner system under Subtitle D (40 CFR Part 258) is a composite liner with two components: an upper component consisting of a minimum 30-mil flexible membrane liner (FML, also commonly called a geomembrane), and a lower component consisting of at least a two-foot layer of compacted soil with a hydraulic conductivity of no more than 1 x 10-7 cm/sec. Although the existing Part 40 CFR Part 258.40(a)(1) requirements allow for alternative liner demonstrations, EPA expresses reluctance in allowing alternative liners for new CCR facilities in 75 FR 35203.

Respondent comments

GMA would like to ensure that EPA is aware of all pertinent information related to the effective use of geosynthetic materials for waste containment The Geosynthetic Institute (Drs. Robert and George Koerner, Folsom, PA) website contains an index of the U.S. EPA documents that are related to the use of geosynthetics. The complete list is attached as Appendix “C” a link to the webpage is here: www.geosynthetic-institute.org/epa.html. Clearly, geosynthetic materials have been well examined and proven to be effective.

In 75 FR 35202, EPA solicits comment on whether the Subtitle D (i.e., municipal solid waste) option should allow facilities to use an alternative design for new disposal units, so long as the owner or operator demonstrates that CCR constituent concentrations are not exceeded at the relevant point of compliance. Additionally, in 75 FR 35203, EPA states interest in receiving data and information that demonstrates whether an alternative liner would be equally protective. Similarly, in 75 FR 35175 and 75 FR 35222, EPA solicits comment with supporting information and data on whether the Subtitle C option should also provide for alternative liner designs based on a specific performance standard. GMA would like to state our concurrence with the opinions and information previously supplied to the EPA docket by CETCO Lining Technologies. In the interest of brevity, GMA does not re-supply the technical reference materials listed in that document. However, based on the technical information presented therein, GMA recommends that the USEPA CCR Disposal Proposed Rule for either the proposed Subtitle C and Subtitle D Regulation option be revised to define a ‘composite liner’ as consisting of two components: An upper component consisting of a minimum 30-mil flexible membrane liner (FML), and a lower component consisting of either at least a two-foot layer of compacted soil with a hydraulic conductivity of no more than 1 x 10-7 cm/s, or a geosynthetic clay liner (GCL) containing at least 0.75 lb/ft² of sodium bentonite. If ‘composite liner’ is not redefined to include a lower component GCL, then the allowance of an alternative liner design/system should be included.

EPA 9090 testing is a historically important testing protocol that was developed to demonstrate the chemical resistance of geosynthetic materials. EPA document EPA/600/S2-90/041 (Appendix “D”) outlines the application of this testing protocol. Appendices “E, F, G, H and I” demonstrate the excellent performance of specific geosynthetic materials.

Conclusion

The benefits and successes of utilizing geosynthetic barriers in containment systems has been well documented by the technical materials supplied by GMA previously and further referenced here. Geosynthetics have been tested and successfully evaluated in great detail over a long period of use in a very wide range of applications by EPA.

GMA recommends that the US EPA CCR Disposal Proposed Rule for either of the Subtitle C and/or Subtitle D Regulation options define and require a ‘composite liner’ consisting of two components: An upper component consisting of a minimum 30-mil flexible membrane liner (FML), and a lower component consisting of a geosynthetic clay liner containing at least 0.75 lb/ft² of sodium bentonite. If ‘composite liner’ is not redefined to include a lower component GCL, then the allowance of an alternative liner design/system should be included.

GMA thanks EPA for the consideration provided. GMA, the respective member companies and their staffs are more than willing to respond to any additional EPA inquiry on this or other related topics.

Sincerely,

Andrew M. Aho
Managing Director
Geosynthetic Materials Association
Industrial Fabrics Association International
1801 County Road B West
Roseville, MN 55113-4061

John Henderson
Chairman: Executive Council
Geosynthetic Materials Association
TenCate Geosynthetics N. A.
365 South Holland Drive
Pendergrass, GA 30567

Instruction to access the full GMA comments and attachments

1. Go to www.regulations.gov
2. Type “geosynthetic materials association” in the Enter Keyword or ID field
3. Click on the first search result ID: EPA-HQ-RCA-2009-0640-4033 ; Comment submitted by Andrew M. Aho, Managing Director and John Henderson, Chairman, Executive Council, Geosynthetic Materials Association (GMA)
4. Click on primary letter to EPA and supporting documents (attachments)

As hearings continued through September 2010, the U.S. Environmental Protection Agency (EPA) seeks comments regarding the regulation of coal ash containment sites. The Geosynthetic Materials Association (GMA) was among the first in line to address the issue Aug. 30 at the initial hearing in Arlington, Va.

The major issue in the proposed EPA regulations concerns how coal ash should be classified—as solid waste just as household garbage is regulated or as hazardous waste.

GMA has long maintained a position that coal combustion residuals (CCRs) could be safely contained as solid waste and that a designation as hazardous waste would be overkill. However, regardless of the designation the EPA makes, it is clear that through advocacy efforts by GMA and others, the use of liners will be required in the disposal of coal ash waste.

GMA’s comments regarding the coal ash disposal regulations were prepared for the EPA’s seven public hearings around the country in August and September. The EPA’s hearings were scheduled in Arlington, Va., Denver, Dallas, Charlotte, Chicago, Pittsburgh, and Louisville. In addition to the Aug. 30 Arlington hearing, GMA members planned comments at public hearings in Denver on Sept. 2, Dallas Sept. 8, Charlotte Sept. 14, Chicago Sept. 16, Pittsburgh Sept. 21, and Louisville on Sept. 28.

In addition, GMA has posted several written comments on this issue. (The complete set of GMA’s comments can be found at: http://geosyntheticsmagazine.com/news/gmaupdate)

In addition to the public hearings and written comments, GMA bolsters support for geosynthetic lining of coal ash sites during Capitol Hill meetings with U.S. House and Senate staffs during GMA’s Lobby Day activities Sept. 15.

Following are the comments made by GMA members during the Aug. 30 EPA hearing in Arlington, just outside Washington, D.C.:

Today I am representing the Geosynthetic Materials Association, the trade group of 80 companies that manufacture, distribute and install geosynthetic materials, including liners systems. The industry employs 12,000 people throughout the United States.

Our comment to EPA is very simple. We request that EPA mandate the geosynthetic lining of coal ash storage facilities using composite lining systems. In the shortest terms, use liners, specifically composite liners.

Why? Because liners work. Concerns of safety regarding CCRs are mitigated if the landfill storage sites are lined with a composite liner system of a geomembrane and a geosynthetic clay liner. A composite liner system prevents the leachate from entering the environment. Safety concerns regarding surface impoundments are also mitigated if the impoundments are lined with a composite liner system.

The American Society of Civil Engineers does a regular “Report Card on America’s Infrastructure.”For the last three report cards, representing over a decade, solid waste has received the highest grade of any category. My industry does a good job of taking America’s waste and properly storing it to protect the environment. The materials, technology and people exist [now]—the engineers, engineering techniques and standards, the general contractors and installers who can build the proper facilities and the regulators and inspectors who assure the work is done correctly. We urge EPA to “use what exists and is working today.”

Further, our industry has continuously improved over time and EPA has been a part of that effort. Over the years, EPA has commissioned nearly 80 studies of the design and performance of lining systems. We specifically call your attention to a 2002 study titled “Assessment and Recommendations for Optimal Performance of Waste Containment Systems” (EPA 600/R-02/099). That study contains a great deal of pertinent information on how to construct containment systems. Most illustrative for today is a graph charting the leakage rate of different designs over the life cycle of nearly 200 facilities. The composite liner system of a geomembrane and a geosynthetic clay liner was demonstrated to have the lowest leakage rate over all life cycle stages, including a near zero leakage rate after the facilities are closed and final cover placed. Our materials work.

Use of composite liner systems will achieve the EPA mission to protect human health and the environment for all Americans.

A brief word on the hazardous/non-hazardous question. While coal ash does contain heavy metals, it lacks the traditional characteristics of hazardous materials, radioactivity or the presence of infectious medical waste, etc. In the opinion of our trade organization, coal ash can be properly stored using subtitle “D” regulations, a non-hazardous solid waste designation with composite liner systems.

Thank you.

Chart courtesy of the Geosynthetic Research Institute (GRI) at Drexel University.

Waste disposal sites in the U.S.—199 total—with a variety of designs and materials were examined. The survey population included sites at different phases of the site lifespan as indicated on the “X” axis. The site leakage (collection) rate was plotted on the “Y” axis for the three types of liner design: yellow–geomembrane alone, greengeomembrane and compacted clay, red–a geomembrane and GCL (geosynthetic clay liner) composite liner system.

The key point is the optimal performance of the composite liner system(s), including a near zero leakage rate for the closed (“After Final Cover”) site.

Data Source: Bonaparte, Daniel, and Koerner. (2002) “Assessment and Recommendations for Optimal Performance of Waste Containment Systems,” EPA/600/R-02/099. U. S. EPA, ORD, Cincinnati, OH