&EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication: 9345.3-03FS
April 1992
Guide to Management of
Investigation-Derived Wastes
Office of Emergency and Remedial Response
Hazardous Site Control Division OS-220W
Quick Reference Fact Sheet
CERCLA field investigation activities (e.g., remedial investigation/feasibility studies and remedial designs) may result in the generation of
waste materials that may pose a risk to human health and the environment. These investigation-derived wastes (IDW) may include drilling muds,
cuttings, and purge water from test pit and well installation; purge water, soil, and other materials from collection of samples; residues (e.g., ash,
spent carbon, well development purge water) from testing of treatment technologies and pump and treat systems; contaminated personal
protective equipment (PPE); and solutions (aqueous or otherwise) used to decontaminate non-disposable protective clothing and equipment.
The management of IDW must ensure protection of human health and the environment and comply with (or waive) regulatory requirements
that are applicable or relevant and appropriate requirements (ARAR). This fact sheet presents an overview of possible IDW management
options, discusses the protectiveness requirements and ARARs associated with these options, and outlines general objectives established for
IDVV management under Superfund.1
The general options for managing IDW (see Highlight 1) are
collection and either (1) immediate disposal or (2) some type of
interim management. Interim management may include storage or
other temporary measures. As discussed below, the specific option
selected will depend on the type of waste produced, its relative
threat to human health and the environment, and other site-specific
conditions.
IDW MANAGEMENT REQUIREMENTS
When managing IDW, site managers are required to choose an
option that: (1) is protective of human health and the environment
and (2) complies with (or waives) ARARs, as described below.
Protectiveness
In determining if a particular management/disposal option is
protective, site managers should consider the following:
• The contaminants, their concentrations, and total volume of
IDW;
• Media potentially affected (e.g., ground water, soil) under
management options;
• Location of the nearest population(s) and the likelihood and/or
degree of site access;
1 Management of treatability study and treatment pilot wastes is
discussed in Guide for Conducting Treatabilitv Studies Under
CERCLA. Interim Final, December 1989, EPA/540/2-89/058.
Information on management of IDW generated during
Preliminary Assessments and Site Investigations is provided in
Management of Investigation-Derived Waste During Site
Investigations. May 1990, EPA/540/G-91/009.
• Potential exposures to workers; and
• Potential for environmental impacts.
As a general rule, it will be necessary to use best professional
judgment, in light of the site-specific conditions, to determine
whether an option is protective of human health and the
environment. For example, a site manager may determine that
storing IDW temporarily until the final action or returning IDW to
its source is protective, based on knowledge that the material poses
low risk and/or that the final action will address any risks posed by
the wastes and there will be no unacceptable risks in the interim.
Alternatively, if the site includes or is near residential areas, the
site is unsecured, and/or contaminants appear to be present at
unacceptable levels, it may not be protective to return excavated
soil to the source. Storing IDW in containers in an on-site, secure
location, or sending it off site immediately may be more
appropriate.
Site managers also need to consider the potential effects of
IDW management-related activities on environmental media. For
example, pouring contaminated purge water on the ground around
a well may not be prudent, because such an action could mobilize
any hazardous constituents present in the soil or introduce
contaminants into clean soil.
Compliance with ARARs
Remedial Investigation/Feasibility Study (RI/FS) and Remedial
Design (RD) actions must comply with ARARs "to the extent
practicable, considering the exigencies of the situation" (NCP, 55
FR 8756, emphasis added); therefore, it generally will not be
necessary to obtain a waiver if an ARAR cannot be attained during
these actions. If a site manager determines that, based on site-
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Highlight 1: IDW MANAGEMENT OPTIONS
Type of IDW
Soil
Generation Processes*
• Well/test pit installation
• Boreholç drilling
• Soil sampling
Mana2ement Options
• Return to boring, pit, or
source immediately after
generation
• Spread around boring, pit, or
source within the AOC
• Consolidate in a pit (within
the AOC)
• Send to on-site TDU
• Send to TDU off site
immediately
• Store for future treatment
and/or disposal
Sludges/sediment
Sludge pit/sediment sampling
• Return to boring, pit, or
source immediately after
generation
• Send to on-site TDU
• Send to TDU off site
immediately
• Store for future treatment
and/or disposal
Aqueous liquids (ground water,
surface water, drilling fluids, other
wastewaters)
• Well installation/development
• Well purging during sampling
• Ground water discharge
during pump tests
• Surface water sampling
• Discharge to surface water
• Pour onto ground close to
well (non-hazardOus waste)
• Send to on-site TDU
• Send to off-site commercial
treatment unit
• SendtoPOTW’
• Store for future treatment
and/or disposal
Decontamination fluids
• Decontamination of PPE
and equipment
• Send to on-site TDU
• Evaporate (for small amounts
of low contnminz tion organic
fluids)
• SendtoTDUoffsite
Immediately
• Store for future treatment
and/or —
Disposable PPE
• Sampling procedures or other
on-site activities
• Send to on-site TDU
• Place In on-site industrial
dumpster
• SendtoTDUOffsite
immediately
• Store for future treatment
and/or disposal
* The generation processes listed here are provided as examples. IDW may also be produced as a result of activities not
listed here.
+ Q : Area of Contamination (AOCs at a site may not yet have been identified at the time of the RiIFS); TDU:
Treatment/disposal Unit; POTW : Publicly Owned Treatment Works; PPE Personal Protective Equipment
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specific factors, compliance with an ARAR is practicable but an
ARAR waiver is warranted for an RI/FS or RD action, an interim
action waiver may be available if the final remedy will attain the
ARAR. An action memorandum should be prepared for the
waiver, the state given an opportunity to comment, and the decision
document placed in the administrative record.
Potential ARARs for IDW at CERCIA sites include
regulations under the Resource Conservation and Recovery Act
(RCRA) (including both Federal and State underground injection
control (UIC) regulations), the clean Water Act (CWA), the Clean
Air Act (CAA), the Toxic Substances Control Act (TSCA), and
other State environmental laws. How these various requirements
may direct or influence IDW management decisions is described
below.
Resource Conservation and Recovery Act (RCRA). Certain
sections of the RCRA Subtitle C hazardous waste regulations (e.g.,
land disposal restrictions and storage restrictions) may be ARARs
for IDW should RCRA hazardous waste be identified at a site.
(Note that RCRA may be relevant and appropriate even if the
IDW is not a RCRA hazardous waste.) A waste is hazardous
under RCRA if it is listed as such in 40 CFR 261.31 - 261.33 or if
it exhibits one of four characteristics : ignitability, corrosivity,
reactivity, or toxicity.
Site managers should not assume that a waste considered to
pose a potential risk at a CERCLA site is a listed or characteristic
RCRA hazardous waste. Until there La positive evidence (records,
test results, other knowledge of waste properties) that the IDW Is
a RCRA hazardous waste, site managers should manage it in a
protective manner (hut not necessarily in accordance with Subtitle
C requirements). Business records or facility processes should be
examined to determine whether RCRA fisted wastes were
generated and are present in the IDW. For characteristic wastes,
site managers should rely on testing results or on knowledge of the
material’s properties. If best professional judgment and available
information indicate that, for protectiveness reasons (or because
RCRA requirements are relevant and appropriate), IDW is best
managed as a “hazardous waste,” management in accordance with
Subtitle C requirements is prudent, regardless of whether it is
known to be a RCRA waste.
If aqueous liquid IDW is considered a RCRA hazardous waste,
the site manager should determine whether the Domestic Sewage
Exclusion (DSE) applies to the discharge of that IDW to a POTW.
The RCRA DSE exempts domestic sewage and any mixture of
domestic sewage and other wastes that passes through a sewer
system to a POTW for treatment from classification as a solid waste
and, therefore, as a RCRA hazardous waste (40 CFR 261.4).
Land Disposal Restrictions
If IDW is determined to be a RCRA hazardous waste and
subject to the land disposal restrictions (LDRs), “land disposal” of
the IDW will be prohibited unless specified treatment standards are
met (see Superfurid LDR Guides #5 and #7, Determining When
LDRs Are Applicable to CERCLA ponse Actions and
Determining When LDRs Are Relevant and Appropriate to
CERCLA Response Actions , OSWER Directive 93473. .O5FS and
9347.3-O8FS, June 1989 and December 1989 and the NCP, 55 FR
8759, March 8, 1990). “Land disposal” occurs when wastes from
different AOCs are consolidated into one AOC; when wastes are
moved outside an AOC (for treatment or storage) and returned to
the same or a different AOC; or when wastes are excavated, placed
in a separate hazardous waste management unit such as an
incinerator or tank within the AOC, and then redeposited into the
AOC.
Storing IDW in a container (“a portable device in which a
material Is stored, transported, treated, disposed of, or otherwise
handled” (40 CFR 260.10)) within the AOC and then returning It
to its source, however, j allowable without meeting the specified
LDR treatment standards, Under the definition of “hazardous
waste management unit” (40 CFR 260.10), EPA states that “a
container alone does not constitute a unit; the unit includes the
containers and the land or pad upon which they are placed.”
Therefore, returning IDW that has been stored in containers (not
tanks or other RCRA-regulated units) within the AOC to its source
does not constitute land disposal, as Long as containers are not
managed in such a manner as to constitute a RCRA storage unit
as defined in 40 CFR 260.10. In addition, sampling and direct
replacement of wastes within an AOC do constitute land
disposal.
• Storage
Subtitle C outlines the storage requirements for RCRA
hazardous wastes. Under RCRA, “storage” is defined as “the
holding of hazardous waste for a temporary period, at the end of
which the hazardous waste is treated, disposed of, or stored
elsewhere” (40 CFR 260.10).
On-site Superfund actions are only required to comply with the
substantive standards of other laws (see 40 CFR 300.5, definitions
of applicable or relevant and appropriate requirements). Superfund
sites are also exempt from permit requirements under CERCLA
§ 121(e). Therefore, site managers are not required to comply with
administrative requirements triggered by RCRA storage deadlines
(e.g., contingency planning, inspections, recordkeeping). Generally
equivalent administrative activities are undertaken at Superfund
sites, however, under existing Superfund management practices.
Site managers storing known RCRA hazardous waste must
comply with the substantive, technical requirements of 40 CFR
Parts 264 and 265 Subparts I (containers), J (tanks), and L (waste
piles), to the extent practicable. (See Highlight 2 for a summary
of these technical requirements for each type of unit). In addition,
the ground-water monitoring requirements of 40 CFR Parts 264
and 265 Subpart F are potential ARARs, and to the extent they are
determined to be ARARs at a site, they should be attained to the
extent practicable (or waived). (In many cases, ground-water
monitoring conducted during the RI/FS will provide protection
equivalent to the Subpart F requirements.)
[ NOTE Under the LDRS, restricted RCRA hazardous waste
may not be stored at a site unless the storage is solely for the
purpose of accumulating sufficient quantities of the waste to
facilitate proper disposal, treatment, or recovery (see 40 CFR
26830). Generally, storing IDW until a final disposal option Is
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selected in a Record of Decision (ROD) and implemented during
the remedial action is allowable storage under the RCRA LDR
storage prohibition.]
Recordkeepjng and Manifestij g
If hazardous wastes are sent off site, the site manager must
comply with both administrative and substantive elements of the
RCRA generator requirements of 40 CFR Part 262 and LDR
notification and certification requirements of Part 268. (For
example, a site manager must prepare an LDR notification and
certificaiion when restricted wastes are sent off site to a land
disposal facility.) These standards include requirements such as
manifests for shipping waste that list hazardous waste listing and
characteristics applicable to the waste (see 40 CFR 262.11),
packaging and transport requirements, and recordkeeping
requirements.
If the LI)Rs are applicable, the following information should be
collected and available before the removal of wastes to an off-site
disposal lacility: EPA hazardous waste number, LDR treatment
standards, manifest number for the waste shipment, and waste
analysis data.
Underground Injection Control (UIC) Program
Under the Uic regulations, RCRA hazardous wastes may be
injected into Class I permitted wells. In some cases, hazardous
liquids, such as extracted ground water from pump and treat
operations, may be injected into a Class IV UIC well. For example,
ground water contaminated with RCRA hazardous wastes may be
injected into Class IV permitted wells if it is part of a CERCLA
response action or a RCRA corrective action and if it has been
treated to “substantially reduce hazardous constituents prior to such
injection...” (RCRA § 3020(b)). (See Applicability of Land
Disposal Restrictions to RCRA and CERCLA Ground Water
Treatment Reinjection , OSWER Directive #9234,1-06, December
1989.)
Non-RCRA Hazardous Wastes
Some non-RCRA hazardous waste may be subject to
management requirements under Subtitle D of RCRA as solid
wastes. Subtitle D regulates disposal of solid waste in facilities such
as municipal landfills. Therefore, non-RCRA hazardous IDW, such
as decontaminated PPE or equipment, may need to be disposed of
in a Subtitle D facility (depending on State requirements).
Clean Water Act (CWA). Discharges of aqueous IDW to surface
water and publicly owned treatment works (POTWs) may be
required to comply with CWA Federal, State, and local
requirements. Requirements to be met may include water quality
criteria, pre-treatment standards, State water quality standards, and
NPDES permit conditions. Direct discharges to on-site waters are
subject only to substantive requirements, while discharges to
POTWs and other off-site discharges must comply with both
substantive and administrative CWA requirements (including
permitting requirements). (See Guide to Discharging CERCIA
Aqueous Wastes to POTWs , June 1991 and CERCLA Compliance
with the CWA and SDWA , #9234.2-O6FS, January 1991.)
Toxic Substances Control Act (TSCA). If IDW contains Pc&,
TSCA treatment and/or disposal requirements may apply during its
management. ThCA requirements regulate the disposal of material
contaminated with PCBs at concentrations of 50 ppm or greater as
found on site (i.e., based on sample analysis and not the PCB
concentration of the source material {e.g., transformer fluid}).
(See PCB Guidance Manual , EPAJS44J/G-90/007, August 1990.) In
addition, TSCA storage requirements may apply that limit the time
that PCBs may be stored to one year. Furthermore, if PCB
materials are mixed with a RCRA hazardous waste, they may be
regulated by the LDR California list prohibitions. (See RCRA
sections 3004(d)(2)(D) and (E).)
Department of Transportation (DOT) requirements. Where IDW
will be disposed of off site or transported on public roads to a site,
highlight 2:
EXAMPLES OF RCRA TECHNICAL STORAGE
REQUIREMENTS
RCRA storage requirements, applicable to both less-than-
90-days generators and permitted or interim status storage
facilities, may include the following substantive requirements:
Containers 40 CFR 264 Subpart I and 265 Subpart I
• Containers must be in good condition
• Wastes must be compatible with container
• Container must be closed during storage
• Container storage areas must have a containment
system that can contain 10 percent of the volume of
containers or of the largest container
• Spilled or leaked waste must be removed from the
collection area as necessary to prevent overflow
Tanks 40 CFR 264 Subpart J and 265 Subpart J
• Tanks must have a secondary containment system that
includes a liner, a vault, a double.walled tank, or an
equivalent device (applies only to certain tanks)
Waste Piles 40 CFR 264 Subpart L and 265 Subpart L
• Waste piles must have a liner and a leachate collection
and removal system
• Owners/operators must have a run-on control system
to prevent flow onto the active portion of the pile
during peak discharge from at least a 25-year storm
• Owners/operators must have a run-off management
system to collect and control at least the water volume
resulting from a 24-hour, 25-year storm
* This is a partial list of substantive requirements. For
more detail, see 40 CFR Part 264 and 265.
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DOT requirements for containerizing, labeling, and transporting
hazardous materials and substances may apply.
State requirements. Promulgated State regulations that are legally
enforceable, timely identified, and more stringent than Federal
regulations may be potential ARARs for IDW managed on site.
Substantive requirements of State law that may be ARARs for
IDW management include State water quality standards, direct
discharge limits, and RCRA requirements (including underground
injection control regulations) promulgated in a State with an
authorized RCRA hazardous waste management program (as well
as programs authorized by State laws). Off-site, substantive and
administrative requirements of State law may apply.
Off-Site Policy. In addition to complying with requirements of
Federal and State laws, all off-site disposal of wastes must comply
with CERCLA section 121(d)(3) and the CERCLA Off-Site Policy
(OSWER Directive No. 9834.11 (November 13, 1987)). The Off-
Site Policy establishes criteria for selecting an appropriate
treatment, storage, or disposal facility (TSDF), including release
criteria for all facilities that receive wastes from CERCI.A-
authorized or funded response actions. In addition, receiving
facilities must be in compliance with all “applicable laws.”
Before shipping wastes off site, approval should be obtained for
the proposed disposal facility from EPA’s Regional Off-Site Policy
Coordinator. In addition, EPA has adopted a policy for Superfund
wastes shipped out of State that written notification should be
provided to receiving States (OSWER Directive 9330.2-07,
September 14, 1989).
GENERAL OBJECTIVES FOR IDW MANAGEMENT
In addition to the two requirements of protectiveness and
compliance with ARAR5 to the extent practicable (on site) or
compliance with applicable law (off site), EPA has identified two
general objectives that Superfund site managers should consider
when managing IDW: (1) minimization of IDW generation; and
(2) management of IDW consistent with the final remedy for the
site. The extent to which these objectives can be achieved is highly
dependent on site-specific circumstances.
JDW MInimization
Site managers should strive to minimize the generation of IDW
to reduce the need for special storage or disposal requirements’that
may result in substantial additional costs yet provide little or no
reduction in site risks relative to the final remedial action.
Generation of IDW can be minimized through proper planning of
all remedial activities that may generate IDW, as well as through
use of screening information from the site inspection. The potential
problems of managing IDW should be a factor in choosing an
investigative method. Site managers may wish to consider
techniques such as replacing solvent-based cleaners with aqueous-
based cleaners for decontamination of equipment, reuse of
equipment (where it can be decontaminated), limitation of traffic
between clean and hot zones, and drilling methods and sampling
techniques that generate little waste. Examples of such techniques
include using gridding techniques to minimize the number of test
pits or using soil borings instead of test pits. Alternative drilling
and subsurface sampling methods may include the use of small
diameter boreholes, as well as borehole testing methods such as a
core penetrometer instead of coring. Site managers should also be
careful to keep hazardous wastes separate from nonhazardous
wastes.
Mana2ement Consistent with Final Remedy
Most IDW (with the exception of non-indigenous IDW)
generated during the course of an investigation are intrinsic
elements of the site. If possible, IDW should be considered part of
the site and should be managed with other wastes from the site,
consistent with the final remedy. This will avoid the need for
separate treatment and/or disposal arrangements.
Because early planning for IDW management can prevent
unnecessary costs and the use of treatment or disposal capacity,
IDW management should be considered as early as possible during
the remedial process. A key decision to be made is whether the
waste will best be treated/disposed of immediately or addressed with
the final remedy. If addressed with the final remedy, IDW volumes
should be considered in the FS. In addition, when IDW is stored
on site, it should be managed as part of the first remedial
action/operable unit that addresses the affected media.
SELECTION OF IDW DISPOSAL OPTIONS
The following sections present the Agency’s presumptions for
IDW management that have been established based on the above
considerations. The actual option selected should be based upon
best professional judgment and should take into account the
following factors:
• The type and quantity of IDW generated (sludge/soil, aqueous
liquid, non-indigenous IDW);
• Risk posed by managing the IDW on site (e.g., based on site
access controls, contaminant concentrations);
• Compliance with ARARs, to the extent practicable (on site);
• !DW minimization; and
• Whether the final remedy is anticipated to be an off-site or on-
site remedy (or this information is unknown) and whether IDW
can be managed consistent with the final remedy.
Off-sIte Final Remedies
If a site manager believes that the final remedy will involve off-
site disposal of wastes, EPA’s presumption is to manage the IDW
as part of the remedial action addressing the waste/medium. Thus,
until the final action, the IDW may be stored (e.g., drummed,
covered waste pile) or returned to its source. However, the
management option selected should also take into account any
protectiveness concerns, ARARs, and other relevant site-specific
factors (e.g., weather, storage space, and public concernj
perceptions).
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There are several potential reasons why it may be advisable to
store IDW until the final action. First, because wastes at the site
will be shipped off site eventually, returning IDW (especially sludges
and soil) to its source would require that it be excavated again.
Thus, site managers may consider it practical to containerize IDW
as soon as it is generated. Second, storing IDW in containers may
be more protective than returning it to its source. Third, because
off-site actions may trigger such requirements as the LDRs,
temporary storage will eliminate the need to meet these additional
requirements until the final remedy.
In some cases, circumstances may lead site managers to choose
to return the IDW to its source. This may be appropriate if it is
determined that returning IDW to the source is protective and that
storage at the site is not possible or practicable (i.e., given State or
community concerns). In other cases, long-term storage may not
be protective, and immediate off-site disposal may be a better
option.
vary from the presumption based on protectiveness, ARARs, and/or
community concerns.
Aqueous liquids
On-site Final Remedies (or Final Management in an Unknown
Location
When final management of wastes is likely to occur on site, the
management presumptions vary depending on the type of IDW
produced.
Sludge/soIl
Generally, the Agency expects sludge or soil IDW will be
returned to its source if short-term protectiveness is not an issue.
The reason behind this presumption is that IDW that may pose a
risk to human health and the environment in the long term will be
addressed by the final action. Storage of RCRA hazardous lOW
In containers within the AOC prior to returning It to the source
will not trigger the LDRs, as long as the contaIners are not
managed In such a way as to constitute a RCRA storage unit as
defined in 40 CFR 260.10. Therefore, it may be possible to store
IDW temporarily before redisposing of it. However, EPA believes
that, in many cases, returning sludges and soils to their source
immediately will be protective and will avoid potentially increased
costs and requirements associated with storage. Site-specific
decisions on how to manage sludge and soil IDW may ultimately
EPA has not established a presumption for the management of
aqueous liquid IDW (e.g., ground water). Site managers should
determine the most appropriate disposal option for aqueous liquids
on a site-specific basis. Parameters to consider, especially in
making the protectiveness decision, include the volume of IDW, the
contaminants present in the ground water, the presence of
contaminants in the soil at the site, whether the ground or surface
water is a drinking water supply, and whether the ground-water
plume is contained or moving. Special disposal/handling may be
needed for drilling fluids because they may contain significant solid
components. Examples of aqueous liquid management decisions
considering these factors are presented in the box on the next page.
Non-Indigenous lOW
Non-indigenous IDW (e.g., sampling materials, disposable PPE,
decontamination fluids) should be stored until the final remedy or
disposed of immediately. If contaminated, such waste may not be
disposed of onto the ground because such an action would add
contamination that was not present when activities began at the site
(e.g., solvents used for decontamination). If non-indigenous IDW
is contaminated with RCRA hazardous waste, it must be managed
in accordance with RCRA Subtitle C requirements. Otherwise, site
Sludge/Soil
Example 1 : The soil at a site contains wastes that are
expected to be stabilized on site during the final remedial
action. The site manager determines that sending soil IDW
off site is not cost-effective, because off-site disposal would
involve testing and transport costs for a relatively small
amount of waste. Instead, knowing that the site is secure
and that redisposing the waste at the source will not increase
site risk or violate ARARs, the site manager decides to
return soil IDW to the source area from which it originated.
Example 2 : A site manager determines that returning highly
contaminated PCB wastes to the ground at a site is not
protective because of the potential risks associated with the
material; instead, the site manager chooses to drum the
waste and send it off site (in compliance with TSCA). (Off-
site disposal may occur immediately or at a later date.)
Example 3 : Soil IDW contaminated with a RCRA
hazardous waste is generated from a soil boring. The site
manager decides to put the IDW back into the borehole
immediately after generation, but ensures that site risks will
not be increased (e.g., the contaminated soil will not be
replaced at a greater depth than where it was originally so
that it will not contaminate “clean” areas) and that the
contamination will be addressed in the final remedy.
Off .site Remedy
Example : A site involves volatile organic RCRA hazardous
wastes that will likely be sent off site for final treatment and
disposal. Site conditions are such that temporary storage of
IDW is considered protective until the remedial action
begins. Because off-site disposal will trigger RCRA disposal
requirements such as the LDRS and immediate
containerization would be more protective than redepositing
into the source area at the time of sampling, the site
manager decides to containerize the IDW (and comply with
RCRA substantive technical tank and container standards)
until the final action is initiated.
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Aqueous Liquids
Non-Indigenous IDW
managers may generally dispose of it in an on-site dumpster (for
PPE).
COMMUNITY CONCERNS
Residents of communities near a CERCLA site, local
governments, or States may have concerns about certain disposal
methods or long-term storage of IDW at the site. As with all
CERCLA activities, site managers should evaluate comn unity
concerns regarding disposal of IDW in deciding what action to take.
For example, if a community is concerned about the direct
discharge of IDW water to surface water on site, site managers may
want to consider sending the water to a POTW, if one is located
nearby. In some instances, it may be appropriate to prepare fact
sheets, include options in other community relations documents, or
explain IDW management decisions at public meetings prior to
actions.
Example 1 : Disposable PPE (e.g., gloves, shoe covers)
becomes contaminated with RCRA hazardous waste during the
field investigation. The site manager containerizes and disposes
of this IDW in compliance with RCRA Subtitle C
requirements.
Example 2 : Disposable equipment becomes contaminated
during a field investigation. The site manager decontaminates
them and sends them to a Subtitle D facility.
Example 1 : A site manager has large volumes of ground
water IDW and does not know if it is contaminated.
Pouring this IDW on the ground would not be protective,
because it may contaminate previously uncontaminated soil
or may mobilize contaminants that are present in the soil.
Therefore, the site manager stores the water in a mobile
tank until a determination is made as to whether the water
and soil are contaminated or until the final action.
Example 2 : IDW is generated from the sampling of
background, upgradient wells. Because there are no
community concerns or evidence of any soil contamination
from other sources, the site manager decides to pour this
presumably uncontaminated IDW on the ground around the
well.
Example 3 : Purge water from a deep aquifer is known to
be contaminated with a RCRA hazardous waste. At this
site, if this water were poured on the ground, it could
contaminate a previously uncontaminated shallow aquifer
that is a potential drinking water source and would have to
comply with the LDRs. The site manager decides to
containerize the water within the AOC and store it until the
final remedy.
NOTICE The policies set out in this memorandum are not final agency action, but are intended solely as guidance. They are not
intended, nor can they be relied upon, to create any rights enforceable by any party in litigation with the United States. EPA officials
may decide to follow the guidance provided in this memorandum, or to act at variance with the guidance, based on an wialysis of
specific site circumstances. The Agency also reserves the right to change this guidance any time without public notice.
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