g
\ ^Mr UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
JAN 151992
9345.3-03FS
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Guide to Management of Investigation-Derived Wastes
FROM: Henry L. Longest II, Director /s/
Office of Emergency and Remedial Response
TO: Waste Management Division Director
Regions I, IV, V, VII, VIII
Emergency and Remedial Response Division Director
Region II
Hazardous Waste Management Division Director
Regions III, VI
Toxics and Waste Management Division Director
Region IX
Hazardous Waste Division Director
Region X
The purpose of this memorandum is to distribute the final fact sheet
entitled "Guide to Management of Investigation-Derived Wastes." This fact
sheet was circulated for Regional review and comment in November 1991;
comments have been incorporated into this final version.
Additional copies of the fact sheet can be obtained from EPA's
Superfund Docket (FTS 260-3046) . If you have any questions regarding the
information in the fact sheet, please call your HSCD Regional Coordinator,
or Andrea McLaughlin at FTS 678-8365 or 703-308-8365.
Enclosure
cc: Superfund Branch Chiefs, Regions I-X
Superfund Section Chiefs, Regions I-X
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United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication: 9345.3-03FS
January 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 IDW 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. As dismissed 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.
row 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 populations) and the likelihood and/or
degree of site access;
• Potential exposures to workers; and
• Potential for environmental impacts.
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.
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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
temporary 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-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.
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Type of row
Soil
Highlight 1: IDW MANAGEMENT OPTIONS
Generation Processes* Management Options
Well/test pit installation
Borehole drilling
Soil sampling
Sludges/sediment
Sludge pit/sediment sampling
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
Decontamination fluids
Decontamination of PPE+ and
equipment
Disposable PPE
Sampling procedures or other on-
site activities
Return to boring, pit, or
source immediately after
generation
Spread around boring, pit, or
source within the AOC+
Consolidate in a pit (within
theAOC)
Send to on-site TDU+
Send to TDU off site
immediately
Store for future treatment
and/or disposal
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
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
Send to POTW+
Store for future treatment
and/or disposal
Send to on-site TDU
Evaporate (for small amounts
of low contamination organic
fluids)
Send to TDU off site
immediately
Store for future treatment
and/or disposal
Send to on-site TDU
Place in on-site industrial
dumpster
Send to TDU off site
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.
AOC: Area of Contamination (AOCs at a site may not yet have been identified at the time of the RI/FS); TDU:
Treatment/disposal Unit; POTW: Publicly Owned Treatment Works; PPE: Personal Protective Equipment
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Potential ARARs for IDW at CERCLA 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, ortoxicity.
Sitemanagers 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 is 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 (but not necessarily in accordance with Subtitle C
requirements). Business records or facility processes should be
examined to determine whether RCRA listed 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 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 Superfund LDR Guides #5 and #7. Determining When LDRs
Are Applicable to CERCLA Response Actions and Determining
When LDRs Are Relevant and Appropriate to CERCLA Response
Actions. OSWER Directive 9347.3-05FS and 9347.3-08FS, June
1989 and December 1989 andtheNCP, 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, is allowable without meeting the specified LDR
treatment standards. Under the definition of "hazardous waste
management until" (40 CFR 260.10), EPA states that "a container
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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 not constitute land disposal.
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
268.50). Generally, storing IDW until a final disposal option is
selected in a Record of Decision (ROD) and implemented during the
remedial action is allowable storage under the RCRA LDR storage
prohibition.]
• Recordkeeping and Manifesting
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 certification
when restricted wastes are sent off site to a land disposal facility.)
These standards include requirements such as manifests for shipping
waste that list all hazardous waste listings and characteristics
applicable to the waste (see 40 CFR 262.11), packaging and transport
requirements, and recordkeeping requirements.
If the LDRs are applicable, the following information should be
collected and available before the removal of wastes to an off-site
disposal facility: EPA hazardous waste number, LDR treatment
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Highlight 2:
EXAMPLES OF RCRA TECHNICAL STORAGE
REQUIREMENTS*
RCRA storage requirements, applicable to both less-than-90-day s
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.
standards, manifest number for the waste shipment, and waste
analysis data.
• Underground Injection Control (1110 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)). fSee Applicability of Land Disposal
Restrictions to RCRA and CERCLA Ground Water Treatment
Reiniection, OSWER Directive #9234,1-06, December 1989.)
• Non-RCRA Hazardous Wastes
Some non-RCRA hazardous waste may be subj ect 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
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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 CERCLA Aqueous Wastes
to POTWs, June 1991 and CERCLA Compliance with the CWA and
SDWA, #9234.2-06FS, January 1991.)
Toxic Substances Control Act (TSCA). If IDW contains PCBs,
TSCA treatment and/or disposal requirements may apply during its
management. TSCA 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 EPA/540/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, 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
(OSWERDirective 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 CERCLA-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 ARARs to the extent practicable (on site) or
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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.
IDW 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.
Management 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 or 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);
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• IDW 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 concern/perceptions).
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.
Examples: 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 redepo siting 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.
On-site Final Remedies (or Final Management is as 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
IDW in containers with 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
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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
vary from the presumption based on protectiveness, ARARs, and/or
community concerns.
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 secured 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.
Aqueous liquids
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 following box.
Non-indigenous IDW
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
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.
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
managers may generally dispose of it in an on-site dumpster (for
PPE).
Example 1: Disposable PPE (e.g., gloves, shoe covers) becomes
contaminated with RCRA hazardous waste during the field
investigation. The sitemanager 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.
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 community
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.
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 analysis of specific site circumstances.
The Agency also reserves the right to change this guidance any time without public notice.
Word-searchable version - Not a true copy
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