Waste Management
Managing wastes generated on remediation sites can be a confusing and expensive task. Regulated wastes may be generated in all phases of the remedial process, not just the remediation itself. Additionally, the transport of regulated waste is governed by both the RCRA regulations and DOT hazardous materials transport regulations. A thorough understanding of all regulations applicable to waste characterization, storage, transport, and disposal is necessary to properly manage remedial wastes.
RCRA and state waste disposal regulations were primarily written to address solid wastes generated in industrial processes, and the regulations are not always directly transferable to remediation wastes. Additionally, some provisions of the RCRA regulations such as the "Contained In Rule" and the "Derived From Rule" may be applicable to remediation wastes, which can further complicate waste characterization and disposal. In order to properly characterize remediation waste, the chemical composition and the source of the contamination need to be understood.
In my time in the remediation business, I have directed the management and disposal of remediation derived wastes anywhere from a single drum, to well over 200,000 cubic yards of contaminated soil. Management practices have ranged from on-site treatment and placement to disposal in municipal landfills to incineration and export outside of the US. Media have included trash, personal protective equipment, water, soil, petroleum products, unknown drum contents, and non-aqueous liquids. Contaminants managed have included chlorinated and non-chlorinated solvents, asbestos, PCBs, dioxins, metals, radioisotopes, semivolatile organic compounds and petroleum hydrocarbons.
I am especially sensitive to the overall costs associated with the safe and regulatory compliant disposal of wastes. I have driven efforts to characterize, minimize, segregate, and dispose of wastes to control costs. For instance, disposal cost may not be the determining factor for the overall cost-effectiveness of a disposal option. The construction, transportation, and analytical costs may have a significant impact on the overall disposal option cost. I carefully evaluate all costs for each disposal option in order to determine the most cost-effective disposal package. In addition, many clients have different risk tolerances for managing wastes. Since the generator carries the responsibility for waste in perpetuity, the client may also want to balance potential future risk with cost when deciding on the disposal option.