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DOE/EH-413-0005 Environmental Restoration Waste Management Guide July 2000 United States Department of Energy Office of Environmental Policy and Guidance RCRA/CERCLA Division (EH-413)
DOE/EH-413-0005
EnvironmentalRestoration WasteManagement Guide
July 2000
United States Department of EnergyOffice of Environmental Policy and Guidance RCRA/CERCLA Division (EH-413)
DOE/EH-413-0005
ENVIRONMENTAL RESTORATIONWASTE MANAGEMENT GUIDE
JULY 2000
Prepared byU.S. Department of Energy
Office of Environmental Policy and GuidanceRCRA/CERCLA Division (EH-413)
Technical Support byEnergetic, Incorporated
Project Performance Corporation
For Additional Information Contact:
Jerry Coalgate, EH-413phone: 202-586-6075
fax: [email protected]
TABLE OF CONTENTS
Chapter 1: Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1
1.1 - Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-11.2 - Scope of Document . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-21.3 - Regulatory Basis for Environmental Restoration Waste Management . . . . . . . . . . . . . . . 1-4
Chapter 2: Systematic Environmental Restoration Waste Planning Approach . . . . . . . . . . . . . . . 2-1
2.1 - Systematic Uncertainty Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-22.2 - Environmental Management Waste Planning Matrix . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-5
Chapter 3: Characterization of Environmental Restoration Wastes . . . . . . . . . . . . . . . . . . . . . . . . 3-1
3.1 - Drivers of Characterization for Environmental Restoration Wastes . . . . . . . . . . . . . . . . . 3-13.2 - Specific Questions Project Managers May Require Characterization to Answer . . . . . . . 3-23.3 - Timing and Data Quality Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-53.4 - Requirements For Characterizing Various Waste Types . . . . . . . . . . . . . . . . . . . . . . . . . . 3-6
Chapter 4: Management of Contaminated Groundwater During Environmental RestorationProjects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1
4.1 - Summary of Major Requirements For Groundwater . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-14.2 - Summary of Ground Water Management Technologies . . . . . . . . . . . . . . . . . . . . . . . . . . 4-34.3 - Basic Management Requirements During Pre-Treatment, Treatment, and
Post Treatment Phases for Hazardous Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-34.4 - Basic Management Requirements During Pre-Treatment, Treatment, and
Post-Treatment Phases for Radioactive Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-184.5 - Basic Management Requirements During Pre-Treatment, Treatment, and
Post-Treatment Phases for Mixed Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-224.6 - Alternate Compliance Options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-23
Chapter 5: Management of Contaminated Soil During Environmental Restoration Projects . . . 5-1
5.1 - Summary of Major Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-25.2 - Concepts and Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-35.3 - Summary of Soil Treatment Technologies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-55.4 - Basic Management Requirements During Pre-Treatment, Treatment, and
Post-Treatment Phases for Hazardous Soil Environmental Restoration Wastes . . . . . 5-55.5 - Basic Management Requirements During Pre-Treatment, Treatment, and
Post-Treatment Phases for Radioactive Soil Environmental Restoration Wastes . . . . 5-245.6 - Basic Management Requirements During Pre-Treatment, Treatment, and
Post-Treatment Phases for Mixed Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-325.7 - Managing PCB- and Asbestos-Containing Soil Wastes . . . . . . . . . . . . . . . . . . . . . . . . . 5-325.8 - Compliance Options for Managing Soil Environmental Restoration Wastes . . . . . . . . . 5-34
Chapter 6: Management of Contaminated Debris During Environmental Restoration Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1
6.1 - Summary of Major Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-16.2 - Concepts and Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-26.3 - Management Options for Hazardous Debris . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-36.4 - Management of Radioactive, Mixed Waste, and Other Types of Debris . . . . . . . . . . . . . 6-106.5 - Exemptions For Managing Debris . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-13
LIST OF EXHIBITS
Exhibit 1-1: Categories of Environmental Restoration Wastes Addressed in This Guide . . . . . . . . . . . 1-3
Exhibit 2-1: Example Waste Management Planning Matrix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-7Exhibit 2-2: Example Completed Waste Management Planning Matrix . . . . . . . . . . . . . . . . . . . . . . . . . 2-9
Exhibit 3-1: Properties of a Characteristic Hazardous Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-8Exhibit 3-2: Listed Hazardous Waste Types . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-9Exhibit 3-3: Categories of Asbestos-Containing Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-14
Exhibit 4-1: Summary of Chapter Sections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1Exhibit 4-2: Typical Ground Water Treatments for Hazardous Waste and Resulting Residuals . . . . . . 4-4Exhibit 4-3: Typical Ground Water Treatments for Radioactive Waste and Resulting Residuals . . . . . 4-7Exhibit 4-4: Ground Water Monitoring Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-10Exhibit 4-5: Summary of Potential Standards for Hazardous Waste Residuals Generated During In-SituManagement Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-12
Exhibit 5-1: Summary of Chapter Sections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1Exhibit 5-2: EPA Presumptive Remedies for Contaminated Soil . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-3Exhibit 5-3: In-Situ Treatment Technologies Typically Available for Hazardous Contaminated Soil . . 5-7Exhibit 5-4: Ex-Situ Treatment Technologies for Hazardous Contaminated Soil . . . . . . . . . . . . . . . . 5-11Exhibit 5-5: Treatment Technologies for Soil Contaminated with Radioactive Waste . . . . . . . . . . . . 5-15Exhibit 5-6: Potentially Applicable RCRA Standards for In-Situ Response Actions . . . . . . . . . . . . . . 5-17Exhibit 5-7: Waste Specific Design and Operating Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-19Exhibit 5-8: Summary of PCB Requirements for PCB Remediation Waste . . . . . . . . . . . . . . . . . . . . . 5-33
Exhibit 6-1: Summary of Chapter Sections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1Exhibit 6-2: Alternative Treatment Standards for Hazardous Debris . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-6Exhibit 6-3: Surface Activity Guidelines Allowable Total Residual Surface Activity
(dpm/100cm2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-15
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Throughout this Guide,definitions, notes, andspecific sources of additionalinformation will be providedin this margin. An excellentgeneral source of regulatoryinformation is the Internetsite maintained by DOE’sOffice of EnvironmentalPolicy and Guidance, EH-41, found at:http://www.eh.doe.gov/oepa.
This Guide incorporatesEPA policies andrulemakings throughDecember 1, 1999. EPA isconsidering other importantrulemakings, such asmodification to its correctiveaction management unitregulations, that could affectrestoration wastemanagement. Projectmanagers must be aware ofthese types of policy changesto stay current on futurerule changes.
Chapter 1: Introduction
1.1 Background
Faced with continued pressure to meet enforceable schedules and reducecosts, Department of Energy (DOE) project managers continue to focuson how to plan and implement efficient and effective environmentalrestoration projects and how to avoid unanticipated circumstances thatmay lead to delays in project completion. Cost-effective management ofwastes generated during restoration (“environmental restoration wastes”)is an essential component to conducting these more efficient andeffective cleanups.
The management of environmental restoration wastes, however, can becomplex. There are numerous regulatory requirements governing howenvironmental restoration waste management activities must beconducted. Additionally, there are always uncertainties associated withwaste management, some of which a project manager may not be able toeliminate prior to beginning actual environmental remediation work. Toensure such waste management activities remain in compliance withlaws and regulations and do not impede project implementation, aproject manager must be able to identify and manage major uncertaintiesthat are associated with managing environmental restoration wastes.
Identifying proper management strategies for environmental restorationwastes is primarily driven by an adequate understanding of three factors:(1) what media type (e.g., soil, debris, ground or surface water) needs tobe managed; (2) what are the key characteristics of contaminants foundin the media (including type of waste, constituents present, concentrationlevels, and extent of contamination); and (3) what is the selectedresponse action (e.g., what steps will occur to implement the action). Although investigations provide much of the information needed to planwaste management strategies, uncertainties will nearly always remain.
The purpose of this Environmental Restoration Waste Management Guide (or Guide) is to provide remedial project managers withinformation that may help facilitate better planning of wastemanagement processes for projects subject to both the ComprehensiveEnvironmental Response, Compensation and Liability Act (CERCLA)and Resource Conservation and Recovery Act (RCRA) CorrectiveAction program. It introduces a systematic approach that projectmanagers can use to address waste management issues. This approach isbased on the concept of uncertainty management, consistent withDepartment of Energy and Environmental Protection Agency’s (EPA)principles of environmental restoration, (Principles of Environmental
Introduction Environmental Restoration Waste Guide
Page 1-2
These EH-41 fact sheetsinclude: UncertaintyManagement: ExpeditingCleanup ThroughContingency Planning,Expediting Cleanup ThroughEarly Identification of LikelyResponse Actions, andExpediting Cleanup Through Problem Identification andDefinition (see “Policy andGuidance” on OEPAwebsite).
This is the Federal RCRAdefinition for remediationwaste. States may expandon or make more stringentdefinitions under theirdelegated authorities andmany States have done so.
DOE Order 435.1,Radioactive WasteManagement, issued on July9, 1999, replaced DOEOrder 5820.2A. It definesrequirements for managing transuranic (TRU) and low-level waste (LLW). It isfound at:[http://www.explorer.doe.gov:1776/html/alldirectives.html].
Restoration Workshop, November 1997), and several EH-41 Principlesof Environmental Restoration fact sheets. In addition, this Guideprovides references and summaries of the major regulatory requirementsthat drive how waste management must be conducted, and the practicalimplications of those regulations on environmental remediation projects. This Guide complements, and is complemented by another recent EH-413 guidance document entitled “Management of Remediation WasteUnder RCRA, December 20, 1999, which is found on the EH-41website at: http://www.eh.doe.gov/oepa under “Policy and Guidance”.
1.2 Scope of Document
This Guide has a broader scope than that of “remediation wastes”because remediation wastes, as defined in RCRA (40 CFR 260.10), onlyrefer to media contaminated with hazardous wastes. The RCRAdefinition (as amended in the HWIR-Media rule, 63 FR 65881,November 30, 1998) is:
All solid and hazardous wastes, and all media(including ground water, surface water, soils, andsediments) and debris, that contain listed hazardouswastes or that themselves exhibit a hazardouscharacteristic, and are managed for implementingcleanup.
Environmental restoration wastes, as discussed in this Guide, consist ofa broader range of contaminated media such as radioactive waste andmixed radioactive and hazardous waste and other wastes such as PCBsand asbestos-containing wastes. This Guide discusses the managementissues associated with major restoration wastes for each media in whichthey may be found (i.e., ground water, soil, and debris). Each of thewaste types covered by this Guide are briefly defined in Exhibit 1-1.
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This chapter relies on use ofthe uncertaintymanagement principle. More information can befound in UncertaintyManagement: ExpeditingCleanup ThroughContingency Planning,(DOE/EH/(CERCLA)-002),and Expediting CleanupThrough Early Identificationof Likely Response Actions.[http://www.eh.doe.gov/oepaunder “Policy &Guidance” ]
Chapter 2: Systematic Environmental RestorationWaste Planning Approach
To meet the objectives of effective and efficient remediation actions,project managers need to conduct a systematic evaluation of keyparameters of each waste stream that will be produced duringenvironmental restoration projects. This approach is necessary for tworeasons:
• First, an extensive number of requirements often apply to themanagement of environmental restoration wastes. Given thecomplexity of many of these requirements, systematic evaluationof each waste stream allows a project manager to ensure thatenvironmental restoration waste management requirements donot hinder implementation of the desired response action.
• Second, even small differences among remediation alternatives(e.g., using different types of technologies to separatecontaminants from a media) or small differences in whatcontaminants are present can lead to significant changes in howrestoration waste streams must be managed. Project managers,therefore, need to understand likely restoration wastemanagement requirements early in their projects, and identifyand manage key uncertainties in these waste plans that, ifencountered, may have significant cost or schedule impacts.
This chapter describes a systematic approach that project managers canuse to conduct this analysis and outlines a process to manage theuncertainties that are inherent in handling environmental restorationwastes.
The basis for the systematic approaches outlined in this Guide is the useof principles of environmental restoration that the DOE and U.S. EPAhave developed and promoted. In particular, two of the principles, (1)the importance and value of the early identification of appropriateresponse actions and (2) uncertainty management, are critical tounderstanding and implementing effective environmental restorationwaste management. Two other principles, (1) establishment of aneffective core team and (2) early problem identification, are alsorelevant, but not as central to effective management of environmentalrestoration wastes.
This chapter discusses each of these two principles and then describeshow a simple planning matrix (tool shown in Exhibit 2-1, for usethroughout the planning and execution of environmental restoration and
Uncertainty managementfocuses on identifying the likelyconditions that will beencountered, deviations to thoseconditions, and evaluation ofstrategies to manage thepossibility that those deviationswill occur and the impacts ifthey do.
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Uncertainty analysis, asdiscussed in this Guide,refers to the identificationand evaluation of knownand unknown conditions,the potential impacts ondecision making of theunknown conditions, andevaluation of what, if any,additional data orcontingency planning areneeded to reduce theimpacts of the uncertainty.
facility disposition projects) can be beneficial for environmentalrestoration waste planning. Early identification of likely responseactions, and the implementation of those responses as soon as sufficientsite information is available to do so, can significantly decrease the costsand accelerate the schedules of environmental restoration projects byeliminating unnecessary engineering studies. Because environmentalrestoration waste planning depends in large part on the response actionselected, early identification of probable response actions allows theproject manager to assess which regulatory requirements the waste willlikely be subject, and begin planning compliant waste handling methods.By focusing early on the response strategy, project managers alsoimprove their ability to collect missing data efficiently.
The rest of this chapter and Chapter 3 provide some overallconsiderations about managing environmental restoration waste. Eachmedia-specific chapter of the Guide that follows (i.e., Chapters 4through 6) briefly identifies the likely response actions available (onlyfor the purposes of identifying what residual waste streams thetechnologies likely will generate) and the specific requirementsapplicable to managing these residual wastes. This is necessary becauseearly identification of these residual waste streams and theircharacteristics is the cornerstone of the systematic approach advocatedin this Guide.
2.1 Systematic Uncertainty Management
2.1.1 Background
Uncertainty exists in nearly every aspect of an environmental restorationor facility disposition project. One major uncertainty is how wastes thatwill be generated during an environmental restoration project must behandled. Key elements of this uncertainty are often technical (e.g., whatcontaminants are present, what the depth of contamination is in soil), butalso can be regulatory (e.g., will wastes have to meet RCRA landdisposal restrictions) or programmatic (e.g., what funding is available ifa more stringent set of regulatory obligations are triggered because ofunanticipated wastes that were found).
Although a project manager may be able to identify the expected wastestreams that will be generated during an environmental restorationproject, the characteristics of these wastes, and which regulations willapply to these wastes, there is always a possibility that the actual wastetypes generated when a project is implemented or the characteristics ofthe waste may deviate from these expectations. If expected and actualconditions differ significantly, planned waste management approachesmay not satisfy the actual set of regulatory requirements that aretriggered. Moreover, if a project manager must significantly change
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waste management approaches to address unanticipated waste streams ortheir characteristics during a project, significant increases in cost anddelays in schedule may result.
In this Guide, uncertainty analysis and management are processes tosystematically evaluate and identify where it may be necessary to planfor circumstances that could differ from expected characteristics ofenvironmental restoration waste streams. These processes also help toidentify where differences are between expected and actualcircumstances (e.g., an additional contaminant is present in a waste thatwas not anticipated) that could have major impacts because differentregulatory requirements may apply.
2.1.2 Fundamentals of Uncertainty Management
Critical to uncertainty management is what options are available toproject managers when inevitable uncertainties exist. Three options areavailable. For any uncertainty, a project manager may 1) disregard theuncertainty because it is judged to be insignificant; 2) attempt toeliminate or reduce the uncertainty by obtaining more information aboutwhether expected circumstances are the actual circumstances (e.g.,through additional data collection to determine exactly what waste typesare present in a media); or 3) manage the uncertainty (e.g., through acontingent approach) such that if the actual and expected circumstancesare not the same, a plan is already in place to address the situation.
To make a decision about which option is most appropriate given anyparticular uncertainty, a project manager should consider three factors.
1. The potential impact of the uncertainty. This impact dependsboth on the likelihood that a circumstance different from anexpected circumstance exists and the impact that this differencewould have on implementing the project. Some deviationsbetween expected and actual conditions only may have anegligible impact. For example, if a listed hazardous waste isknown to be present in soil that is to be excavated, theconcentration of that contaminant will not determine or affectthe determination of whether the waste is subject to RCRA orcorresponding State hazardous waste regulations (because listedwastes are hazardous regardless of concentration).
Conversely, other types of unexpected circumstances may have ahigh impact on a project. For example, if a project managerexpects ground water to be contaminated only with hazardoussubstances at a known concentration, he may plan to manage[i.e., extract, treat (if necessary), and discharge] extractedground water under a National Pollutant Discharge Elimination
Options for managing uncertainty:
• Disregard uncertainty due to itsinsignificance.
• Eliminate or reduce theuncertainty by obtaining moreinformation about whetherexpected circumstances are actualcircumstances.
• Manage the uncertainty such thatactual and expected circumstancesare the same.
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System (NPDES) permit. However, if radionuclides, anunexpected contaminant, are found in the waste stream duringthe implementation of the project, the project manager may nolonger be able to discharge the ground water through a NPDESpermit without first applying the best available technology fortreating the radioactive component. This unanticipatedcircumstance could result in substantial cost and scheduleincreases or even preclude use of the planned discharge option.
2. The effectiveness of available contingency options. Althoughan uncertainty may have a potentially significant impact on aproject, the project manager may determine that it is mostappropriate (i.e., cost effective) to manage this uncertaintyduring implementation (e.g., develop a contingency plan) ratherthan reduce it up-front by collecting additional data. This is thecase if a project manager determines that: (1) monitoring andcontingency plans can easily minimize the impact ofencountering unexpected conditions on project success; or (2) itis more cost-effective to resolve the uncertainty duringimplementation than through up-front characterization.
For example, the project manager may not know if the type andlevel radionuclides in soil will meet the definition of TRUwaste. Rather than attempting to resolve this issue through datacollection and analysis prior to implementation, the projectmanager may instead require that soil is analyzed in the field asit is excavated. If contamination is detected that would indicatethat TRU wastes could be present, the project manager couldthen establish and implement a contingency plan to segregatethis portion of the waste for further analysis and appropriateTRU-waste management. This approach has the potential tominimize up-front costs of data collection and still ensure thatthe waste management approach is compliant with applicableregulations.
3. The feasibility of reducing the uncertainty. In some cases, it isnot feasible to resolve an uncertainty up-front and, therefore, itmust be managed through a contingency plan. For example, inexcavating waste management trenches where several differenttypes of waste streams were likely disposed, no amount ofcharacterization is likely to provide sufficient information aboutthe nature of the waste materials to develop final wastemanagement plans. In this example, a project manager has fewoptions other than to develop contingency plans that wouldaddress the different likely types of materials, and to specifyhow these materials could be handled during waste excavation,segregation, and management of wastes to ensure thatappropriate requirements are met.
Decision factors involved in uncertaintymanagement:
1. The impact posed by theuncertainty (Whether or notunexpected circumstances exist andif so, will they negatively impactproject implementation?)
2. The effectiveness of availablecontingency options (Are projectuncertainties better managedduring implementation ifmonitoring and contingency planscan easily minimize encounteringunexpected conditions on projectsuccess? Is it more cost effective toresolve uncertainty during aremedial project than beforehandduring characterization?)
3. The feasibility of reducing theuncertainty up-front duringcharacterization, rather thanduring project implementationthrough a contingency plan.
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2.2 Environmental Management Waste Planning Matrix
The primary tool for conducting the systematic analysis recommended inthis Guide is the Environmental Management Waste Planning Matrix(see Exhibit 2-1). This matrix allows the project manager to compilecritical information about each waste stream that will be generatedduring an environmental restoration action and evaluate the potentialuncertainties that may occur during the activity. Additionally, it assistsproject managers in making logical choices about characterization needs,if any, for critical decisions related to restoration wastes (i.e., reducingthose uncertainties that cannot be managed). Further, the EnvironmentalManagement Waste Planning Matrix allows a project manager todetermine what contingency plans may be required if unexpectedconditions are encountered.
The remaining chapters describe the regulatory information needed tocomplete this planning matrix for wastes generated as a result ofremediation of contaminated soil, debris, and ground water. In addition,chapter 3 describes how to address characterization issues related toenvironmental restoration wastes. The planning matrix describedthroughout this Guide is an iterative tool for use throughout the planningand conduct of environmental restoration projects.
See Exhibit 2-1 for the EnvironmentalManagement Waste Planning Matrix.
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More information on the useof process knowledge can befound in the Mixed WasteTesting Guidance (Office ofEnvironmental Policy andGuidance Memo, December23, 1997).[http://www.eh.doe.gov/oepaunder “Policy & Guidance”]
2.2.1 Sources of Information
Information to complete the matrix and conduct the systematic analysisof environmental management waste streams will be found in manyplaces:
• Process-knowledge and analysis from existing data ofcharacteristics of existing waste streams and likely wasteresiduals following the response action;
• Characterization conducted during the investigation phase of theresponse action (see Chapter 3); and
• In-process monitoring or characterization conducted duringdesign or implementation.
This Guide describes the types of information required to makerestoration waste management decisions and strategies forcharacterization that may be required in any phase of a remediationproject.
2.2.2 Example of Completed Matrix
Exhibit 2-2 presents an annotated version of a completed environmentalrestoration waste planning matrix for a hypothetical project. For thisexample, listed hazardous constituents in the soil above action levelshave been detected and the likely response action is excavation fordisposal offsite at a permitted, commercial disposal facility.
See Exhibit 2-2 for an example of acompleted environmentalrestoration waste planning matrixfor a hypothetical project.
Characterization informationused to complete environmentalrestoration waste planningmatrices is discussed in Chapter3 of this Guide.
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ntin
genc
y pl
anne
eded
to m
anag
e th
esi
tuat
ion
if th
e lik
ely
devi
atio
n w
as f
ound
to e
xist
]
Sys
tem
atic
App
roac
h
E
nviro
nmen
tal R
esto
ratio
n W
aste
Gui
de
P
age
2-8
Exp
ecte
dco
ndit
ion
ofw
aste
stre
amge
nera
ted
from
acti
on
Reg
ulat
ory
and
Man
agem
ent
Issu
es
Lik
ely
Dev
iati
ons
from
expe
cted
cond
itio
ns
Impa
ct t
o R
espo
nse
Act
ion
Unc
erta
inty
Man
agem
ent
App
roac
h
Mon
itor
ing
Pla
nC
onti
ngen
cy p
lan
EX
AM
PL
E:
Exc
avat
ed s
oil i
sco
ntam
inat
ed w
ithon
ly li
sted
haza
rdou
sm
ater
ials
.
Lan
d D
ispo
sal
Res
tric
tions
(LD
Rs)
Exc
avat
ed s
oil
cont
ains
radi
oact
ive
cons
titue
nts
abov
eba
ckgr
ound
leve
ls.
Plan
ned
disp
osal
faci
lity
will
not
acc
ept
mix
ed w
aste
s; d
ispo
sal
cost
s gr
eatly
incr
ease
;si
te m
ust b
e ab
le to
man
age
mix
ed w
aste
appr
opri
atel
y.
Proc
ess
hist
ory
and
curr
ent
sam
plin
g ef
fort
sin
dica
te th
at n
ora
diol
ogic
alco
ntam
inat
ion
ispr
esen
t. M
anag
ere
mai
ning
unce
rtai
nty
duri
ng a
ctio
n.
Mon
itor
exca
vate
dso
il fo
r ra
dioa
ctiv
ityab
ove
back
grou
ndle
vels
.
Seg
rega
te m
ixed
was
te im
med
iate
ly;
stor
e in
app
ropr
iate
cont
aine
rs; e
valu
ate
feas
ibili
ty (
tech
nica
lan
d co
st)
to tr
eat
haza
rdou
s co
mpo
nent
of w
aste
pri
or to
disp
osal
; ide
ntif
y a
mix
ed w
aste
dis
posa
lfa
cilit
y w
ith c
apac
ityif
trea
tmen
t is
not
feas
ible
.
Exc
avat
ed s
oil w
illno
t be
clas
sifi
ed a
sa
RC
RA
char
acte
rist
icha
zard
ous
was
te.
Lan
d D
ispo
sal
Res
tric
tions
Exc
avat
ed s
oil i
scl
assi
fied
as
aR
CR
Ach
arac
teri
stic
haza
rdou
s w
aste
.
Exc
avat
ion
can
cont
inue
but
the
char
acte
rist
icco
mpo
nent
of
was
tem
ust b
e tr
eate
d to
mee
tL
DR
s pr
ior
to d
ispo
sal.
Unc
erta
inty
can
be m
anag
eddu
ring
act
ion.
As
defi
ned
in th
esa
mpl
ing
and
anal
ysis
pla
n, o
btai
na
com
posi
te s
ampl
efr
om e
ach
ship
men
tco
ntai
ner
tode
term
ine
char
acte
rist
ic w
aste
sar
e pr
esen
t.
Tre
at c
hara
cter
istic
com
pone
nt o
f w
aste
with
Bes
t Ava
ilabl
eD
emon
stra
ted
Tec
hnol
ogy
(BA
DT
).
EH
-413
June
, 200
0
Pag
e 2-
9
Exh
ibit
2-2
: E
xam
ple
Com
plet
ed W
aste
Man
agem
ent
Pla
nnin
g M
atri
x
Exp
ecte
dco
ndit
ion
ofw
aste
stre
amge
nera
ted
from
acti
on
Reg
ulat
ory
and
Man
agem
ent
Issu
es
Lik
ely
Dev
iati
ons
from
expe
cted
cond
itio
ns
Impa
ct t
o R
espo
nse
Act
ion
Unc
erta
inty
Man
agem
ent
App
roac
h
Mon
itor
ing
Pla
nC
onti
ngen
cy p
lan
Eva
luat
ion
of e
xcav
ated
soi
l fro
m w
aste
pit
s. T
he r
emed
iati
on p
lan
calls
for
slu
dges
and
soi
ls t
o be
exc
avat
ed a
nd c
ateg
oriz
ed t
o fa
cilit
ate
disp
osal
at a
ppro
pria
te w
aste
sit
es.
Bas
ed o
n th
e w
aste
acc
epta
nce
crit
eria
(W
AC
) of
the
fac
iliti
es in
volv
ed, C
ateg
orie
s of
was
tes
bein
g ev
alua
ted
are
“typ
ical
/non
-typ
ical
was
tes.
” I
n ad
diti
on, e
valu
atio
n fo
cuse
s on
whe
ther
was
tes
are
“pro
cess
able
” at
the
sel
ecte
d fa
cilit
y. T
his
is a
hyp
othe
tica
lsc
enar
io o
nly.
Exc
avat
ed s
oil
mee
ts th
e W
AC
and
size
requ
irem
ents
for
the
offs
iteco
mm
erci
aldi
spos
al f
acili
ty.
Lan
d D
ispo
sal
Res
tric
tions
Exc
avat
ed s
oil i
sno
n-ty
pica
l was
te;
it do
es n
ot m
eet
WA
C a
nd c
anno
tbe
trea
ted
to m
eet
WA
C.
Was
tes
cann
ot b
esh
ippe
d of
fsite
to th
epl
anne
d co
mm
erci
aldi
spos
al f
acili
ty f
ordi
spos
al; s
ched
ule
will
be d
elay
ed a
nd c
osts
incr
ease
; app
ropr
iate
onsi
te s
tora
ge is
nece
ssar
y.
Unc
erta
inty
can
be m
anag
eddu
ring
act
ion.
As
defi
ned
in th
esa
mpl
ing
and
anal
ysis
pla
n, o
btai
na
com
posi
te s
ampl
efr
om e
ach
ship
men
tco
ntai
ner
tode
term
ine
if W
AC
are
met
.
If W
AC
sam
plin
gid
entif
ies
non-
typi
cal
was
te, p
lace
inco
ntai
ners
for
on-
site
stor
age
until
appr
opri
ate
disp
osal
faci
lity
with
cap
acity
is id
entif
ied.
Exc
avat
ed s
oil i
sno
n-pr
oces
sabl
ew
aste
; it m
eets
disp
osal
fac
ility
’sW
AC
but
doe
sn’t
mee
t siz
ere
quir
emen
ts.
Was
te c
anno
t be
ship
ped
offs
ite to
plan
ned
com
mer
cial
disp
osal
fac
ility
for
disp
osal
unt
il si
ze is
redu
ced.
Unc
erta
inty
can
be m
anag
eddu
ring
act
ion.
Dur
ing
exca
vatio
n,m
ater
ial i
s ev
alua
ted
for
size
.
Seg
rega
te o
vers
ized
mat
eria
l; sh
red
mat
eria
l to
mee
t siz
ere
quir
emen
ts o
f th
edi
spos
al f
acili
ty.
Sys
tem
atic
App
roac
h
E
nviro
nmen
tal R
esto
ratio
n W
aste
Gui
de
Exp
ecte
dco
ndit
ion
ofw
aste
stre
amge
nera
ted
from
acti
on
Reg
ulat
ory
and
Man
agem
ent
Issu
es
Lik
ely
Dev
iati
ons
from
expe
cted
cond
itio
ns
Impa
ct t
o R
espo
nse
Act
ion
Unc
erta
inty
Man
agem
ent
App
roac
h
Mon
itor
ing
Pla
nC
onti
ngen
cy p
lan
P
age
2-10
Exc
avat
ed s
oil i
sco
ntam
inat
ed w
ithon
ly li
sted
haza
rdou
sm
ater
ials
.
Lan
d D
ispo
sal
Res
tric
tions
Exc
avat
ed s
oil
cont
ains
radi
oact
ive
cons
titue
nts
abov
eba
ckgr
ound
leve
ls.
Plan
ned
disp
osal
faci
lity
will
not
acc
ept
mix
ed w
aste
s; d
ispo
sal
cost
s gr
eatly
incr
ease
;si
te m
ust b
e ab
lem
anag
e m
ixed
was
teap
prop
riat
ely.
Proc
ess
hist
ory
and
curr
ent
sam
plin
g ef
fort
sin
dica
te th
at n
ora
diol
ogic
alco
ntam
inat
ion
ispr
esen
t. M
anag
ere
mai
ning
unce
rtai
nty
duri
ng a
ctio
n.
Mon
itor
exca
vate
dso
il fo
r ra
dioa
ctiv
ityab
ove
back
grou
ndle
vels
.
Seg
rega
te m
ixed
was
te im
med
iate
ly;
stor
e in
app
ropr
iate
cont
aine
rs; e
valu
ate
feas
ibili
ty (
tech
nica
lan
d co
st)
to tr
eat
haza
rdou
s co
mpo
nent
of w
aste
pri
or to
disp
osal
; ide
ntif
y a
mix
ed w
aste
dis
posa
lfa
cilit
y w
ith c
apac
ityif
trea
tmen
t is
not
feas
ible
.
Exc
avat
ed s
oil w
illno
t be
clas
sifi
ed a
sa
RC
RA
char
acte
rist
icha
zard
ous
was
te.
Lan
d D
ispo
sal
Res
tric
tions
Exc
avat
ed s
oil i
scl
assi
fied
as
aR
CR
Ach
arac
teri
stic
haza
rdou
s w
aste
.
Exc
avat
ion
can
cont
inue
but
the
char
acte
rist
icco
mpo
nent
of
was
tem
ust b
e tr
eate
d to
mee
tL
DR
s pr
ior
to d
ispo
sal.
Unc
erta
inty
can
be m
anag
eddu
ring
act
ion.
As
defi
ned
in th
esa
mpl
ing
and
anal
ysis
pla
n, o
btai
na
com
posi
te s
ampl
efr
om e
ach
ship
men
tco
ntai
ner
tode
term
ine
ifch
arac
teri
stic
was
tes
are
pres
ent.
Tre
at c
hara
cter
istic
com
pone
nt o
f w
aste
sw
ith B
DA
T.
EH
-413
June
, 200
0
Exp
ecte
dco
ndit
ion
ofw
aste
stre
amge
nera
ted
from
acti
on
Reg
ulat
ory
and
Man
agem
ent
Issu
es
Lik
ely
Dev
iati
ons
from
expe
cted
cond
itio
ns
Impa
ct t
o R
espo
nse
Act
ion
Unc
erta
inty
Man
agem
ent
App
roac
h
Mon
itor
ing
Pla
nC
onti
ngen
cy p
lan
Pag
e 2-
11
Vol
ume
ofex
cava
ted
soil
will
not e
xcee
d 50
0cu
bic
met
ers.
Cap
acity
of
disp
osal
fac
ility
Vol
ume
ofex
cava
ted
soil
exce
eds
500
cubi
c m
eter
s.
Add
ition
al s
hipm
ent
cont
aine
rs w
ill b
ere
quir
ed; e
xcav
atio
nca
n co
ntin
ue b
ut if
disp
osal
fac
ility
doe
sno
t hav
e ad
ditio
nal
capa
city
, ano
ther
faci
lity
mus
t be
iden
tifie
d an
d st
orag
eon
site
will
be
requ
ired
.
Unc
erta
inty
can
be m
anag
eddu
ring
act
ion.
Tra
ck v
olum
e of
soi
lex
cava
ted.
Onc
e 45
0cu
bic
met
ers
has
been
exc
avat
ed,
impl
emen
tco
ntin
genc
y.
Obt
ain
addi
tiona
lsh
ipm
ent c
onta
iner
sth
an c
an a
lso
be u
sed
to s
tore
mat
eria
l;id
entif
y a
diff
eren
tdi
spos
al f
acili
ty if
addi
tiona
l cap
acity
cann
ot b
eac
com
mod
ated
at
plan
ned
disp
osal
faci
lity.
Exc
avat
ed s
oil w
illm
eet R
CR
A L
DR
sL
and
Dis
posa
lR
estr
ictio
nsE
xcav
ated
soi
ldo
es n
ot m
eet
RC
RA
LD
Rs
Soi
l mus
t be
trea
ted
with
the
BD
AT
pri
or to
disp
osal
;
Unc
erta
inty
can
be m
anag
eddu
ring
act
ion.
As
defi
ned
in th
esa
mpl
ing
and
anal
ysis
pla
n, o
btai
na
com
posi
te s
ampl
efr
om e
ach
ship
men
tco
ntai
ner
to e
nsur
eth
at L
DR
s ar
e m
et.
Obt
ain
nece
ssar
yeq
uipm
ent o
r id
entif
yco
ntra
ctor
s to
trea
tw
aste
s w
ith B
DA
T.
Tec
hnic
al d
iffi
culti
esm
ay p
reve
nt e
ffec
tive
trea
tmen
t with
the
BD
AT
.
Unc
erta
inty
can
be m
anag
eddu
ring
act
ion.
As
defi
ned
in th
esa
mpl
ing
and
anal
ysis
pla
n, o
btai
na
com
posi
te s
ampl
efr
om e
ach
ship
men
tco
ntai
ner
to e
nsur
eth
at L
DR
s ar
e m
et.
Seg
rega
te w
aste
that
cann
ot b
e tr
eate
d;st
ore
onsi
te w
hile
obta
inin
g a
com
plia
nce
optio
n(e
.g.,
a tr
eata
bilit
yva
rian
ce).
Sys
tem
atic
App
roac
h
E
nviro
nmen
tal R
esto
ratio
n W
aste
Gui
de
Exp
ecte
dco
ndit
ion
ofw
aste
stre
amge
nera
ted
from
acti
on
Reg
ulat
ory
and
Man
agem
ent
Issu
es
Lik
ely
Dev
iati
ons
from
expe
cted
cond
itio
ns
Impa
ct t
o R
espo
nse
Act
ion
Unc
erta
inty
Man
agem
ent
App
roac
h
Mon
itor
ing
Pla
nC
onti
ngen
cy p
lan
P
age
2-12
A p
ortio
n of
exca
vate
d so
il w
illex
ceed
moi
stur
eco
nten
t allo
wed
for
disp
osal
.
Ons
ite th
erm
alun
it ca
paci
tyan
d sc
hedu
lefo
r tr
eatm
ent o
fw
aste
s an
dre
sulti
ngw
aste
stre
ams.
Exc
avat
ed s
oil
does
not
exc
eed
moi
stur
e co
nten
tal
low
ed f
ordi
spos
al.
Neg
ligib
le im
pact
. No
dryi
ng is
req
uire
d.
Seg
rega
te s
oil
depe
ndin
g on
moi
stur
e co
nten
tdu
ring
act
ion;
disp
ose
of s
oil
with
out t
reat
men
tif
app
ropr
iate
.
Vis
ual m
onito
ring
duri
ng e
xcav
atio
nw
ill in
dica
te if
soi
ldo
es n
ot e
xcee
dal
low
able
moi
stur
eco
nten
t.
Gre
ater
vol
umes
than
exp
ecte
d of
exca
vate
d so
ilex
ceed
allo
wab
lem
oist
ure
cont
ent.
Exc
avat
ion
can
cont
inue
but
ons
itest
orag
e w
ill b
e re
quir
edif
ther
mal
uni
t can
not
dry
soil
as q
uick
ly a
s it
is e
xcav
ated
.
Unc
erta
inty
can
be m
anag
eddu
ring
act
ion.
Vis
ual m
onito
ring
duri
ng e
xcav
atio
nw
ill in
dica
te if
soi
lex
ceed
s al
low
able
moi
stur
e co
nten
t.
Seg
rega
te w
aste
for
stor
age
onsi
te u
ntil
ther
mal
uni
t can
trea
tso
il.
EH
-413
June
, 200
0
Exp
ecte
dco
ndit
ion
ofw
aste
stre
amge
nera
ted
from
acti
on
Reg
ulat
ory
and
Man
agem
ent
Issu
es
Lik
ely
Dev
iati
ons
from
expe
cted
cond
itio
ns
Impa
ct t
o R
espo
nse
Act
ion
Unc
erta
inty
Man
agem
ent
App
roac
h
Mon
itor
ing
Pla
nC
onti
ngen
cy p
lan
Pag
e 2-
13
Eva
luat
ion
of w
aste
stre
ams
resu
ltin
g fr
om t
herm
al d
ryin
g pr
oces
s
Air
em
issi
ons
resu
lting
fro
mth
erm
al d
ryin
g un
itw
ill b
e co
ntro
lled
with
an
off-
gas
clea
ning
sys
tem
and
will
not
exce
ed a
ir q
ualit
yco
ntro
l sta
ndar
ds.
Nat
iona
lE
mis
sion
Stan
dard
s fo
rH
azar
dous
Air
Pol
luta
nts
(NE
SH
AP
s)
Air
em
issi
ons
resu
lting
fro
mth
erm
al d
ryin
gun
it ex
ceed
air
qual
ity c
ontr
olst
anda
rds.
Tre
atm
ent m
ust h
alt
until
air
sta
ndar
ds a
rem
et.
Can
not r
educ
eun
cert
aint
y pr
ior
to a
ctio
n.
Mon
itori
ng s
tatio
nspl
aced
at t
he p
oint
of
rele
ase
from
the
ther
mal
dry
ing
unit
(i.e
., ve
nt s
tack
) an
dar
ound
the
peri
met
erof
the
ther
mal
dry
ing
unit.
If a
ir q
ualit
y co
ntro
lst
anda
rds
are
not m
et,
stop
wor
k, r
epla
cefi
lter,
load
mat
eria
lm
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EH-413 June, 2000
Page 1-3
Hazardous wastes are either characteristic or listedwastes (or sometimes both) Characteristic wastesexhibit one of the followingtraits: ignitability,corrosivity, reactivity, ortoxicity [40 CFR 261.21-24]. Listed hazardous wastes aresource specific, non-specificsource, or commercialchemical products waste(see 40 CFR 261.31-33).
A curie is a unit measuringradioactive decay. Specifically, one curie is 37billion atoms undergoingdecay each second. A"nanocurie" is one billionthof a curie.
Exhibit 1-1: Categories of Environmental RestorationWastes Addressed in this Guide
- Hazardous Waste is a solid waste that: 1) exhibits a characteristic ofa hazardous waste; 2) is a listed hazardous waste; 3) is a mixture of ahazardous waste and a nonhazardous waste; or 4) is derived from thetreatment storage, or disposal of a listed waste. States may expand onor make more stringent definitions under their delegated authority. 40CFR 260 and 261 define hazardous wastes at the Federal level.
- Transuranic Waste (TRU) is radioactive waste that contains morethan 100 nanocuries (3700 becquerels) of alpha-emitting transuranicisotopes per gram of waste, with half-lives greater than 20 years,except for: 1) High level radioactive waste; 2) Waste that theSecretary of Energy has determined, with the concurrence of theAdministrator of the EPA, does not need the degree of isolationrequired by the 40 CFR Part 191 disposal regulations; or 3) Wastethat the Nuclear Regulatory Commission (NRC) has approved fordisposal on a case-by-case basis in accordance with 10 CFR Part 61.[Source: WIPP (Waste Isolation Pilot Plant) Land Withdrawal Act of1992, as amended]
- Low-Level Waste (LLW) is radioactive waste that is not HLW,spent nuclear fuel (SNF), TRU, by-product material (as defined insection 11(e.)(2) of the Atomic Energy Act of 1954, as amended(AEA)), or naturally occurring radioactive material. [Adapted from:Nuclear Waste Policy Act of 1982, as amended]
- Mixed Waste is waste that contains both radioactive (source,special nuclear, or by-product material) and hazardous componentssubject to the AEA as amended and the RCRA, respectively.[Adapted from: Federal Facility Compliance Act of 1992] Mixedwaste is further defined as high level mixed, transuranic mixed, orlow-level mixed wastes. Unless demonstrated otherwise, all high-level waste shall be considered mixed waste and is subject to therequirements of the AEA and the RCRA, according to DOE M 435.1-1, Chapter II (C)(1).
- Other Wastes (not an official waste type) may also be found as partof environmental remediation activities at DOE sites. For example,polychlorinated biphenyls (PCBs) and asbestos may be found at DOEsites. These wastes are regulated under the Federal Toxic SubstancesControl Act (TSCA), and in some States, they are considered to behazardous wastes under State law. They may or may not be found inmixtures containing Federal hazardous wastes or radioactive wastes.
Introduction Environmental Restoration Waste Guide
Page 1-4
Guidance on ARARscompliance can be found inCERCLA Compliance withOther Laws Manual,CERCLA Compliance withState Requirements,(OSWER Dir. 9234.2-05/FS,EPA 1989) and CERCLACompliance with Other LawsManual: Guide to Manual,(OSWER Dir. 9234.2-02/FS,EPA 1989). These are notavailable on the Internet,but can be obtained fromthe EPA RCRA/CERCLAHotline by calling: (800) 424-9346.
Although DOE sites also manage spent nuclear fuel and high-levelwaste, these are generally not found as part of remediation projects andare not discussed further in this Guide. DOE Order 435.1 defines spentnuclear fuel as
fuel that has been withdrawn from a nuclear reactor followingirradiation, the constituent elements of which have not beenseparated by reprocessing. Test specimens of fissionablematerial irradiated for research and development only, and notproduction of power or plutonium, may be classified as waste,and managed in accordance with the requirements of DOE O435.1 when it is technically infeasible, cost prohibitive, or wouldincrease worker exposure to separate the remaining testspecimens from other contaminated material.
The Order defines high-level waste is defined as
the highly radioactive waste material resulting from thereprocessing of spent nuclear fuel, including liquid wasteproduced directly in reprocessing and any solid materialderived from such liquid waste that contains fission products insufficient concentrations; and other highly radioactive materialthat is determined, consistent with existing law, to requirepermanent isolation.
1.3 Regulatory Basis for Environmental Restoration WasteManagement
Compliance with all environmental laws that apply to remediationactivities is required under both CERCLA and RCRA corrective actionprojects. The legal mechanism, however, is different for each program.
For CERCLA actions, subsection 121(d) of CERCLA specifies that on-site Superfund remedial actions must attain federal standards,requirements, criteria, limitations, or more stringent state standardsdetermined to be legally applicable or relevant and appropriate (ARAR)to the circumstances at a given site. To be applicable, a state or federalrequirement must directly address the hazardous substance, the actionbeing taken, or other circumstance at the site. A requirement that is notapplicable may be relevant and appropriate if it addresses problems orpertains to circumstances similar to those encountered at a Superfund(CERCLA) site. ARARs are used in conjunction with risk-based goalsto govern Superfund response activities and to establish cleanup goals.
For wastes that are hazardous for example, a variety of substantiverequirements may be treated as ARARs if CERCLA site-specific
EH-413 June, 2000
Page 1-5
CERCLA’s off-site rule (40CFR 300) requires that onlyfacilities that meet EPA’sacceptability criteria can beused for off-site managementof CERCLA waste, includingtransfer facilities. Moreinformation can be found inthe CERCLA InformationBrief The Off-Site Rule, EH-231-020/0194, March, 1994,available for downloading at [http://www.eh.doe.gov/oepaunder “Policy & Guidance”].
EPA’s RCRA correctiveaction program has madethese policy decisions in thecontext of its remedyselection process. EPAguidance on remedyselection is part of EPA’scurrent RCRA correctiveaction national traininginitiative and EPA hasissued Final RemedySelection for Results-BasedCorrective Action (December13, 1999) that addresses thisconcept.
activities are considered treatment, storage, and disposal activitiesregulated under Subtitle C. RCRA Subtitle C regulations (appearing in40 CFR Parts 260-299), which govern hazardous waste from the point ofgeneration through the point of disposal, commonly are applicable orrelevant and appropriate to CERCLA response actions. Theserequirements are outlined in detail in Chapters 4 through 6 of this Guideas they apply to ground water, soil, and debris, respectively, that arethemselves hazardous wastes or contain hazardous wastes that are listedor exhibit one of the four characteristics (toxicity, corrosivity,ignitability, or reactivity) outlined in 40 CFR 261.21-24.
EPA’s current interpretation of the CERCLA Section 121(e) permitexclusion establishes that RCRA administrative standards (in addition tosubstantive requirements) apply when hazardous wastes are sent off-sitefor further management. Administrative RCRA standards include theobligation to obtain permits and keep various records at all hazardouswaste treatment, storage, and disposal facilities (TSDFs); and therequirement to include a hazardous waste manifest when sendinghazardous wastes offsite.
In addition, CERCLA has established additional requirements thatproject managers must meet when wastes are sent off site to amanagement facility (known as the off-site rule).
Under the current RCRA national corrective action program, correctiveaction requirements or regulations applicable to restoration wastes arelimited to 40 CFR 264.100 [Corrective Action Program], 40 CFR 264Part 264.101 [Corrective Action for Solid Waste Management Units], 40CFR 264.552 and 553 [Corrective Action Management Units (CAMU)and Temporary Units (TU), respectively]. Although there are limitedcorrective action regulatory requirements, the EPA has, over the years,issued a number of guidance documents which are used to direct theprogram. Currently, the primary guidance document for the correctiveaction program is the Corrective Action for Releases from Solid WasteManagement Units at Hazardous Waste Management Facilities:Advanced Notice of Proposed Rulemaking (ANPRM), 61 FR 19432, May1, 1996. Prior to the issuance of the ANPRM, the primary guidancedocument was the Corrective Action for Releases from Solid WasteManagement Units at Hazardous Waste Management Facilities(“Subpart S”): Proposed Rule, 55 FR 30798, July 27, 1990. The“Subpart S” proposed Rule was partially withdrawn by the EPA in 1999[64 FR 54604, October 7, 1999].
Given the recent withdrawal of the 1990 proposed Subpart S [64 FR54604, October 7, 1999, http://www.epa.gov/epaoswer/hazwaste/ca/partwith.htm] comprehensive national regulation for RCRA
Introduction Environmental Restoration Waste Guide
Page 1-6
corrective actions, there is limited specific direction from EPA on whenthe requirements of other laws must be met during corrective actionprojects. However, in its recent policy training (RCRA CorrectiveAction Workshop on Results-Based Project Management, 1999) EPA hasstated that any requirements of RCRA or other laws that are legallyapplicable are inherent elements of remedy selection evaluations underthe RCRA corrective action program.
EH-413 June, 2000
Page 3-1
Additional guidance onregulatory interpretations andwaste characterization issues isalso available on the EH-41website at:[http://www.doe.gov/oepa] or from EPA’s Waste Analysisof Facilities that Generate,Treat, or Dispose of HazardousWaste - A Guidance Manual,U.S. EPA, EPA-530-R-94-024,April 1994.
Chapter 3: Characterization of EnvironmentalRestoration Wastes
3.1 Drivers of Characterization For Environmental RestorationWastes
Environmental restoration investigations (i.e., remedial investigations,RCRA facility investigations) seldom, if ever, result in a projectmanager learning all of the information needed to manage environmentalrestoration wastes. Effective sampling and analysis data gathered duringthese investigations, historical information regarding site operations, andinformation regarding the characteristics of contaminated ground water,soil, and debris, will assist the remedial project manager in identifyingthe range of potential regulatory requirements that could apply to eachtype of environmental restoration waste. Furthermore, this informationshould allow a project manager to better identify expected circumstancesfor each environmental restoration waste stream. Once these expectedcircumstances are defined, project managers can then determine which,if any, remaining uncertainties need to be managed to avoid unintended,negative consequences when a project is actually implemented.
Characterization activities have two primary objectives relative toplanning for environmental restoration waste management. First,characterization may provide the information that a program managerneeds to determine what the likely regulatory requirements may be, andwhat, if any, other regulations might apply if actual circumstances differfrom those expected to exist. Second, characterization activities mayalso be needed to substantiate that environmental restoration wastemanagement practices satisfy appropriate waste management regulationsor site-specific permit or operation requirements (e.g., WAC,compliance with a National Pollution Discharge Elimination System(NPDES) permit).
For example, DOE facilities such as WIPP, and the Nevada Test Siteradioactive waste management complex both have WAC, andcorresponding certification programs, to ensure that only compliantwaste streams are sent to their facilities. According to DOE M 435.1-1, facilities for TRU waste must at a minimum have WAC that:
� Specify allowable waste management activities and/orconcentrations of specific radionuclides;
� Specify acceptable waste form and/or container requirementsthat ensure the chemical and physical stability of waste underconditions that might be encountered during transportation,storage treatment or disposal;
� Specify restrictions or prohibitions on waste, materials, or
The primary roles of sitecharacterization include:
1. To determine applicableregulatory requirements andmanage unexpectedcircumstances.
2. To determine how to meetappropriate waste managementregulations or site-specific permitor operating requirements.
Characterization Environmental Restoration Waste Guide
Page 3-2
containers that may adversely affect waste handlers orcompromise facility or waste container performance;
� Identify TRU as defense or non-defense, and specify limitationson waste acceptance; and
� Specify the basis, procedures, and levels of authority requiredfor granting exceptions to the waste acceptance requirements,which shall be contained in each facility’s waste acceptancedocumentation. Each exception request shall be documented,including its disposition as approved or not approved.
Facilities accepting low-level waste must establish WAC that at aminimum:
� Specify allowable waste management activities and/orconcentrations of specific radionuclides;
� Specify acceptable waste form and/or container requirementsthat ensure the chemical and physical stability of waste underconditions that might be encountered during transportation, storage treatment or disposal; and
� Specify restrictions or prohibitions on waste, materials, orcontainers that may adversely affect waste handlers orcompromise facility or waste container performance.
It is important to remember that because a waste management sitewill refuse to accept environmental restoration wastes that do notmeet its WAC, project managers should routinely check the WAC ofa planned waste management facility beginning early in therestoration project to ensure that they have accurate informationand that waste meets a facility’s disposal or managementrequirements.
This chapter summarizes the major technical and regulatory issues thatmust be considered when characterizing environmental restorationwastes. It also discusses the key questions that a program manager mustbe able to answer to plan and implement an effective waste managementapproach.
3.2 Specific Questions Project Managers May RequireCharacterization to Answer
For project managers to manage environmental restoration wastessystematically, they must be able to answer a number of key questions.Some of these questions may be answered sufficiently using historicalrecords, process knowledge, and/or existing sampling information. If anyof the key questions cannot be answered using existing information,
DOE M 435.1-1 establishes minimumWAC that facilities must establishfor TRU wastes (Chapter III.G), andlow-level wastes (Chapter IV.G). [http://www.explorer.doe.gov:1776/htmls/currentdir.html].
EH-413 June, 2000
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additional sampling and analysis activities (as part of a plannedinvestigation) may be needed, existing information reevaluated, orcontingency approaches developed to determine the answers. Thespecific questions project managers may require characterization toanswer include:
& What are the expected characteristics of the waste(s) (e.g.,contaminant type, constituents, physical characteristics) thatwill be generated during remediation? Given these expectedconditions, what regulatory requirements are applicable or, forCERCLA actions, are also relevant and appropriate toconsider)? Specifically, a project manager must considerwhether environmental restoration wastes will be hazardous,radioactive, or mixed wastes and have sufficient data todetermine what parts of corresponding regulations apply (e.g.,do concentrations levels of hazardous wastes present alreadymeet LDR (land disposal restriction) treatment standards or istreatment of any wastes generated during the action required?).Project managers must also determine if the wastes will be co-regulated under other Federal statutes or State programs (e.g.,are PCBs regulated as hazardous wastes in a certain State). Bydefining which regulatory framework(s) will likely governmanagement of environmental restoration wastes, a projectmanager can identify compliant options for the management andfinal disposition of wastes or determine when regulatoryvariances may be needed.
& What are the potential impacts of these applicable (or relevantand appropriate) regulations on planned waste handling andwaste management? After project managers define whichregulatory framework(s) will likely apply to the management ofenvironmental restoration wastes, they can evaluate the potentialimpacts of regulations and determine how these requirementscan be integrated into plans designed to meet the statutory andregulatory requirements (e.g., protect human health and theenvironment). For example, management of hazardous wastesmay require treatment prior to disposal to meet LDR treatmentstandards, and characterization may be required to determinewhether various proposed treatment approaches can achievepromulgated LDR treatment levels. In other cases, projectmanagers may require specific types of data to justify a varianceor alternate approach that must be approved by regulators beforeimplementation of a response can be initiated.
& What uncertainties exist? Specifically, are deviations fromexpected circumstances likely? How likely are they? Whatwould the impact be of encountering these unexpectedcircumstances? The impact of encountering unexpectedconditions ranges from significant to negligible. A significant
Characterization decisions mustaddress the expectedcharacteristics of the wastestream, in addition toconsidering ARARs forCERCLA actions andapplicable requirements forRCRA corrective actions.
Waste characterization processesshould take into account thepresence of existing uncertainties,the likelihood of futureuncertainties in an environmentalrestoration project, the potentialimpact such uncertainties may haveon the project and any deviationsfrom expected circumstances.
The impacts of any applicableregulatory requirements or ofARARs on planned wastehandling and waste managementshould also be considered duringthe waste characterizationprocess.
Characterization Environmental Restoration Waste Guide
Page 3-4
impact is one that would cause a change in waste handling andmanagement were an unexpected condition to occur. Forexample, if soil being managed as hazardous waste is found tocontain any radioactive contaminants (an unexpectedcircumstance) in addition to hazardous waste constituents (anexpected circumstance), the material must be handled as a mixedradioactive waste. Additionally, the project manager mustdetermine if disposal at a mixed waste facility is appropriate, orif treatment prior to disposal (rending the waste no longerhazardous) could allow the waste to be managed only as a low-level radioactive waste.
A negligible or insignificant impact is one that would not impacthow an environmental restoration waste stream is managed. Forexample, concentrations of radioactive constituents in soil maybe greater than expected, but still result in a waste beingclassified as a LLW. In this case, if the project manager knowsin advance that the receiving facility can still accept the wastebecause the higher concentrations still meet all WAC, no furtherevaluation of this unexpected circumstance is likely necessary.
� What is the likely final disposition of environmental restorationwastes? The quality and quantity of data required to ensure thatwaste is managed appropriately also depend on the likely finaldisposition of environmental restoration wastes (e.g., disposalonsite, disposal offsite, recycling of material). The likely finaldisposition may also impact when data need to be collected.
For example, an off-site disposal facility’s WAC may specifynot only the number of composite samples to be analyzed, butwhen they must be collected and analyzed (e.g., before wastesare shipped, to verify they meet WAC, and a certain numberafter wastes have been packaged for transportation to ensure thatthe wastes shipped are consistent with the initial verificationsample). For wastes dispositioned in place, on the other hand,limited (if any) sampling may be required before capping, butextensive sampling from monitoring wells during post-closureperiods will likely need to be implemented.
Evaluation of these types of questions should be a routine part ofenvironmental restoration projects, from initial scoping (where a projectteam first identifies the problems requiring remediation, likely responseactions, and characterization needs to select a response) throughremedial design and implementation, when environmental restorationwastes are actually managed and potential uncertainties may becomemanagement realities.
The likely final disposition of anenvironmental restoration wastestream is a vital consideration ofwaste characterization processes.
EH-413 June, 2000
Page 3-5
More information on processknowledge can be found inMixed Waste Testing Guidance(Office of EnvironmentalPolicy and Assistance Memo,December 23, 1997), andManagement of RemediationWaste under RCRA (EPA 530-F-98-026), October 1998.[http://www.eh.doe.gov/oepaunder “Policy &Guidance” ]
3.3 Timing and Data Quality Issues
The specific techniques for sampling and analyzing environmentalrestoration wastes and issues associated with obtaining data that are ofappropriate quality to make decisions (e.g., ways of obtaining samples,sample management, test methods, use of field instruments vs.traditional laboratory analysis) are generally the same as they are forother characterization activities. There are, however, certain timing andquality considerations that may be specific to restoration wastemanagement.
3.3.1 When Characterization for Environmental RestorationWastes is Needed
Many of the data that are traditionally available or are collected duringthe investigations that precede remedy implementation can also be usedto anticipate which environmental restoration wastes will be present at asite and how they should be managed. For example, a generalunderstanding of likely contaminant types often can be obtained fromhistorical process knowledge of site operations and data collected todetermine the location and magnitude of risks posted by past sitereleases. Once available, this information allows a project manager tobegin to determine the regulatory framework under which the projectlikely will be conducted and the implications these regulations likelywill have on environmental restoration waste management activities.
In some cases, traditional data that are collected may need to besupplemented with data that specifically answer key questions aboutenvironmental restoration waste management issues. For example,although total concentrations of an inorganic contaminant often will beneeded to establish whether a release poses a risk to human health or theenvironment, determining whether the waste is hazardous (and,therefore, whether it will trigger RCRA Subtitle C requirements if it isexcavated, stored, treated, or re-disposed) may require that a projectmanager conduct a toxicity characteristic leaching procedure (TCLP)analysis.
Therefore, a project manager should identify key uncertainties aboutpotential environmental restoration waste streams as early in projects aspossible to determine what, if any, additional analysis is needed toevaluate potential alternatives that are being considered for the waste.
3.3.2 Degree of Data Quality Required for Waste Management
The data quality needed for making environmental restoration wastemanagement decisions is based on two factors: 1) the data qualityrequirements established by specific regulations, permits, or WACs; and,2) the amount of certainty that the project team requires to make wastemanagement decisions.
Characterization Environmental Restoration Waste Guide
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For more information, seeUsing the Data QualityObjectives Process in RiskAssessment, EH-231-023/0794,July, 1994, available fordownloading at[http://www.eh.doe.gov/oepa/under “Policy and Guidance”]and DOE Order 435.1-1,Radioactive Waste ManagementManual, July, 1999[http://www.explorer.doe.gov:1776/htmls/currentdir.html].
The quality of data needed to meet regulatory requirements, in mostcases, are clearly defined in the regulations themselves or in site-specificdocuments such as permits or operating plans. Project managers shouldconsult these to determine what methods, for example, are acceptable tomake these types of restoration waste management decisions.
The amount of certainty a project team requires to make decisions ismuch more variable and is a key element of successfully completing theEnvironmental Waste Management Planning Matrix in Chapter 2. Insome cases, by carefully defining and evaluating uncertainties, theproject team may discover that it is able to plan an acceptable wastemanagement approach for environmental restoration wastes using onlydata available already.
For instance, a project team may decide that process history informationand existing sampling data (e.g., collected to ensure worker health andsafety during remediation) are satisfactory to determine that the expectedcircumstance that debris resulting from demolition of a radioactivelycontaminated facility is low-level radioactive waste, and thatencountering TRU waste is unlikely. Because the project team can alsorely on field monitoring information during implementation to ensurethat no unexpected TRU waste is encountered, the team could decidethat no additional characterization would be required prior to action. Theproject team could then conduct the demolition in a manner to controlthe release of radioactive contamination (e.g., through continuousspraying of the facility to control dust), and manage the resulting debrisas LLW. In this case, additional characterization for waste managementpurposes might only be required to substantiate that the debris meetsstorage and transportation requirements, and the WAC of the disposalfacility prior to shipping it offsite or disposing of it onsite.
If the project team determines that data quality is of concern for makingwaste management decisions, EPA’s Data Quality Objective (DQO)approach is a tool that allows a project team to ensure thatenvironmental restoration waste is characterized in an effective,resource-efficient manner. The DQO Approach provides a systematicprocedure for defining waste characterization design criteria, includingwhen, where, and how many samples to collect, and the acceptable levelof data uncertainty. Because it is not always necessary to know theconcentrations or extent of contamination to make waste managementdecisions, the level of data required to make decisions is in many casesmuch less than that required for a risk assessment.
3.4 Requirements For Characterizing Various Waste Types
This section describes major considerations for characterizing differentwaste types (e.g., hazardous, radioactive, mixed, other) includingvariances for which characterization data may be needed.
EH-413 June, 2000
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A major policy to determine if contaminated environmentalmedia is subject to hazardouswaste requirements is the“contained-in” policy. Thispolicy requires that mediacontaining listed wastes mustbe managed as listed wastesuntil they no longer containthe waste (sometimes referredto as the “contained-out”policy).
3.4.1 Hazardous Waste
Characterization of hazardous environmental restoration wastes ofteninvolves determining if the restoration waste meets the definition of ahazardous waste as defined in 40 CFR 261.3 or corresponding stateenvironmental regulations. Environmental media contaminated with alisted or characteristic hazardous waste is considered hazardous underthe “contained in” policy. As long as the environmental media“contains” the hazardous waste or exhibits a hazardous waste“characteristic”, it needs to be managed as a hazardous waste.
Characteristic Wastes
Contaminated media or waste will have to be managed as a hazardouswaste as long as it exhibits a hazardous waste characteristic [40 CFR261.3]. The trigger levels for each type of hazardous wastecharacteristic are listed in Exhibit 3-1.
Listed Wastes
To determine if contaminated media must be managed as a hazardouswaste because it contains a listed waste, the site manager will need toreview process history information to determine how the original wastewas generated. A listed waste is any waste that appears on one of threeEPA lists of hazardous wastes: non-specific source wastes, specificsource wastes, or discarded commercial materials found in 40 CFR 261Subpart D. Types of listed hazardous waste are found in Exhibit 3-2.
If the facility owner/operator cannot determine if the waste is a listedhazardous waste, according to the memo, Management of RemediationWaste Under RCRA, (EPA 530-F-98-026, October 1998), states:
Where a facility owner/operator makes a good faith effort todetermine if a material is a listed hazardous waste but cannotmake such a determination because documentation regarding asource of contamination, contaminant, or waste is unavailableor inconclusive, EPA has stated that one may assume the source,contaminant or waste is not listed hazardous waste and,therefore, provided the material in question does not exhibit acharacteristic of hazardous waste, RCRA requirements do notapply.
Characterization Environmental Restoration Waste Guide
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EPA routinely issuesdirectives, letters, and otherpolicy interpretations thatclarify when wastes arehazardous. Examples include:RCRA Regulatory Status ofContaminated Groundwater,and RCRA Regulation ofWastes Handled by DOEFacilities.
Exhibit 3-1Properties of a Characteristic Hazardous Waste
Property Trigger Levels Test Method Reference
Ignitable Liquids with less tan 24 %alcohol and a flash point < 140(F
Solids capable of causing firethrough friction, absorption ofmoisture, or spontaneous chemical changes that whenignited will burn vigorouslyenough to create a hazard.
Closed CupTester specifiedin ASTMstandard D-93-80or inASTM standardD-3278-78.
40 CFR261.21
Corrosive Liquids with a pH �2 or pH�12.5
Liquids that corrode steel(SAE 1020) at a rate of 6.35mm/yr at 130 (F
EPA test methodset forth in260.20.
NACE standardTM-01-69
40 CFR261.22
Reactive Normally unstable and readilyundergoes violentchangewithout detonating.
Reacts violently or formspotentially explosive mixtureswith water .
Generates toxic gases, vapors,or fumes when mixed withwater.
It’s a cyanide or sulfidebearing waste capable ofgenerating toxic fumes.
It is capable of detonation orexplosive reaction if subjectedto an initiating source or ifheated under confinement.
It is a forbidden, Class A, or Class B explosive as defined in 49 CFR 173.51, 173.53, or173.88, respectively.
Not specified. 40 CFR261.23
Toxic Wastes that leach the constituents listed in 40 CFR 261.24 at or above specifiedconcentrations.
TCLP. 40 CFR261.24
Exhibit 3-1 outlines the propertiesof characteristic hazardous waste,including chemical properties,regulatory trigger levels, testingmethods and applicable statutoryreferences.
EH-413 June, 2000
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Exhibit 3-2Listed Hazardous Waste Types
Source Description Code Cite Occurrenceat DOE
Sites
Non-specific Sources Generic wastesproduced from avariety ofmanufacturing andindustrial processes. To determine if Flisting applies,information isneeded on thespecific process thatgenerated the wasteas well as theconstituents present.
F 40 CFR261.31
Spentsolvents(F001-F005)are commonat DOE sites
Specific Sources Wastes originatingfrom specificindustries. Thesewastes are less likelyto be present at DOEsites.
K 40 CFR261.32
NotcommonbecauseDOEproductionprocessesare generallynot listed
Discardedcommercial materials
Commercialchemical products,off-specificationproducts, or theresidue, container, orcontaminated mediaof a commercialchemical productthat has beendiscarded or intendedto be discarded.
P or U 40 CFR261.33
Notcommon butmay befound ifproductswerediscardedwithout use
3.4.2 When Is a Waste No Longer Hazardous Waste?
Media contaminated with a hazardous waste, must be managed ashazardous waste until it is either delisted, no longer “contains” listedwastes, and/or no longer exhibits a characteristic of a waste [40 CFR260.22].
Environmental restoration waste contaminated with listed wastes will nolonger be considered a hazardous waste if the contaminating waste is“delisted”. Delisting is a formal agency rulemaking procedure where theEPA Regional Administrator grants exemption to a waste listing on afacility- and waste-specific case-by-case basis. It is important to notethat a site may determine that it is more cost effective to manage anddispose of a hazardous waste as such without attempting to delist it(because delisting can be time-consuming and expensive).
Exhibit 3-2 describeslisted hazardous wastetypes by source ofgeneration, descriptionreference code,applicable regulationand frequency ofoccurrence at DOE sites.
Characterization Environmental Restoration Waste Guide
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Additional information ondelisting can be found in theEPA’s Fact Sheet DelistingPetitions and the PetitionReview Process, EPA-530-F-93-005, April 1993.
In addition to the contained-inpolicy, EPA has established alow-level threat variance (see40 CFR 268.44(h)(4),promulgated May 26, 1998) forcontaminated soils (seeChapter 5 for more details).
Chapter IV of DOE Order5400.5 outlines therequirements and guidelinesfor the release of property,applicable at the time that theproperty is released. TheOrder establishes thatauthorized limits must be metfor remedial actions to beconsidered complete and forproperty to be released withoutrestrictions on use due toresidual radioactive material. The OEPA has developedguidance on property releaseunder 5400.1. These are“Application of DOE 5400.4 –Requirements for Release andControl of PropertyContaining ResidualRadioactive Material”, and“Handbook for ControllingRelease for Reuse or Recycle ofNon-Real Property ContainingResidual RadioactiveMaterial”[http://www.eh.doe.gov/oepaunder “Policy and Guidance”].
Under EPA’s “contained in” policy, environmental media contaminatedwith a RCRA listed hazardous waste must be managed as hazardouswaste until the media no longer “contains” the hazardous waste. Amedia is considered to no longer “contain” hazardous waste (1) whenthey no longer exhibit a characteristic of hazardous waste; and (2) whenconcentrations of hazardous constituents from listed hazardous wastesare below health-based levels. In a rule published on August 18, 1992(57 FR 37193-37264), EPA codified the “contained in” policyspecifically for debris. Although the “contained in” policy has not beencodified for other media, EPA has interpreted the policy to apply to allcontaminated media that contain a hazardous waste.
The determination that soil, ground water, or debris no longer contains alisted waste is made by the EPA Regional Administrator (or authorizedstate) on a case-by-case basis. Once the medium has been determined tobe “clean” by the regulator, the medium can be returned to the ground(e.g., reinjected, applied to the land) without triggering the RCRASubtitle C restrictions.
Media contaminated with a characteristic waste is no longer hazardousonce it does not display the characteristic that caused the waste to bedefined as hazardous. Therefore, if the medium no longer meets thetrigger levels that define ignitability, corrosivity, reactivity, or toxicity,then the medium is no longer hazardous and can be disposed of, orreapplied to the land without triggering further RCRA Subtitle Crestrictions.
One potential exception to this circumstance is that once a characteristichazardous waste becomes subject to RCRA land disposal restrictions,the waste may still require treatment to the LDR treatment standard eventhough the waste itself no longer exhibits a hazardous wastecharacteristic. When a waste is hazardous by the characteristic oftoxicity, once the LDR treatment standards are triggered, treatment mustoccur to meet the universal treatment standards for all underlyinghazardous constituents reasonably expected to be present (or alternatestandards for contaminated soil), which, in some cases, are morestringent than the level at which the waste is defined to exhibit acharacteristic.
EH-413 June, 2000
1 NOTE: On January 12, 2000, the Secretary of Energy placed a moratorium on the Department’s release of volumetricallycontaminated metals pending a decision by the Nuclear Regulatory Commission (NRC) whether to establish national standards [News Release –Energy Secretary Richardson Blocks Nickel Recycling at Oak Ridge]. Therefore, the Department will not allow the release of scrap metals forrecycling if contamination from DOE operations is detected using appropriate, commercially available monitoring equipment and approvedprocedures. Consequently, the unrestricted release for recycling of scrap metals from radiation areas is suspended until improvements in releasecriteria and information management have been developed and implemented. Additionally, on July 13, 2000, the Secretary [SecretarialMemorandum-Release of Surplus and Scrap Materials] directed further action in four areas: (1) improvement of the Department’s release criteriaand monitoring practices; (2) expansion of efforts to promote reuse and recycling within the complex of DOE facilities; (3) improvement of theDepartment’s management of information about material inventories and releases; and, (4) the accelerated recovery of sealed sources asdescribed in the July 13, 2000, Secretarial memorandum. While updated release criteria and record keeping procedures are being developed andimplemented, the Department will undertake several activities to promote internal reuse and recycling. Finally, when revised directives andguidance are in place, the Department will require each DOE site to have local public participation before the site may resume the unrestrictedrelease for recycling of scrap metals from radiation areas.
Page 3-11
3.4.3 Radioactive Waste1
Under DOE M 435.1-1, radioactive waste is defined as any garbage,refuse, sludges, and other discarded material, including solid, liquid,semisolid, or contained gaseous material that must be managed for itsradioactive content.
In general, a project manager needs to conduct characterization of mediawith radioactive constituents to determine:
1) if the material requires remediation because the radionuclidespose an unacceptable risk to human health and the environmentor exceed regulatory guidelines,
2) the classification of waste (e.g., LLW, TRU, mixed), and 3) if the contaminated media can be released without restriction
due to radioactive content (see note below).
The minimum waste characterization requirements for TRU waste andLLW are set forth in DOE M 435.1-1. For TRU, the minimum wastecharacterization requirements, contained in Chapter III.I(2) of DOE M435.1-1, include:
� Physical and chemical characteristics of the waste;� Waste volume, including the waste and any stabilization or
absorbent media;� The weight of the waste container and its contents;� Identities, activities, and concentrations of major radionuclides;� Characterization date;� Generating source;� Packaging date; and� Any other information which may be needed to prepare and
maintain the disposal facility performance assessment ordemonstrate compliance with applicable performance objectives.
The following minimum waste characterization requirements, containedin Chapter IV.I(2) of DOE M 435.1-1 apply to LLW:
Characterization of environmentalmedia containing radioactivematerials must be conducted inorder to determine:
1. If the material posesunacceptable human healthor environmental risks, orif such material exceedsregulatory limits and mustbe remediated.
2. The classification of thewaste (e.g., HLW, TRU,LLW)
3. If the material can bereleased without restrictiondue to its radioactivecontent.
Characterization Environmental Restoration Waste Guide
Page 3-12
DOE has provided additionalguidance regarding radiologicalrelease requirements in Responseto Questions and Clarification ofRequirements and Processes:DOE 5400.5, Section II.5 andChapter IV Implementation(Requirements Relating toResidual Radioactive Material);dated 11/17/95[http://www.eh.doe.gov/oepa/under “Policy and Guidancc”].
� Physical and chemical characteristics of the waste;� Waste volume, including the waste and any stabilization or
absorbent media;� The weight of the waste container and its contents;� Identities, activities, and concentrations of major radionuclides;� Characterization date;� Generating source; and� Any other information which may be needed to prepare and
maintain the disposal facility performance assessment ordemonstrate compliance with applicable performance objectives.
Typically, each of these minimum requirements are specified in moredetail through a receiving facility’s WAC.
Conditions under which material with radioactivity may be releaseddepends in part on the media of concern. Media that is non-porous andnot “bulk” material (e.g., steel debris resulting from facility demolition)may be released without restrictions due to radioactivity using surfacecontamination criteria established in DOE Order 5400.5 or NRC’sRegulatory Guide 1.86. Consequently, for non-porous materials,characterization is typically focused on ensuring that the average,maximum, and removable surface contamination meets release criteria.A characterization survey of this type generally consists of surfacesmears and measurements of the disintegrations per minute (dpm), takenwith a hand-held meter.
For porous material (e.g., concrete debris) or bulk material (e.g., soil,ground water), characterization for radioactivity is measured in twoways: dose and curie content counts. The type of characterizationrequired to establish that a remedial action is complete is based onwhether or not generic guideline values exist. Generic guidelines arecleanup values that have been established independently of the site andare taken from existing radiation protection standards. For example,DOE 5400.5 establishes the following guideline value for Ra-226: 5pCi/g of Ra-226, averaged over the first 15 cm of soil below the surfaceand 15 pCi/g of Ra-226, averaged over 15-cm-thick layers of soil morethan 15 cm below the surface. Characterization to demonstrate that amedia meets generic guideline values is generally measured using curiecontent counts.
If generic guidelines do not exist, specific property guidelines must bederived from a basic dose limit, using specific property models and data. The basic dose limit, as established in DOE Order 5400.5, is 100 mremper year above background to members of the public, taking into accountall exposure modes and all DOE sources of radiation. However, forpractical purposes, DOE has interpreting this dose limit to be constrictedto 30 mrem/yr.
EH-413 June, 2000
Page 3-13
“Remediation waste” meansmedia containing PCBs as aresult of a spill, release, orother unauthorized disposal.
For more information, seePCB Spill Response andNotification Requirements,EH-231-059/1294, andRegulatory RequirementsAffecting Disposal of Asbestos-Containing Waste, EH-413-062/1195, available from theOEPA web site (see below).
To determine specific property guidelines for radioactive wastes, a sitemust additionally consider all significant exposure pathways forreasonably expected uses, including exposures to workers conductingcorrective actions at disposal facilities. Specific property guidelinesgoverning LLW facilities must also take into account unforseentemporary human intrusion into the waste disposal facility followingclosure. Under DOE 435.1 IV (P)(2)(h), dose limits of 100millirems/year and 500 millirems total effective dose equivalent,excluding airborne radon are set for chronic and acute exposurescenarios involving inadvertent human intruders.
3.4.4 Characterization of Other Wastes (PCB and Asbestos)
A determination that a waste does not meet the definition of eitherhazardous, radioactive, or mixed waste, does not mean that the waste isexempt from any regulatory requirements. Non-hazardous and non-radioactively contaminated wastes may still be subject to Federal solidwaste restrictions, State requirements, or on-site and off-site wasteacceptance criteria. If environmental restoration wastes are generatedthat are not characterized as either hazardous, radioactive, or mixedwaste, the project manager should consult State and local regulatoryagencies to investigate the potential for regulatory restrictions on themanagement of that waste.
Two special categories of materials often encountered as part ofremediation actions are PCBs and asbestos-containing materials. Acritical piece of characterization information for PCBs is theconcentration of PCBs. In particular, it is important to determine (1)whether PCBs are greater than 50 ppm or greater than 500 ppm becausedifferent disposal regulations apply depending on these concentrationthresholds, and (2) whether the PCB material is “remediation waste” asdefined in 40 CFR 761.61 or another type of regulated PCB article.
The TSCA regulations do allow certain assumptions to be made aboutthe PCB concentration of spilled material if the actual concentration isunknown. For example, fluids of unknown PCB concentration releasedas the result of a transformer rupture must be assumed to have a PCBconcentration of greater than or equal to 500 ppm if the transformer’snameplate indicates that the transformer contains PCB dielectric fluid orif dielectric fluid with a PCB concentration greater than or equal to 500ppm is known or suspected to have been added to the transformer.
For asbestos, critical characterization information is whether the waste isfriable or non-friable, and which category the material is classified in, asshown in Exhibit 3-3.
In characterizing environmentalrestoration wastes containingPCBs and asbestos bearingmaterials, two elements must beconsidered:
1. The concentration ofPCBs.
2. Whether or not theasbestos bearing materialis friable or non-friable,and which category thematerial is classified in,as shown in Exhibit 3-3.
Characterization Environmental Restoration Waste Guide
Page 3-14
Friable asbestos material isdefined as any materialcontaining more than 1percent asbestos that, whendry, can be crumbled,pulverized, or reduced topowder by hand pressure. Non-friable asbestos is anymaterial that does not meetthis definition.
See Regulatory RequirementsAffecting Disposal of Asbestos-Containing Waste, EH-413-062/1195 (November, 1995) onthe EH-41 web site,[http://www.eh.doe.gov/oepa/under “Policy & Guidance].
Exhibit 3-3Categories of Asbestos-Containing Material
Category Definition
Category I non-friable asbestos-containing material
Asbestos-containing packings, gaskets,resilient floor covering, and asphaltroofing products containing more than 1percent asbestos
Category II non-friable asbestos-containing material
Any material, except Category I non-friable asbestos-containing materials,containing more than 2 percent asbestosthat, when dry, cannot be crumbled,pulverized, or reduced to powder byhand pressure.
Regulated asbestos-containing material Friable asbestos material; Category Inon-friable asbestos containing materialthat has become friable; Category I non-friable asbestos-containing material thatwill be subject to sanding, grinding,cutting or abrading; and Category II non-friable asbestos-containing material thathas a high probability of becoming or hasbecome crumbled, pulverized, or reducedto powder by the forces expected to acton the material in the course ofdemolition or renovation operations.
Asbestos-containing waste materials Regulated asbestos-containing materialswaste and materials contaminated withasbestos during demolition andrenovation operations, includingdisposable equipment and clothing.
EH-413 June, 2000
Page 4-1
Management requirementsfor three types of media arepresented in the followingthree chapters:
Chapter 4 Ground WaterChapter 5 SoilsChapter 6 Debris
For more information onground water remediationstrategies, please refer to theGuide to Ground WaterRemediation at CERCLAResponse Action and RCRACorrective Action Sites(DOE/EH-0505, October1995), [http://www.eh.doe.gov/oepaunder “Policy & Guidance”].
Chapter 4Management of Contaminated Ground WaterDuring Environmental Restoration Projects
This chapter addresses how to manage ground water when it is anenvironmental restoration waste. The requirements for handling,managing, and disposing of ground water as an environmentalrestoration waste are provided in separate sections for hazardous wastes,radioactive wastes, and mixed wastes. The following exhibit outlineseach section of this chapter and its contents:
Exhibit 4-1Summary of Chapter Sections
Section Contents
4.1 - Summary of Major Requirements(page 4-1)
Overview of Main Messages
4.2- Summary of Ground WaterManagement Technologies (page 4-3)
Includes descriptions, information onamount of waste generated, residualwaste generated, and follow-on activitiesfor a variety of treatment technologies
4.3 - Basic Management RequirementsDuring Pre-Treatment, Treatment, andPost-Treatment Phases for HazardousWastes (page 4-3 )
Discusses regulations that are triggeredas a result of different managementstrategies for hazardous wastes that aregenerated as environmental restorationwastes
4.4 - Basic Management RequirementsDuring Pre-Treatment, Treatment, andPost-Treatment Phases for RadioactiveWastes (page 4-18)
Discusses regulations that are triggeredas a result of different managementstrategies for radioactive wastes that aregenerated as environmental restorationwastes
4.5 - Basic Management RequirementsDuring Pre-Treatment, Treatment, andPost-Treatment Phases for Mixed Wastes(page 4-22)
Discusses regulations that are triggeredas a result of different managementstrategies for mixed wastes that aregenerated as environmental restorationwastes
4.6 - Alternate Compliance Options(Page 4-23)
Discusses a variety of alternatives formeeting regulatory requirements
4.1 Summary of Major Requirements For Ground Water
The following are the main points explained in detail in this chapter:
Ground Water Environmental Restoration Waste Guide
Page 4-2
The “contained-in policy”was first articulated by EPAin 1986 and is the basis forregulating ground water ashazardous wastes. Manystates have their ownpolicies. More informationcan be found in the EH-413menorandum, Managementof Remediation Waste UnderRCRA, December 21, 1999,http://www.eh.doe.gov/oepa under “Policy & Guidance”and in Chapter 3.
Ex-situ management options arediscussed in detail beginning onpage 4-15.
“Generated” is a RCRAconcept meaning a waste issubject to regulatoryrequirements becauseregeneration of previouslydisposed or dischargedwaste is considered to be thesame as “generation.”
• Ground water contaminated with a listed hazardous waste isconsidered hazardous under the “contained in” policy or may behazardous if it exhibits a characteristic of a hazardous waste. Aslong as ground water exhibits the characteristic of a hazardouswaste or “contains” the listed waste, it must be managed as ahazardous waste and is subject to the restrictions of eitherRCRA Subtitle C or the more stringent requirements of anauthorized state program.
• Ground-water management strategies can be classified into threegeneral types of management approaches, each of which leadsproject managers to consider different types of environmentalrestoration waste requirements: (1) monitored naturalattenuation, (2) active in-situ treatment (e.g., bioremediation, in-situ well stripping) , or (3) ex-situ management (e.g., extraction,treatment, and discharge). For example, during monitorednatural attenuation, environmental restoration wastes are seldomgenerated, and the focus is on monitoring to ensure theattenuation is occurring as predicted. During active in-situmanagement approaches, the focus is also on monitoring theperformance of the remedy but project managers also mustdetermine how to manage any treatment residuals (e.g., vapors)generated during treatment. During ex-situ management, thefocus of environmental restoration waste management is oncomplying with the regulatory requirements applicable to boththe water extracted and any wastes generated as residuals fromtreatment.
• During ex-situ treatments, the contaminated ground water extracted from the subsurface can be treated, and either (1)reinjected into an aquifer, (2) discharged under a NPDES permit,(3) sent to a Publicly Owned Treatment Works (POTW) orFederally Owned Treatment Works (FOTW), or (4) sent to anon-site wastewater treatment plant. Each of these dischargeoptions impose different environmental restoration wastehandling requirements (which are explained in the appropriatesections of this Chapter).
• Ground water containing radionuclides, or radionuclides andhazardous wastes (mixed wastes), will be subject to radioactivewaste management or mixed waste requirements, respectivelydepending on how the ground water is managed during aremediation.
• DOE’s requirements for remediating releases of radionuclides to
DOE M 435.1-1 (July 1999) describes radioactive and mixed wastemanagement requirements. Mixedwaste management requirements areaddressed specifically in sections IIIB(1) (for transuranic wastes), and IVB(1) (for low-level wastes).[http://www.explorer.doe.gov:1776/htmls/currentdir.html]
EH-413 June, 2000
Page 5-1
Environmental restoration wastesinclude contaminated soils thatare managed during a responseaction, including residuals fromthat management, and anyresiduals produced during in-situmanagement.
Additional guidance on managingcontaminated sediments can befound from several sourcesincluding: Contaminated SedimentManagement Strategy, EPA823-R-98-001, April 1998; Handbook -Remediation of ContaminatedSediments, EPA/625/6-91/028,April, 1991; and NationalConference on Management andTreatment of ContaminatedSediments, EPA/625/R-98/001,August 1998.
Chapter 5 Management of Contaminated Soil During
Environmental Restoration Projects
This chapter describes the requirements for managing soil when it is anenvironmental restoration waste contaminated with hazardous orradioactive wastes (or mixed wastes). Because of the many physicalsimilarities between soils and sediments, and similar managementoptions used to manage soils and sediments that are dredged, this chapteralso applies to contaminated sediments. The chapter is organized asoutlined in Exhibit 5-1.
Exhibit 5-1Summary of Chapter Sections
Section Contents
5.1 Summary of Major Requirements(page 5-2 )
Overview of main messages.
5.2 Concepts and Definitions (page 5-3) Definitions of terms and key conceptsused throughout the chapter.
5.3 Summary of Soil TreatmentTechnologies (page 5-5)
Brief technology descriptions andresidual wastes typically generated for avariety of treatment technologies.
5.4 Basic Management RequirementsDuring Pre-Treatment, Treatment, andPost-Treatment Phases for HazardousSoil Environmental Restoration Wastes(page 5-5)
Discusses requirements and managementstrategies for hazardous soils that areenvironmental restoration wastes.
5.5 Basic Management RequirementsDuring Pre-Treatment, Treatment, andPost-Treatment Phases for RadioactiveSoil Environmental Restoration Wastes(page 5-24)
Discusses requirements and managementstrategies for radioactively contaminatedsoils that are environmental restorationwastes.
5.6 Basic Management RequirementsDuring Pre-Treatment, Treatment, andPost-Treatment Phases for Mixed Waste(page 5-32)
Discusses requirements and managementstrategies for mixed waste soils that areenvironmental restoration wastes.
5.7 Managing PCB- and Asbestos-Containing Soil Wastes (page 5-32)
Discusses requirements associated withmanaging contaminated PCB andasbestos-containing soil wastes.
5.8 Compliance Options for ManagingSoil Environmental Restoration Wastes(page 5-34)
Discusses a variety of alternatives formeeting regulatory requirements.
Soil Environmental Restoration Waste Guide
Page 5-2
EPA defines placement to includeexcavation and management ofwastes in another “unit.” Placement does not includeconsolidation within an area ofcontamination, capping in place,or in-situ treatment.
Universal treatment standards(UTS) are promulgated by EPAfor each hazardous constituent in40 CFR 268. Different standardsare established for waste watersand non-waste waters.
5.1 Summary of Major Requirements
The major requirements affecting soils that are generated asenvironmental restoration wastes during a response action are thefollowing.
& The main regulatory drivers that determine how projectmanagers must manage soil environmental restoration wastesthat contain listed wastes or exhibit a characteristic of ahazardous waste are those requirements that determined to beapplicable or relevant and appropriate requirements (ARARs)under CERCLA, or requirements that must be met during and atthe conclusion of a RCRA corrective action. These primarilyare the Land Disposal Restrictions (LDRs) under RCRA orequivalent State programs; handling requirements that applywhile wastes are being managed; and operating requirements forunits in which these wastes are managed.
• Because EPA has established presumptive remedies for severaltypes of soil remediation projects, it is possible to determine thelikely technologies that will be used for soil remediation early inthe planning of a response action and, therefore, begin toanticipate issues with management of contaminated soil. Exhibit5-2 summarizes the presumptive remedies that EPA hasestablished for different types of contaminants in soils.
• In 1998, EPA promulgated specific LDR treatment standards forcontaminated soils (63 FR 28605, May 26, 1998). Thesestandards require either compliance with the original (processwaste) treatment standards or reduction in concentrations ofunderlying hazardous constituents reasonably expected to bepresent at 10 times their universal treatment standard. Thestandard established is reduction by 90 percent with thetreatment for any given constituent capped at 10 times theuniversal treatment standard.
• As part of the 1998 Phase IV LDR rulemaking, EPA alsoestablished a site-specific, risk-based, “minimize threats”variance that may be appropriate to consider for lowconcentrations of contaminants in soils. This variance allowscontaminated soil to no longer be subject to RCRA Subtitle Crequirements.
EH-413 June, 2000
Page 5-3
This includes formal WAC andrequirements contained inpermits and operatingprocedures.
For definitions of listed andcharacteristic hazardous waste,see Chapter 3: Characterizationof Environmental RestorationWastes.
Exhibit 5-2EPA Presumptive Remedies for Contaminated Soils
PresumptiveRemedy
PresumptiveTechnologies
Reference
Volatile organiccompounds(VOCs) in Soils
� Soil Vapor Extraction(SVE)
� Thermal Desorption� Incineration
EPA Directive 9355.0-48FS; EPA 540-F-93-048;PB 93-9633346September 1993
Metals in Soils Principal Threats� Recovery/ reclamation,
or� Immobilization
Low Level Threat Wastes� Containment
EPA Directive 9355.0-72FS; EPA 540-F-98-054;PB99-963301September 1999
Wood Treaters(semi-volatilecontaminantssuch asPolynuclearAromaticHydrocarbons)
� Bioremediation� Thermal Desorption� Incineration� Immobilization
EPA Directive 9200.5-162;EPA/540/R-95/128; PB 95-963410December 1995
• The requirements for managing radioactive soil wastes arelargely specified in DOE Order 435.1 for Radioactive WasteManagement and is accompanying Manual.
• For remediation projects where wastes will be sent to an existingmanagement facility, the WAC for the receiving facility definemany of the conditions that must be met to properly handle andtransport the radioactive waste.
• If project managers will construct new radioactive wastefacilities as part of a remediation project, the DOE Order andManual contain detailed design and performance criteria thatmust be met.
5.2 Concepts and Definitions
There are several key concepts and definitions critical to understandinghow to manage hazardous soil, several of which EPA newly introducedas part of its 1998 Phase IV LDR rulemaking that specificallyestablished treatment standards for contaminated soil:
Soil Environmental Restoration Waste Guide
Page 5-4
These definitions are establishedor clarified in the 1998 Phase IVLDR rulemaking (63 FR 28605,May 26, 1998).
EPA re-emphasized theseprinciples in the preamble to therecent Phase IV LDR rulemaking.
Soil means materials that are primarily of geologic origin such as sand,silt, loam, or clay that are indigenous to the natural geologicenvironment. It is important to note that CERCLA defines soil as havinga particle size under two millimeters, while the RCRA defines soil ashaving a particle size under nine millimeters.
Hazardous soil means soil that either contains listed waste or exhibits acharacteristic of hazardous waste.
Contaminated soil means soil (as defined above) that is both hazardouscontaminated soil (soil that contains a listed hazardous waste or exhibitsa characteristic of hazardous waste) and other soil (such asdecharacterized soil) that may be subject to the LDRs.
Principles for Evaluating When LDRs Apply to Contaminated Soils. EPA relies on three principles when evaluating the potentialapplicability of LDRs to contaminated soil:
1. Land disposal restrictions only attach to prohibited hazardouswaste (or hazardous contaminated soil) when it is (a) generatedand (b) placed in a land disposal unit.
2. Once a decision has been made to generate and re-disposecontaminated soils on land, LDRs generally only apply tocontaminated soils that contain hazardous wastes (unless aregulatory option, such as a corrective action management unit,is used).
3. Once LDRs attach (generally at the point of generation, Seeprinciple 1), to any given hazardous waste or volume ofhazardous contaminated soil, the LDR treatment standardscontinue to apply until they are met.
Timing for evaluating LDRs. Because of their potential impacts andinherent complexities, it is extremely important to determinewhether soil wastes generated during a CERCLA remedial action orRCRA corrective action is subject to LDRs as early as possible inthe Remedial Investigation/Feasibility Study (RI/FS) or RemedialField Investigation/Corrective Measures Study (RFI/CMS) process. Compliance with LDRs may affect the ability to land dispose ofrestricted wastes, and, therefore, may end up representing a majoruncertainty for the entire project if not evaluated sufficiently. Becauseof the requirements to conduct treatment for many soil wastes for allunderlying hazardous constituents reasonably expected to be present atmore than 10 times the universal treatment standard, LDR issues may be
EH-413 June, 2000
Page 5-5
For extensive information on soiltreatment technologies, see theRemediation TechnologiesScreening Matrix and ReferenceGuide, Version 3.0, on the FederalRemediation TechnologiesRoundtable homepage atwww.frtr.gov.
Wastes that are not managedduring a response action (i.e.,those left in place) are notenvironmental restoration wastes(see Chapter 1, Section 1.2). However, wastes that are cappedin place or treated in place areconsidered to be “managed” and,therefore, are included in thisGuide.
Requirements apply to CERCLAactions to the degree they areapplicable or relevant andappropriate. In some cases, theRCRA interim statusrequirements of 40 CFR 265 maybe deemed relevant andappropriate rather than thoseoutlined in 40 CFR 264.
a significant problem and require early evaluation even for soilcontaminated with low concentrations of hazardous constituents.
5.3 Summary of Soil Treatment Technologies
Because the regulatory requirements for soils that are environmentalrestoration wastes differ significantly depending on what technologiesare selected and what residuals are generated, it is important for projectmanagers to identify potentially appropriate technologies early in projectplanning. Exhibit 5-3, therefore, briefly describes some of the morecommon in-situ treatment technologies for hazardous soil and theresulting waste residuals (and do not attempt to suggest whichtechnologies are better or more feasible to use). From a remediationwaste management perspective, the main advantage of in-situ treatmentis that it allows soil to be treated without being excavated andtransported, resulting in potentially significant cost savings. However,in-situ treatment generally requires longer time periods, and there is lesscertainty about the uniformity of treatment because of the variability insoil and because the efficacy of the process is more difficult to verify.
Exhibit 5-4 briefly describes some of the more common ex-situtreatment technologies for hazardous soil and the resulting wasteresiduals. The main advantage of ex-situ treatment is that it generallyrequires shorter time periods, and there is more certainty about theuniformity of treatment because of the ability to homogenize, screen, andcontinuously mix the soil. However, ex-situ treatment requiresexcavation of soils, leading to increased costs and engineering forequipment, possible permitting, and material handling/worker exposureconsiderations.
Exhibit 5-5 briefly describes the potentially available technologies forradioactively contaminated soils.
5.4 Basic Management Requirements During Pre-Treatment,Treatment, and Post-Treatment Phases for Hazardous SoilEnvironmental Restoration Wastes
The waste handling requirements for soils that are a hazardousenvironmental restoration waste differ in large part on whethertechnologies are implemented in-situ or ex-situ (e.g., whether or not theyinvolve excavation and placement of wastes). This chapter describesmanagement requirements for both in-situ and ex-situ managementduring pre-treatment, treatment, and post-treatment phases of a project.
Soil Environmental Restoration Waste Guide
Page 5-6
5.4.1 In-Situ Management - Soils Managed as Hazardous Waste
For in-situ management approaches, the primary requirements governingmanagement of environmental restoration wastes focus on propermanagement of any waste residuals generated and on proper closure andmonitoring of the waste “unit” itself that contains the contaminated soil. Exhibit 5-6 summarizes potentially applicable RCRA standards for thesetypes of response actions.
EH
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ity
of n
atur
ally
occ
urri
ng m
icro
bes
isst
imul
ated
by
circ
ulat
ing
wat
er-b
ased
sol
utio
nsth
roug
h co
ntam
inat
ed s
oils
to e
nhan
ce in
-sit
ubi
olog
ical
deg
rada
tion
of
orga
nic
cont
amin
ants
.N
utri
ents
, oxy
gen,
or
othe
r am
endm
ents
may
be
used
to e
nhan
ce b
iode
grad
atio
n an
d co
ntam
inan
t des
orpt
ion
from
sub
surf
ace
mat
eria
ls.
Bio
rem
edia
tion
tech
niqu
es h
ave
been
succ
essf
ully
use
d to
rem
edia
te s
oils
cont
amin
ated
wit
h pe
trol
eum
hydr
ocar
bons
, sol
vent
s, p
esti
cide
s, w
ood
pres
erva
tive
s, a
nd o
ther
org
anic
chem
ical
s.
Bio
rem
edia
tion
can
not d
egra
de in
orga
nic
cont
amin
ants
, but
it m
ay s
tabi
lize
or
rem
ove
inor
gani
cs b
y ad
sorp
tion
, upt
ake,
accu
mul
atio
n, a
nd c
once
ntra
tion
inm
icro
and
mac
roor
gani
sms.
Lan
d T
reat
men
tC
onta
min
ated
sur
face
soi
l is
trea
ted
in p
lace
by
tillin
gto
ach
ieve
aer
atio
n, a
nd if
nec
essa
ry, b
y ad
diti
on o
fam
endm
ents
. P
erio
dic
till
ing,
to a
erat
e th
e w
aste
,en
hanc
es th
e bi
olog
ical
act
ivit
y.
Lan
d tr
eatm
ent h
as b
een
prov
ensu
cces
sful
in tr
eati
ng p
etro
leum
hydr
ocar
bons
and
oth
er le
ss v
olat
ile,
biod
egra
dabl
e co
ntam
inan
ts.
Lan
d tr
eatm
ent c
anno
t deg
rade
inor
gani
cco
ntam
inan
ts, b
ut it
may
sta
bili
ze o
rre
mov
e in
orga
nics
by
adso
rpti
on, u
ptak
e,ac
cum
ulat
ion,
and
con
cent
rati
on in
mic
ro a
nd m
acro
orga
nism
s. T
he m
ore
chlo
rina
ted
or n
itra
ted
the
com
poun
d, th
em
ore
diff
icul
t it i
s to
deg
rade
.
Soi
lE
nviro
nmen
tal R
esto
ratio
n W
aste
Gui
de
Tre
atm
ent
Tec
hnol
ogy
Bri
ef T
echn
olog
y D
escr
ipti
onA
pplic
able
Con
tam
inan
ts
Res
idua
l Was
te G
ener
ated
P
age
5-8
Nat
ural
Att
enua
tion
N
atur
al s
ubsu
rfac
e pr
oces
ses
- su
ch a
s di
luti
on,
vola
tili
zati
on, b
iode
grad
atio
n, a
dsor
ptio
n, a
ndch
emic
al r
eact
ions
wit
h su
bsur
face
mat
eria
ls -
are
allo
wed
to r
educ
e co
ntam
inan
t con
cent
rati
ons
toac
cept
able
leve
ls.
Tar
get c
onta
min
ants
for
nat
ural
atte
nuat
ion
are
VO
Cs,
SV
OC
s, a
ndpe
trol
eum
hyd
roca
rbon
s. P
esti
cide
s ca
nal
so b
e al
low
ed to
nat
ural
ly a
tten
uate
,bu
t the
pro
cess
may
be
less
eff
ecti
ve a
ndm
ay b
e ap
plic
able
to o
nly
som
eco
mpo
unds
wit
hin
the
grou
p.
Nat
ural
att
enua
tion
can
not d
egra
dein
orga
nic
cont
amin
ants
, but
it m
ayst
abil
ize
or r
emov
e in
orga
nics
by
adso
rpti
on, u
ptak
e, a
ccum
ulat
ion,
and
conc
entr
atio
n in
mic
ro a
ndm
acro
orga
nism
s. S
ome
met
als
may
be
only
tem
pora
rily
imm
obil
ized
wit
hre
mob
iliz
atio
n oc
curr
ing
whe
n na
tura
lat
tenu
atio
n re
-est
abli
shes
oxy
gena
ted
soil
con
diti
ons.
Phy
tore
med
iati
on
Phy
tore
med
iati
on is
a s
et o
f pr
oces
ses
that
use
pla
nts
to c
lean
con
tam
inat
ion
in s
oil,
grou
nd w
ater
, sur
face
wat
er, s
edim
ent,
and
air.
Phy
tore
med
iati
on m
ay b
e ap
plic
able
for
the
rem
edia
tion
of
met
als,
pes
tici
des,
solv
ents
, exp
losi
ves,
cru
de o
il,
Pol
ycyc
lic
Aro
mat
ic H
ydro
carb
ons
(PA
Hs)
, and
land
fill
leac
hate
.
Phy
tore
med
iati
on is
not
eff
ecti
ve f
orso
me
inor
gani
cs o
r st
rong
ly-s
orbe
d (e
.g.,
PC
Bs)
and
wea
kly
sorb
ed c
onta
min
ants
. C
onta
min
ants
in d
eepe
r so
ils
wil
l be
left
in p
lace
bec
ause
the
dept
h of
the
trea
tmen
t zon
e is
dep
ende
nt u
pon
the
type
(s)
of p
lant
s us
ed in
the
phyt
orem
edia
tion
pro
cess
.
PH
YSI
CA
L/C
HE
MIC
AL
TR
EA
TM
EN
T
Ele
ctro
kine
tic
Sep
arat
ion
The
Ele
ctro
kine
tic
Rem
edia
tion
(E
R)
proc
ess
rem
oves
met
als
and
orga
nic
cont
amin
ants
fro
m lo
wpe
rmea
bili
ty s
oil,
mud
, slu
dge,
and
mar
ine
dred
ging
.E
R u
ses
elec
troc
hem
ical
and
ele
ctro
kine
tic
proc
esse
sto
des
orb,
and
then
rem
ove,
met
als
and
pola
r or
gani
cs.
Thi
s in
-sit
u so
il p
roce
ssin
g te
chno
logy
is p
rim
aril
y a
sepa
rati
on a
nd r
emov
al te
chni
que
for
extr
acti
ngco
ntam
inan
ts f
rom
soi
ls.
Tar
gete
d co
ntam
inan
ts f
or e
lect
roki
neti
cse
para
tion
are
hea
vy m
etal
s, a
nion
s, a
ndpo
lar
orga
nics
in s
oil.
Oxi
dati
on/r
educ
tion
rea
ctio
ns c
anno
t be
used
on
petr
oleu
m h
ydro
carb
ons.
In
addi
tion
, the
ER
pro
cess
may
fac
ilit
ate
the
form
atio
n of
und
esir
able
pro
duct
s,su
ch a
s ch
lori
ne g
as.
Fra
ctur
ing
Pre
ssur
ized
air
is in
ject
ed b
enea
th th
e su
rfac
e to
deve
lop
crac
ks in
low
per
mea
bili
ty a
ndov
er-c
onso
lida
ted
sedi
men
ts, o
peni
ng n
ewpa
ssag
eway
s th
at in
crea
se th
e ef
fect
iven
ess
of m
any
insi
tu p
roce
sses
and
enh
ance
ext
ract
ion
effi
cien
cies
.
Fra
ctur
ing
is a
ppli
cabl
e to
the
com
plet
era
nge
of c
onta
min
ant g
roup
s, w
ith
nopa
rtic
ular
targ
et g
roup
.
The
pot
enti
al e
xist
s to
ope
n ne
wpa
thw
ays
for
the
unw
ante
d sp
read
of
cont
amin
ants
(e.
g., D
NA
PL
s).
EH
-413
June
, 200
0
Tre
atm
ent
Tec
hnol
ogy
Bri
ef T
echn
olog
y D
escr
ipti
onA
pplic
able
Con
tam
inan
ts
Res
idua
l Was
te G
ener
ated
P
age
5-9
Soi
l Flu
shin
gW
ater
, or
wat
er c
onta
inin
g an
add
itiv
e to
enh
ance
cont
amin
ant s
olub
ilit
y, is
app
lied
to th
e so
il o
r in
ject
edin
to th
e gr
ound
wat
er to
rai
se th
e w
ater
tabl
e in
to th
eco
ntam
inat
ed s
oil z
one.
Con
tam
inan
ts a
re le
ache
d in
toth
e gr
ound
wat
er, w
hich
is th
en e
xtra
cted
and
trea
ted.
The
targ
et c
onta
min
ant g
roup
for
soi
lfl
ushi
ng is
inor
gani
cs, i
nclu
ding
radi
oact
ive
cont
amin
ants
. T
his
tech
nolo
gy m
ay b
e us
ed to
trea
t VO
Cs,
SV
OC
s, f
uels
, and
pes
tici
des,
but
it m
aybe
less
cos
t-ef
fect
ive
than
alt
erna
tive
tech
nolo
gies
for
thes
e co
ntam
inan
ts.
The
add
itio
n of
env
iron
men
tall
yco
mpa
tibl
e su
rfac
tant
s m
ay b
e us
ed to
incr
ease
the
solu
bili
ty o
f so
me
orga
nic
com
poun
ds; h
owev
er, t
he f
lush
ing
solu
tion
may
alt
er th
e ph
ysic
al/c
hem
ical
prop
erti
es o
f th
e so
il.
Soi
l Vap
or E
xtra
ctio
nV
acuu
m is
app
lied
thro
ugh
extr
acti
on w
ells
to c
reat
e a
pres
sure
/con
cent
rati
on g
radi
ent t
hat i
nduc
es g
as-p
hase
vola
tile
s to
dif
fuse
thro
ugh
soil
to e
xtra
ctio
n w
ells
.T
he p
roce
ss in
clud
es a
sys
tem
for
han
dlin
g of
f-ga
ses.
Thi
s te
chno
logy
als
o is
kno
wn
as in
-sit
u so
il v
enti
ng,
in-s
itu
vola
tili
zati
on, e
nhan
ced
vola
tili
zati
on, o
r so
ilva
cuum
ext
ract
ion.
The
targ
et c
onta
min
ant g
roup
s fo
r in
-sit
uso
il v
apor
ext
ract
ion
are
VO
Cs
and
som
efu
els.
Bec
ause
the
proc
ess
invo
lves
the
cont
inuo
us f
low
of
air
thro
ugh
the
soil
, it
ofte
n pr
omot
es b
iode
grad
atio
n of
low
-vo
lati
lity
org
anic
com
poun
ds th
at m
ay b
epr
esen
t.
In-s
itu
soil
vap
or e
xtra
ctio
n w
ill n
otre
mov
e in
orga
nics
, hea
vy o
ils,
met
als,
PC
Bs,
or
diox
ins
from
the
soil
.
Sol
idif
icat
ion/
Sta
bili
zati
onC
onta
min
ants
are
phy
sica
lly
boun
d or
enc
lose
d w
ithi
na
stab
iliz
ed m
ass
(sol
idif
icat
ion)
, or
chem
ical
rea
ctio
nsar
e in
duce
d be
twee
n th
e st
abil
izin
g ag
ent a
ndco
ntam
inan
ts to
red
uce
thei
r m
obil
ity
(sta
bili
zati
on).
The
targ
et c
onta
min
ant g
roup
for
in-s
itu
soli
difi
cati
on/s
tabi
liza
tion
is g
ener
ally
inor
gani
cs, i
nclu
ding
rad
ionu
clid
es.
The
tech
nolo
gy c
an d
estr
oy o
r re
mov
e so
me
orga
nics
and
imm
obil
ize
mos
t ino
rgan
ics
in c
onta
min
ated
soi
ls.
Sol
idif
icat
ion/
stab
iliz
atio
n ha
s ha
dli
mit
ed e
ffec
tive
ness
aga
inst
SV
OC
s, a
ndpe
stic
ides
and
no
effe
ctiv
enes
s ag
ains
tV
OC
s an
d m
ost f
uels
; how
ever
, sys
tem
sde
sign
ed to
be
mor
e ef
fect
ive
in tr
eati
ngor
gani
cs a
re c
urre
ntly
bei
ng d
evel
oped
and
test
ed.
TH
ER
MA
L T
RE
AT
ME
NT
The
rmal
ly E
nhan
ced
Soi
lV
apor
Ext
ract
ion
(SV
E)
Ste
am/h
ot a
ir in
ject
ion
or e
lect
rom
agne
tic/
fibe
rop
tic/
radi
o fr
eque
ncy/
elec
tric
al c
ondu
ctio
n he
atin
g is
used
to in
crea
se th
e m
obil
ity
of v
olat
iles
and
fac
ilit
ate
extr
acti
on. T
he p
roce
ss in
clud
es a
sys
tem
for
han
dlin
gof
f-ga
ses.
Thi
s sy
stem
is d
esig
ned
to tr
eat S
VO
Cs
but w
ill c
onse
quen
tly
trea
t VO
Cs.
T
herm
ally
enh
ance
d S
VE
tech
nolo
gies
are
also
eff
ecti
ve in
trea
ting
som
epe
stic
ides
and
fue
ls, d
epen
ding
on
the
tem
pera
ture
s ac
hiev
ed b
y th
e sy
stem
.
The
rmal
ly e
nhan
ced
SV
E w
ill n
otre
mov
e in
orga
nics
, hea
vy o
ils,
met
als,
PC
Bs,
or
diox
ins
from
the
soil
. A
fter
appl
icat
ion
of th
is p
roce
ss, s
ubsu
rfac
eco
ndit
ions
are
exc
elle
nt f
orbi
odeg
rada
tion
of
resi
dual
con
tam
inan
ts.
OT
HE
R T
RE
AT
ME
NT
Soi
lE
nviro
nmen
tal R
esto
ratio
n W
aste
Gui
de
Tre
atm
ent
Tec
hnol
ogy
Bri
ef T
echn
olog
y D
escr
ipti
onA
pplic
able
Con
tam
inan
ts
Res
idua
l Was
te G
ener
ated
P
age
5-10
Con
tain
men
t (is
a g
ood
trea
tmen
t tec
hnol
ogy
inth
ese
circ
umst
ance
s)
Con
tain
men
t inc
lude
s ve
rtic
al o
r ho
rizo
ntal
bar
rier
s. I
tca
n pr
ovid
e su
stai
ned
isol
atio
n of
con
tam
inan
ts a
ndpr
even
t mob
iliz
atio
n of
sol
uble
com
poun
ds o
ver
long
peri
ods
of ti
me.
It a
lso
redu
ces
surf
ace
wat
erin
filt
rati
on, c
ontr
ols
odor
and
gas
em
issi
ons,
pro
vide
sa
stab
le s
urfa
ce o
ver
was
tes,
and
lim
its
dire
ct c
onta
ct.
Con
tain
men
t gen
eral
ly is
am
men
able
tom
ost t
ypes
of
cont
amin
ants
, tho
ugh
it is
not a
s ef
fect
ive
at s
ites
wit
h a
high
grou
nd-w
ater
tabl
e or
sit
es lo
cate
d on
afl
oodp
lain
.
Con
tain
men
t doe
s no
t inv
olve
trea
tmen
t,re
duce
toxi
city
or
was
te v
olum
e, a
nd w
ill
gene
rally
res
tric
t fut
ure
uses
of
a si
te.
EH
-413
June
, 200
0
P
age
5-11
Exh
ibit
5-4
: E
x-Si
tu T
reat
men
t T
echn
olog
ies
for
Haz
ardo
us C
onta
min
ated
Soi
l
Tre
atm
ent
Tec
hnol
ogy
Bri
ef T
echn
olog
y D
escr
ipti
onA
pplic
able
Con
tam
inan
ts
Res
idua
l Was
te G
ener
ated
BIO
LO
GIC
AL
TR
EA
TM
EN
T
Bio
pile
sE
xcav
ated
soi
ls a
re m
ixed
wit
h so
il a
men
dmen
ts a
ndpl
aced
in a
bove
gro
und
encl
osur
es. P
roce
sses
incl
ude
prep
ared
trea
tmen
t bed
s, b
iotr
eatm
ent c
ells
, soi
l pil
es,
and
com
post
ing.
Bio
pile
trea
tmen
t is
succ
essf
ul tr
eati
ngno
nhal
ogen
ated
VO
Cs
and
fuel
hydr
ocar
bons
.
Hal
ogen
ated
VO
Cs,
SV
OC
s, a
ndpe
stic
ides
can
als
o be
trea
ted,
but
the
proc
ess
effe
ctiv
enes
s w
ill v
ary
and
may
be a
ppli
cabl
e on
ly to
som
e co
mpo
unds
wit
hin
thes
e co
ntam
inan
t gro
ups.
In
orga
nic
cont
amin
ants
can
not b
e tr
eate
dus
ing
this
tech
nolo
gy.
Com
post
ing
Con
tam
inat
ed s
oils
are
exc
avat
ed a
nd m
ixed
wit
hbu
lkin
g ag
ents
and
org
anic
am
endm
ents
suc
h as
woo
dch
ips,
ani
mal
and
veg
etat
ive
was
tes,
whi
ch a
re a
dded
to e
nhan
ce th
e po
rosi
ty a
nd o
rgan
ic c
onte
nt o
f th
em
ixtu
re to
be
deco
mpo
sed.
The
com
post
ing
proc
ess
may
be
appl
ied
to s
oils
con
tam
inat
ed w
ith
biod
egra
dabl
eor
gani
c co
mpo
unds
.
Alt
houg
h le
vels
of
met
als
may
be
redu
ced
via
dilu
tion
, hea
vy m
etal
s ar
eno
t tre
ated
by
this
met
hod.
Ino
rgan
icco
ntam
inan
ts c
anno
t be
trea
ted
usin
g th
ism
etho
d. I
n ad
diti
on, e
xcav
atio
n of
cont
amin
ated
soi
ls m
ay c
ause
the
unco
ntro
lled
rel
ease
of
VO
Cs.
Fun
gal B
iode
grad
atio
nF
unga
l bio
degr
adat
ion
refe
rs to
the
biod
egra
dati
on o
f a
wid
e va
riet
y of
org
anop
ollu
tant
s by
usi
ng th
eir
lign
in-
degr
adin
g or
woo
d ro
ttin
g en
zym
e sy
stem
.
Thi
s te
chno
logy
has
the
abil
ity
tode
grad
e an
d m
iner
aliz
e a
num
ber
ofor
gano
poll
utan
ts a
nd th
e po
tent
ial t
ode
grad
e an
d m
iner
aliz
e ot
her
reca
lcit
rant
mat
eria
ls, s
uch
as D
DT
, PA
H, a
nd P
CB
.
Thi
s te
chno
logy
gen
eral
ly d
oes
not
degr
ade
cont
amin
ants
to le
vels
suf
fici
ent
to m
eet c
lean
up s
tand
ards
. In
add
itio
n,in
orga
nic
cont
amin
ants
can
not b
e tr
eate
dby
this
tech
nolo
gy.
Lan
dfar
min
gC
onta
min
ated
soi
ls a
re a
ppli
ed o
nto
the
soil
sur
face
and
peri
odic
ally
turn
ed o
ver
or ti
lled
into
the
soil
toae
rate
the
was
te.
Lan
dfar
min
g ha
s be
en p
rove
n su
cces
sful
in tr
eati
ng p
etro
leum
hyd
roca
rbon
s an
dot
her
less
vol
atil
e, b
iode
grad
able
cont
amin
ants
.
Whi
le la
ndfa
rmin
g ca
nnot
deg
rade
inor
gani
c co
ntam
inan
ts, i
t may
sta
bili
zeor
rem
ove
inor
gani
cs b
y ad
sorp
tion
,up
take
, acc
umul
atio
n, a
nd c
once
ntra
tion
in m
icro
and
mac
roor
gani
sms.
The
mor
ech
lori
nate
d or
nit
rate
d th
e co
mpo
und,
the
mor
e di
ffic
ult i
t is
to d
egra
de.
Soi
lE
nviro
nmen
tal R
esto
ratio
n W
aste
Gui
de
Tre
atm
ent
Tec
hnol
ogy
Bri
ef T
echn
olog
y D
escr
ipti
onA
pplic
able
Con
tam
inan
ts
Res
idua
l Was
te G
ener
ated
P
age
5-12
Slu
rry
Pha
se B
iolo
gica
lT
reat
men
tA
n aq
ueou
s sl
urry
is c
reat
ed b
y co
mbi
ning
soi
l or
slud
ge w
ith
wat
er a
nd o
ther
add
itiv
es. T
he s
lurr
y is
mix
ed to
kee
p so
lids
sus
pend
ed a
nd m
icro
orga
nism
s in
cont
act w
ith
the
soil
con
tam
inan
ts. U
pon
com
plet
ion
of th
e pr
oces
s, th
e sl
urry
is d
ewat
ered
and
the
trea
ted
soil
is d
ispo
sed
of.
Slu
rry
phas
e bi
olog
ical
trea
tmen
t has
been
use
d to
suc
cess
full
y re
med
iate
soi
lsco
ntam
inat
ed b
y P
CB
s, p
etro
leum
hydr
ocar
bons
, pet
roch
emic
als,
sol
vent
s,pe
stic
ides
, woo
d pr
eser
vati
ves,
and
oth
eror
gani
c ch
emic
als.
Soi
ls c
onta
inin
g in
orga
nic
cont
amin
ants
wil
l not
be
rem
edia
ted
usin
g sl
urry
pha
sebi
olog
ical
trea
tmen
t tec
hniq
ues.
PH
YSI
CA
L/C
HE
MIC
AL
TR
EA
TM
EN
T
Che
mic
al E
xtra
ctio
nW
aste
con
tam
inat
ed s
oil a
nd e
xtra
ctan
t are
mix
ed in
an
extr
acto
r, d
isso
lvin
g th
e co
ntam
inan
ts. T
he e
xtra
cted
solu
tion
is th
en p
lace
d in
a s
epar
ator
, whe
re th
eco
ntam
inan
ts a
nd e
xtra
ctan
t are
sep
arat
ed f
or tr
eatm
ent
and
furt
her
use.
Che
mic
al e
xtra
ctio
n te
chno
logi
es h
ave
been
eff
ecti
ve in
trea
ting
soi
ls c
onta
inin
gpr
imar
ily
orga
nic
cont
amin
ants
, suc
h as
PC
Bs,
VO
Cs,
hal
ogen
ated
sol
vent
s, a
ndpe
trol
eum
was
te, a
s w
ell a
s he
avy
met
als.
Inor
gani
cs c
an b
e tr
eate
d us
ing
chem
ical
extr
acti
on te
chno
logi
es, b
ut le
vels
are
com
mon
ly n
ot r
educ
ed b
elow
reg
ulat
ory
clea
nup
leve
ls.
In a
ddit
ion,
trac
es o
fso
lven
ts m
ay r
emai
n in
the
trea
ted
soil
afte
r ch
emic
al e
xtra
ctio
n.
Che
mic
alR
educ
tion
/Oxi
dati
onR
educ
tion
/oxi
dati
on c
hem
ical
ly c
onve
rts
haza
rdou
sco
ntam
inan
ts to
non
-haz
ardo
us o
r le
ss to
xic
com
poun
ds th
at a
re m
ore
stab
le, l
ess
mob
ile,
and
/or
iner
t. T
he o
xidi
zing
age
nts
mos
t com
mon
ly u
sed
are
ozon
e, h
ydro
gen
pero
xide
, hyp
ochl
orit
es, c
hlor
ine,
and
chlo
rine
dio
xide
.
The
targ
et c
onta
min
ant g
roup
for
chem
ical
oxi
dati
on/r
educ
tion
isin
orga
nics
. T
his
tech
nolo
gy c
an b
e us
ed,
but m
ay b
e le
ss e
ffec
tive
, aga
inst
no
nhal
ogen
ated
VO
Cs
and
SV
OC
s, f
uel
hydr
ocar
bons
, and
pes
tici
des.
Inco
mpl
ete
oxid
atio
n or
for
mat
ion
ofin
term
edia
te c
onta
min
ants
may
occ
urde
pend
ing
upon
the
cont
amin
ants
and
oxid
izin
g ag
ents
use
d.
Deh
alog
enat
ion
Rea
gent
s ar
e ad
ded
to s
oils
con
tam
inat
ed w
ith
halo
gena
ted
orga
nics
. The
deh
alog
enat
ion
proc
ess
isac
hiev
ed b
y ei
ther
the
repl
acem
ent o
f th
e ha
loge
nm
olec
ules
or
the
deco
mpo
siti
on a
nd p
arti
alvo
lati
liza
tion
of
the
cont
amin
ants
.
Hal
ogen
ated
VO
Cs
and
SV
OC
s, P
CB
s,an
d pe
stic
ides
are
the
targ
et c
onta
min
ant
grou
ps f
or d
ehal
ogen
atio
n tr
eatm
ent.
Inor
gani
cs, h
alog
enat
ed V
OC
s an
dS
VO
Cs,
and
fue
ls c
anno
t be
trea
ted
usin
g de
halo
gena
tion
tech
nolo
gies
.
EH
-413
June
, 200
0
Tre
atm
ent
Tec
hnol
ogy
Bri
ef T
echn
olog
y D
escr
ipti
onA
pplic
able
Con
tam
inan
ts
Res
idua
l Was
te G
ener
ated
P
age
5-13
Rec
over
y/R
ecla
mat
ion
Rec
lam
atio
n/re
cove
ry is
a p
erm
anen
t tre
atm
ent t
hat
sepa
rate
s m
etal
con
tam
inan
ts f
rom
soi
l in
the
form
of
met
al, m
etal
oxi
de, c
eram
ic p
rodu
ct, o
r ot
her
usef
ulpr
oduc
ts th
at h
ave
pote
ntia
l mar
ket v
alue
. R
ecla
mat
ion/
reco
very
may
be
the
prim
ary
trea
tmen
tan
d m
ay in
clud
e hy
drom
etal
lurg
ical
or
leac
hing
proc
esse
s. C
ompo
unds
in w
aste
can
als
o be
con
vert
edto
met
al o
r m
atte
by
tran
sfer
ring
und
esir
able
com
pone
nts
to a
sep
arat
e sl
ag p
hase
.
Rec
lam
atio
n/re
cove
ry o
ften
is a
men
able
to s
itua
tion
s w
ith
high
con
cent
rati
ons
ofva
luab
le o
r ea
sily
vol
atiz
ed m
ater
ials
. F
or z
inc,
lead
, cad
miu
m, n
icke
l, an
dch
rom
ium
it m
ay b
e ec
onom
ical
ly v
iabl
eto
rec
over
met
als
from
larg
e vo
lum
es o
fw
aste
wit
h hi
gh c
once
ntra
tion
s at
5-2
0%.
Add
itio
nall
y, p
rove
n te
chno
logy
exi
sts
for
reco
veri
ng m
ater
ial c
onta
inin
ggr
eate
r th
an 4
0% le
ad.
Sub
sequ
ent t
reat
men
t can
be
perf
orm
edto
upg
rade
the
met
al o
r m
atte
. Fur
ther
man
agem
ent o
f m
ater
ials
left
ove
r m
aybe
req
uire
d to
pro
tect
hum
an h
ealt
h an
dth
e en
viro
nmen
t onc
e m
etal
s ar
ere
cove
red.
Sep
arat
ion
Sep
arat
ion
tech
niqu
es c
once
ntra
te c
onta
min
ated
sol
ids
thro
ugh
phys
ical
and
che
mic
al m
eans
. The
se p
roce
sses
seek
to d
etac
h co
ntam
inan
ts f
rom
thei
r m
ediu
m (
i.e.,
the
soil
, san
d, a
nd/o
r bi
ndin
g m
ater
ial t
hat c
onta
ins
them
).
The
targ
et c
onta
min
ant g
roup
s fo
r ex
-sit
use
para
tion
pro
cess
es a
re o
rgan
ics
and
inor
gani
cs, i
nclu
ding
rad
ionu
clid
es.
The
se te
chno
logi
es c
an b
e us
ed o
nse
lect
ed V
OC
s an
d pe
stic
ides
.
Mos
t org
anic
con
tam
inan
ts, s
uch
as
SV
OC
s, f
uels
, and
VO
Cs,
can
not b
etr
eate
d us
ing
sepa
rati
on te
chni
ques
.
Soi
l Was
hing
Con
tam
inan
ts s
orbe
d on
to f
ine
soil
par
ticl
es a
rese
para
ted
from
bul
k so
il in
an
aque
ous-
base
d sy
stem
on th
e ba
sis
of p
arti
cle
size
. The
was
h w
ater
may
be
augm
ente
d w
ith
a ba
sic
leac
hing
age
nt, s
urfa
ctan
t, pH
adju
stm
ent,
or c
hela
ting
age
nt to
hel
p re
mov
e or
gani
csan
d he
avy
met
als.
Hea
vy m
etal
s, f
uels
, and
SV
OC
s ar
e th
eta
rget
con
tam
inan
t gro
ups
for
soil
was
hing
. T
he te
chno
logy
can
als
o be
used
on
sele
cted
VO
Cs
and
pest
icid
es.
Man
y or
gani
cs w
ill b
e di
ffic
ult t
ore
mov
e us
ing
soil
was
hing
tech
nolo
gies
. In
add
itio
n, th
e co
ntam
inat
ed w
ater
fro
mso
il w
ashi
ng w
ill n
eed
to b
e tr
eate
d w
ith
the
tech
nolo
gy(s
) su
itab
le f
or th
eco
ntam
inan
ts.
Soi
l Vap
or E
xtra
ctio
nA
vac
uum
is a
ppli
ed to
a n
etw
ork
of a
bove
gro
und
pipi
ng to
enc
oura
ge v
olat
iliz
atio
n of
org
anic
s fr
om th
eex
cava
ted
med
ia. T
he p
roce
ss in
clud
es a
sys
tem
for
hand
ling
off
-gas
es.
The
targ
et c
onta
min
ant g
roup
s fo
r ex
-sit
uso
il v
apor
ext
ract
ion
are
VO
Cs,
SV
OC
s,an
d fu
els.
Ex-
situ
SV
E c
anno
t be
used
to tr
eat
inor
gani
c co
ntam
inan
ts.
In a
ddit
ion,
air
emis
sion
s, r
esid
ual l
iqui
d, a
nd s
pent
acti
vate
d ca
rbon
wil
l req
uire
trea
tmen
t.
Sol
ar D
etox
ific
atio
n S
olar
det
oxif
icat
ion
is a
pro
cess
that
des
troy
sco
ntam
inan
ts b
y us
ing
the
ultr
avio
let e
nerg
y in
sunl
ight
.
Dye
s, s
olve
nts,
pes
tici
des,
VO
Cs,
and
SV
OC
s ha
ve a
ll b
een
succ
essf
ully
trea
ted
usin
g so
lar
deto
xifi
cati
onte
chno
logi
es.
Inor
gani
cs c
anno
t be
trea
ted
usin
g so
lar
deto
xifi
cati
on te
chno
logi
es.
Sol
idif
icat
ion/
Sta
bili
zati
onC
onta
min
ants
are
phy
sica
lly
boun
d or
enc
lose
d w
ithi
na
stab
iliz
ed m
ass
(sol
idif
icat
ion)
, or
chem
ical
rea
ctio
nsar
e in
duce
d be
twee
n th
e st
abil
izin
g ag
ent a
ndco
ntam
inan
ts to
red
uce
thei
r m
obil
ity
(sta
bili
zati
on).
The
targ
et c
onta
min
ant g
roup
for
ex-
situ
soli
difi
cati
on/s
tabi
liza
tion
is in
orga
nics
,in
clud
ing
radi
onuc
lide
s.
Mos
t sol
idif
icat
ion/
stab
iliz
atio
nte
chno
logi
es h
ave
lim
ited
eff
ecti
vene
ssag
ains
t org
anic
s an
d pe
stic
ides
.
Soi
lE
nviro
nmen
tal R
esto
ratio
n W
aste
Gui
de
Tre
atm
ent
Tec
hnol
ogy
Bri
ef T
echn
olog
y D
escr
ipti
onA
pplic
able
Con
tam
inan
ts
Res
idua
l Was
te G
ener
ated
P
age
5-14
TH
ER
MA
L T
RE
AT
ME
NT
Inci
nera
tion
Hig
h te
mpe
ratu
res,
871
-1,2
04 °
C (
1,60
0- 2
,200
°F
),ar
e us
ed to
com
bust
(in
the
pres
ence
of
oxyg
en)
orga
nic
cons
titue
nts
in h
azar
dous
was
tes.
Inci
nera
tion
is u
sed
to r
emed
iate
soi
lsco
ntam
inat
ed w
ith
haza
rdou
s w
aste
,pa
rtic
ular
ly c
hlor
inat
ed h
ydro
carb
ons,
PC
Bs,
and
dio
xins
.
Met
als
may
pro
duce
bot
tom
ash
that
requ
ires
sta
bili
zati
on, l
eave
the
com
bust
ion
unit
wit
h fl
ue g
ases
and
requ
ire
inst
alla
tion
of
a ga
s cl
eani
ngsy
stem
, or
reac
t wit
h ot
her
elem
ents
tofo
rm m
ore
vola
tile
and
toxi
c co
mpo
unds
than
the
orig
inal
spe
cies
. In
orga
nics
cann
ot b
e tr
eate
d us
ing
inci
nera
tion
tech
niqu
es.
Pyr
olys
isC
hem
ical
dec
ompo
siti
on is
indu
ced
in o
rgan
icm
ater
ials
by
heat
in th
e ab
senc
e of
oxy
gen.
Org
anic
mat
eria
ls a
re tr
ansf
orm
ed in
to g
aseo
us c
ompo
nent
san
d a
soli
d re
sidu
e (c
oke)
con
tain
ing
fixe
d ca
rbon
and
ash.
The
targ
et c
onta
min
ant g
roup
s fo
rpy
roly
sis
are
SV
OC
s an
d pe
stic
ides
.P
yrol
ysis
is n
ot e
ffec
tive
in e
ithe
rde
stro
ying
or
phys
ical
ly s
epar
atin
gin
orga
nics
fro
m c
onta
min
ated
med
ia.
Vol
atil
e m
etal
s m
ay b
e re
mov
ed a
s a
resu
lt o
f th
e hi
gher
tem
pera
ture
sas
soci
ated
wit
h th
e pr
oces
s bu
t are
sim
ilar
ly n
ot d
estr
oyed
.
The
rmal
Des
orpt
ion
Was
tes
are
heat
ed to
vol
atil
ize
wat
er a
nd o
rgan
icco
ntam
inan
ts. A
car
rier
gas
or
vacu
um s
yste
mtr
ansp
orts
vol
atil
ized
wat
er a
nd o
rgan
ics
to th
e ga
str
eatm
ent s
yste
m.
The
rmal
des
orpt
ion
syst
ems
have
var
ying
degr
ees
of e
ffec
tive
ness
aga
inst
the
full
spec
trum
of
orga
nic
cont
amin
ants
.
Hea
vy m
etal
s in
the
feed
may
pro
duce
atr
eate
d so
lid
resi
due
that
req
uire
sst
abil
izat
ion.
EH
-413
June
, 200
0
P
age
5-15
Exh
ibit
5-5
: T
reat
men
t T
echn
olog
ies
for
Soil
Con
tam
inat
ed w
ith
Rad
ioac
tive
Was
te
Tre
atm
ent
Tec
hnol
ogy
Bri
ef T
echn
olog
y D
escr
ipti
onA
pplic
able
Con
tam
inan
tsR
esid
ual W
aste
Gen
erat
ed
I N-S
ITU
TR
EA
TM
EN
T T
EC
HN
OL
OG
IES
Nat
ural
Att
enua
tion
N
atur
al s
ubsu
rfac
e pr
oces
ses
- su
ch a
s di
luti
on,
vola
tili
zati
on, b
iode
grad
atio
n, a
dsor
ptio
n, a
ndch
emic
al r
eact
ions
wit
h su
bsur
face
mat
eria
ls -
are
allo
wed
to r
educ
e co
ntam
inan
t con
cent
rati
ons
orac
tivi
ty to
acc
epta
ble
leve
ls.
Tar
get c
onta
min
ants
for
nat
ural
atte
nuat
ion
are
VO
Cs,
SV
OC
s, a
ndpe
trol
eum
hyd
roca
rbon
s. P
esti
cide
s ca
nal
so b
e al
low
ed to
nat
ural
ly a
tten
uate
,bu
t the
pro
cess
may
be
less
eff
ecti
ve a
ndm
ay b
e ap
plic
able
to o
nly
som
eco
mpo
unds
wit
hin
the
grou
p.
Whi
le n
atur
al a
tten
uati
on c
anno
t deg
rade
inor
gani
c co
ntam
inan
ts, i
nclu
ding
radi
onuc
lide
s, it
may
sta
bili
ze o
r re
mov
ein
orga
nics
by
adso
rpti
on, u
ptak
e,ac
cum
ulat
ion,
and
con
cent
rati
on in
rece
ptor
s. T
his
allo
ws
radi
onuc
lide
s to
deca
y in
pla
ce, w
ith li
ttle
or n
om
igra
tion
.
Soi
l Flu
shin
gW
ater
, or
wat
er c
onta
inin
g an
add
itiv
e to
enh
ance
cont
amin
ant s
olub
ilit
y, is
app
lied
to th
e so
il o
r in
ject
edin
to th
e gr
ound
wat
er to
rai
se th
e w
ater
tabl
e in
to th
eco
ntam
inat
ed s
oil z
one.
Con
tam
inan
ts a
re le
ache
d in
toth
e gr
ound
wat
er, w
hich
is th
en e
xtra
cted
and
trea
ted.
The
targ
et c
onta
min
ant g
roup
for
soi
lfl
ushi
ng is
inor
gani
cs, i
nclu
ding
radi
oact
ive
cont
amin
ants
. T
his
tech
nolo
gy m
ay b
e us
ed to
trea
t VO
Cs,
SV
OC
s, f
uels
, and
pes
tici
des,
but
it m
aybe
less
cos
t-ef
fect
ive
than
alt
erna
tive
tech
nolo
gies
for
thes
e co
ntam
inan
ts.
The
add
itio
n of
env
iron
men
tall
yco
mpa
tibl
e su
rfac
tant
s m
ay b
e us
ed to
incr
ease
the
solu
bili
ty o
f so
me
orga
nic
com
poun
ds; h
owev
er, t
he f
lush
ing
solu
tion
may
alt
er th
e ph
ysic
al/c
hem
ical
prop
erti
es o
f th
e so
il.
Sol
idif
icat
ion/
Sta
bili
zati
onC
onta
min
ants
are
phy
sica
lly
boun
d or
enc
lose
d w
ithi
na
stab
iliz
ed m
ass
(sol
idif
icat
ion)
, or
chem
ical
rea
ctio
nsar
e in
duce
d be
twee
n th
e st
abil
izin
g ag
ent a
ndco
ntam
inan
ts to
red
uce
thei
r m
obil
ity
(sta
bili
zati
on).
The
targ
et c
onta
min
ant g
roup
for
in-s
itu
soli
difi
cati
on/s
tabi
liza
tion
is g
ener
ally
inor
gani
cs, i
nclu
ding
rad
ionu
clid
es.
The
tech
nolo
gy c
an d
estr
oy o
r re
mov
e so
me
orga
nics
and
imm
obil
ize
mos
t ino
rgan
ics
in c
onta
min
ated
soi
ls.
Sol
idif
icat
ion/
stab
iliz
atio
n ha
s ha
dli
mit
ed e
ffec
tive
ness
aga
inst
SV
OC
s, a
ndpe
stic
ides
and
no
effe
ctiv
enes
s ag
ains
tV
OC
s an
d m
ost f
uels
; how
ever
, sys
tem
sde
sign
ed to
be
mor
e ef
fect
ive
in tr
eati
ngor
gani
cs a
re c
urre
ntly
bei
ng d
evel
oped
and
test
ed.
Soi
lE
nviro
nmen
tal R
esto
ratio
n W
aste
Gui
de
Tre
atm
ent
Tec
hnol
ogy
Bri
ef T
echn
olog
y D
escr
ipti
onA
pplic
able
Con
tam
inan
tsR
esid
ual W
aste
Gen
erat
ed
P
age
5-16
EX
-SIT
U T
RE
AT
ME
NT
TE
CH
NO
LO
GIE
S
Sep
arat
ion
Sep
arat
ion
tech
niqu
es c
once
ntra
te c
onta
min
ated
sol
ids
thro
ugh
phys
ical
and
che
mic
al m
eans
. The
se p
roce
sses
seek
to d
etac
h co
ntam
inan
ts f
rom
thei
r m
ediu
m (
i.e.,
the
soil
, san
d, a
nd/o
r bi
ndin
g m
ater
ial t
hat c
onta
ins
them
).
The
targ
et c
onta
min
ant g
roup
for
ex-
situ
sepa
rati
on p
roce
sses
is in
orga
nics
,in
clud
ing
radi
onuc
lide
s. T
hese
tech
nolo
gies
can
be
used
on
sele
cted
VO
Cs
and
pest
icid
es.
Mos
t org
anic
con
tam
inan
ts, s
uch
as
SV
OC
s, f
uels
, and
VO
Cs,
can
not b
etr
eate
d us
ing
sepa
rati
on te
chni
ques
.
Soi
l Was
hing
Con
tam
inan
ts s
orbe
d on
to f
ine
soil
par
ticl
es a
rese
para
ted
from
bul
k so
il in
an
aque
ous-
base
d sy
stem
on th
e ba
sis
of p
arti
cle
size
. The
was
h w
ater
may
be
augm
ente
d w
ith
a ba
sic
leac
hing
age
nt, s
urfa
ctan
t, pH
adju
stm
ent,
or c
hela
ting
age
nt to
hel
p re
mov
e or
gani
csan
d he
avy
met
als.
Hea
vy m
etal
s, f
uels
, SV
OC
s, a
ndin
orga
nic
cont
amin
ants
, inc
ludi
ngra
dion
ucli
des,
are
the
targ
et c
onta
min
ant
grou
ps f
or s
oil w
ashi
ng.
The
tech
nolo
gyca
n al
so b
e us
ed o
n se
lect
ed V
OC
s an
dpe
stic
ides
.
Man
y or
gani
cs w
ill b
e di
ffic
ult t
ore
mov
e us
ing
soil
was
hing
tech
nolo
gies
. In
add
itio
n, th
e co
ntam
inat
ed w
ater
for
mso
il w
ashi
ng w
ill n
eed
to b
e tr
eate
d w
ith
the
tech
nolo
gy(s
) su
itab
le f
or th
eco
ntam
inan
ts.
Sol
idif
icat
ion/
Sta
bili
zati
onC
onta
min
ants
are
phy
sica
lly
boun
d or
enc
lose
d w
ithi
na
stab
iliz
ed m
ass
(sol
idif
icat
ion)
, or
chem
ical
rea
ctio
nsar
e in
duce
d be
twee
n th
e st
abil
izin
g ag
ent a
ndco
ntam
inan
ts to
red
uce
thei
r m
obil
ity
(sta
bili
zati
on).
The
targ
et c
onta
min
ant g
roup
for
ex-
situ
soli
difi
cati
on/s
tabi
liza
tion
is in
orga
nics
,in
clud
ing
radi
onuc
lide
s.
Mos
t sol
idif
icat
ion/
stab
iliz
atio
nte
chno
logi
es h
ave
lim
ited
eff
ecti
vene
ssag
ains
t org
anic
s an
d pe
stic
ides
.
EH-413 June, 2000
Page 5-17
Exhibit 5-6: Potentially Applicable RCRA StandardsFor In-Situ Response Actions
Standard Brief Description
Management of WasteResiduals
Waste residuals may be produced through such in-situremedies as soil vapor extraction and other technologiesthat separate contaminants from the soil media. In thesecases, the waste residuals may have to be evaluatedagainst the following types of requirements:
• Determination of waste status (e.g., RCRAwaste generator requirements in 40 CFR 262and characterization requirements, seeChapter 3);
• Handling requirements when generated beforefinal disposition (e.g., proper storage,packaging, and transportation in accordancewith 40 CFR 262 and 40 CFR 263); and
• Proper treatment and disposition (e.g., inaccordance with any LDR restrictions andallowable operating and permit conditions ofa receiving facility).
Groundwater Monitoring(40 Part 264, Subpart F)
Additional RCRA standards may be applicable tohazardous waste land disposal units at CERCLA sites. RCRA groundwater monitoring standards are applicablewhen a Superfund response involves the creation of anew land disposal unit or the remediation of an existingland disposal unit.
Closure and Post Closure(Part 264, Subpart G)
RCRA closure and post-closure requirements often areapplicable to hazardous waste management units thatare used for disposal at Superfund or RCRA correctiveaction sites. There are two types of potentiallyapplicable RCRA closure schemes: clean closure andlandfill closure. Clean closure involves removing ordecontaminating all waste residues, contaminatedequipment, and contaminated soils so that no additionalcare or monitoring is required. Landfill closureinvolves leaving hazardous waste and contaminatedwaste equipment in place and may trigger applicablerequirements such as the use of a final cap or cover forthe unit and continued groundwater monitoring in thepost-closure period.
Note: Similar standards under authorized State programs may apply in lieu of FederalRCRA requirements
5.4.2 Ex-Situ Management - Soils Managed as Hazardous Waste
Environmental restoration soil wastes that are managed ex-situ aresubject to a much more comprehensive set of requirements than thosemanaged through in-situ methods because they trigger regulations thatapply only when wastes are land disposed or placed following
Soil Environmental Restoration Waste Guide
Page 5-18
Wastes transported off-siteare subject to both RCRAand DOT regulations. Wastes transported on-siteare subject to restrictionsoutlined in the facility permit.
excavation (the only exception is if wastes remain within an area ofcontamination, in which case EPA determines that “placement” has notoccurred). This section describes the major requirements that applyduring the initial handling and staging of ex-situ managed wastes, aswell as those requirements that typically apply during any treatment andfinal disposal activities.
Requirements During Initial Handling of Soil Wastes
Excavated soil can be managed through a variety of differentmanagement approaches including 1) immediate packaging and shippingto a facility for subsequent management; 2) staging near the source ofexcavation until final management plans are implemented; 3) stagingelsewhere on a site until final management plans are implemented; or 4)treatment near the source of excavation and final disposition either in theoriginal location or in an on- or off-site disposal facility.
Environmental restoration management requirements vary substantiallydepending on the configuration of the management options selected, thepermitted status of the site, and any variances of alternate approachesthat will be used as part of this process (e.g., use of a corrective actionmanagement unit (CAMU)). This section describes the basicmanagement requirements in the areas of transport, complianceassurance, and permitting. Section 5.8 describes available complianceoptions that are available and may be incorporated as a part of a site’smanagement strategy.
Transport
When the waste is being transported to an off-site treatment facility thefield manager must comply with the manifest requirements of 40 CFR262 or an equivalent State program, which include:
& Identification of the hazardous waste (40 CFR 262.11);& Identifying the TSD facility, transportation mode, and company
handling the waste (40 CFR 262.12);& Properly packaging the waste (40 CFR 262.30);& Abiding by labeling, marking, and placarding requirements (40
CFR 262.30 -262.33); and& Completing and signing the manifest (40 CFR 262.20 -262.23).
The requirements for the transporter of the waste are identified in 40CFR 263. In developing these regulations, EPA adopted most of theDOT’s requirements for transporting hazardous waste (49 CFR 171 -179). A transporter should also refer to the DOT regulations to ensurethey are in compliance. For example, the Hazardous Materials Table in
EH-413 June, 2000
Page 5-19
Sites may also rely on a stagingpile, a new unit defined in therecent HWIR-Media rule, or atemporary unit, established in1993. See Section 5.8.2 and5.8.8 of this Guide for moreinformation.
In some cases, projectmanagers may determine therequirements of 40 CFR 265for interim status facilitiesare more appropriate to meetthan those for permittedfacilities.
Additional information oncontainer management maybe found in “Management ofHazardous Waste Containers& Container Storage Areasunder RCRA”, DOE/EH-0333, August 1993,[http://www.eh.doe.gov/oepa/under “Policy andGuidance”].
49 CFR 172.101 identifies wastes that are forbidden from transport aswell as wastes that are restricted to particular modes of transportation.
If soil contaminated with hazardous waste will only be transported to anon-site treatment facility (on non-public roads), the RCRA transporterrequirements are not triggered. On-site transport restrictions orprocedures, however, may be included in the RCRA permit orimplementation plan that require that RCRA and DOT requirements bemet.
Storage
Sites that are storing hazardous contaminated soil (e.g., during stagingactivities) have to meet the applicable or relevant and appropriate unit-specific requirements corresponding to the unit being used (e.g.,container, tank, waste pile). Requirements that typically apply to thesetypes of storage requirements are included in Exhibit 5-7.
Exhibit 5-7Waste Specific Design and Operating Requirements
Storage Unit Design and Operating Requirements
Containers - “any portable device inwhich material is stored, transported,treated, disposed of, or otherwisehandled.” (40 CFR 260.10)
The following general requirementsapply to containers:• Must be in good condition;• Wastes must be compatible;• Containers must be closed
during storage;• Container areas must have a
containment system; and• Special requirements must be
met for ignitable, reactive, andincompatible wastes
[See 40 CFR 264 Subpart I]
Soil Environmental Restoration Waste Guide
Storage Unit Design and Operating Requirements
Page 5-20
Waste accumulation andstorage requirements changeif the site uses a CAMU orTU. The applicability ofCAMUs and TUs inmanaging contaminated soilis discussed in Section 5.8.
For additional information ontank management see“Resource Conservation andRecovery Act HazardousWaste Tank Systems”,DOE/EH-413/9716,September 1997,[http://www.eh.doe.gov/oepa/ under “Policy andGuidance”].
Tanks - “a stationary device, designed tocontain an accumulation of hazardouswaste which is constructed primarily ofnon-earthen materials (e.g., wood,concrete, steel, plastic) which providestructural support.” (40 CFR 260.10)
The following general requirementsapply to tanks:• Must meet design and
operating requirementsspecified in 40 CFR 264.192;
• Must have containment andsystems to detect releases;
• Must comply with generaloperating requirements such asspill prevention;
• Must be inspected routinely;and
• Must meet specialrequirements for ignitable,reactive, or incompatiblewastes
[See 40 CFR 264 Subpart J]
Waste Piles - “any non-containerizedaccumulation of solid, nonflowinghazardous waste that is used fortreatment or storage and that is not acontainment building.” (40 CFR 260.10)
The following general requirementsapply to waste piles:• Must meet design and
operating requirements,including a liner designed toprevent migration of wastes,leachate collection andremoval system, and leakdetection system;
• Must be monitored andinspected; and
• Must meet specialrequirements for ignitable,reactive, and incompatiblewastes
Note: Similar standards under authorized State programs may apply in lieu of FederalRCRA requirements
Compliance Assurance and Record Keeping Requirements
Whenever hazardous wastes are generated or stored, they are subject toroutine inspection, record keeping, and reporting requirements. Theapplicable Federal regulations are outlined in 40 CFR 264.15 and in thespecific regulatory sections for each different type of unit.
Permit Considerations
The current RCRA permit status of a site and the unit where remediationwastes are managed may affect the subsequent need to obtain a permit ora permit modification for managing soil that is hazardous environmentalrestoration waste. Under RCRA corrective actions, a project manager
EH-413 June, 2000
Page 5-21
The exemption for 90-dayaccumulation is promulgated in 40 CFR 262.34 andassociated preamblediscussion is found at 51 FR10168, March 24, 1986.
If the contaminated soil willbe treated on site, the site willneed a RCRA TSDF permit.
See 63 FR 28605, May 26,1998, for the LDR treatmentstandards for contaminatedsoil.
can generate and store environmental restoration waste withoutobtaining a permit provided certain quantity limits and accumulationtime restrictions are met. To generate and store environmentalrestoration wastes without a permit, the site can not store the wastes formore than 90 days. Small quantity generators, those who generate 100 -1000 kg per month, may store wastes without a permit for up to 180 daysprovided the total quantity of waste onsite does not exceed 6,000 kg. EPA or the State may grant extensions to these accumulation restrictionson a case-by-case basis.
If the waste will be treated on site then the site will need to have aRCRA TSDF permit and comply with all the applicable requirements in40 CFR parts 264 and 265 for the specified treatment type.
Under EPA’s interpretation of CERCLA Section 121(e), projectmanagers must only meet the substantive requirements of other laws andregulations for on-site actions. This removes the need to require permitsas part of a response action. Substantive requirements such asinspections and use of proper containers still must be met.
Requirements During Treatment and Post-Treatment
The primary requirement associated with treatment of hazardousenvironmental restoration soil wastes are those of the RCRA LDRs. Until recently, project managers often relied on site-specific treatabilityvariances under 40 CFR 268.44 to comply with LDRs. Recently,however, EPA promulgated the final Phase IV LDR rule for hazardouscontaminated soil because it has long recognized that the LDR treatmentstandards for as-generated industrial hazardous waste were not always asappropriate for contaminated media. The Agency also recognized thatthe previous LDRs for such industrial hazardous wastes may beunachievable in hazardous contaminated soil or may be inappropriate forhazardous contaminated soil due to peculiarities associated with the soilmatrix and the remediation context under which most contaminated soilis managed. In this new rulemaking, therefore, EPA promulgatedspecific standards for hazardous contaminated soil.
Scope and Applicability
The contaminated soil LDR standards promulgated in the Phase IV ruleapply to hazardous contaminated soil when it is generated andsubsequently placed in a land disposal unit. The definition of soilincludes clay, silt, sand, or gravel size particles, or a mixture of suchmaterials with liquids, sludges, or solids which is inseparable by simplemechanical removal and is made up primarily of soil by volume. Smallvolumes of sludges and sediments may be treated to the new LDR
Soil Environmental Restoration Waste Guide
Page 5-22
LDRs also will not requiretreatment when the soil alreadymeets the LDR treatmentstandards or, as outlined inChapter 3, the soil does notcontain a listed hazardous wasteand is not hazardous due to acharacteristic.
The universal treatmentstandards are codified in 40 CFR268.48.
standards to the extent that they fit the definition of soil; in other words,they must be in a mixture that is predominately soil (based on fieldinspection), and must be unable to be separated by simple mechanicalremoval processes. EPA emphasized in the rulemaking that threeprinciples must be adhered to when LDRs apply to prohibited hazardouswastes, including contaminated soils.
Use of the new soil treatment standards will not be necessary at everySuperfund site. As was true prior to the Phase IV rule, hazardouscontaminated soil that is not excavated for subsequent management(i.e., not generated) is still not subject to LDRs. Also, consistent withcurrent policy, soil managed within an area of contamination, even if itis excavated and replaced on the land within such an area, is still notsubject to the LDRs.
Basis for New Soil Treatment Standards.
The Phase IV rule establishes a new LDR treatability group,contaminated soils, and new LDR treatment standards specific to thatgroup. Unlike LDR standards for industrial wastes, the new LDRtreatment standards for soil are not based on the performance of BestDemonstrated Available Technologies (BDAT). Rather, EPA setstandards that can be achieved using a variety of treatment technologiesthat achieve substantial reductions in concentration or mobility ofhazardous constituents and that are generally used to treat soils.
New Soil LDR Standard.
Project managers managing contaminated soil continue to have theoption of complying either with the existing treatment standards forindustrial hazardous waste or the newly established soil treatmentstandards. When using the new standards, the regulation requires thatconstituents in hazardous contaminated soils must be treated to reducethe concentration of hazardous constituents by 90 percent for any oneconstituent, capped at 10 times the universal treatment standard. Underthis standard, all hazardous contaminated soil, including soilcontaminated by listed hazardous waste must be treated for eachunderlying hazardous constituent reasonably expected to be presentwhen such constituents are initially found at concentrations greater than10 times the universal treatment standard. In addition to treatment of allunderlying hazardous constituents, soil exhibiting one or more of thecharacteristics for hazardous soil must also be treated to the point that itno longer exhibits the characteristic. In the case of soil that would behazardous under the toxicity characteristic (TC) test, this treatment mustbe for the TC constituent and, in the case of ignitable, corrosive, orreactive soil, for the appropriate characteristic property.
EH-413 June, 2000
Page 5-23
EPA’s minimum technologyrequirements for hazardous wastelandfills are codified in 40 CFR264.301.
EPA recently promulgated thepost-closure rulemaking (63 FR56710, October 22, 1998), whichincreases the flexibility of theauthorities under which unitclosure can occur. Theserequirements generally will notapply to remediation projects(because they address regulatedunits), but some of the aspects ofthe regulations may be relevantand appropriate. See “StandardsApplicable to Owners andOperators of Closed and ClosingHazardous Waste Facilities: Post-Closure Permit Requirement andClosure Process,”http://www.eh.doe.gov/oepaunder “Policy and Guidance.”
Sampling and Evaluation Requirements for Treatment Activities.
Compliance with the soil treatment standards will be measured andenforced using grab samples. Compliance with the 90 percent reductionstandard should generally be measured using total constituentconcentrations. For hazardous constituents which have a treatmentstandard measured based on concentrations in a TCLP extract,compliance should be measured in leachate using the toxicitycharacteristic leaching procedure (TCLP).
Soil contaminated with a newly identified waste covered under an LDRprohibition extension does not need to be managed as a hazardous wasteunder RCRA Subtitle C. Until these dates expire, soil contaminatedwith the affected wastes can be land disposed without treatment;however, the disposal unit must meet the minimum technologyrequirements for that unit.
Closure of Waste Management Units
The primary requirements that project managers must meet followingcompletion of treatment will be meeting the requirements associatedwith closing the unitss both that managed the waste during remediationand those that receive environmental restoration soils wastes for finaldisposal (in addition to any source areas where residual contaminationmay be left in place). Typically, the closure requirements of interest willbe those for units such as tanks, impoundments, and landfills, althoughother types may be triggered depending on the nature of remediationactivities.
Generally, there are closure requirements specified in regulation for eachtype of unit. For example, the closure requirements for landfills areoutlined in two sections of the regulations: 40 CFR Subpart G (generalclosure and post-closure requirements), and 40 CFR Subpart N (specificdesign and closure requirements for landfills). The regulations aretypically a combination of performance objectives (e.g., ensureprotection of human health through an effective monitoring program)and specific standards (e.g., composition and depth of final caps forland-based units).
In addition to the final disposition unit, project managers must ensurethat any staging or storage areas and any areas used for treatment areclosed in accordance with the applicable requirements. For example,temporary units and staging piles (two options for managing wastesduring remediation discussed later in this Chapter) each have their ownclosure requirements specified in regulations.
Soil Environmental Restoration Waste Guide
Page 5-24
DOE Order 5820.2A,Radioactive WasteManagement, has beenreplaced by DOE Order435.1. The new Order wasfinalized on July 9, 1999. Inaddition to the Order, DOEhas issued DOE M 435.1,which provides most of thetechnical requirements, andDOE G 435.1, which providesdetailed technical guidance. [http://www.explorer.doe.gov:1776/htmls/currentdir.html].
5.5 Basic Management Requirements During Pre-Treatment,Treatment, and Post-Treatment Phases for Radioactive SoilEnvironmental Restoration Wastes
This section outlines the requirements that are triggered when managingradioactive wastes that are generated as part of environmental restorationprojects.
A fundamental aspect of determining what management requirementsare triggered is whether radioactive waste will be stored in existingfacilities, or whether new facilities will be constructed and operated aspart of an environmental restoration project. If existing facilities will berelied on, project managers can generally review the waste acceptancecriteria for the facility to determine many of the specific requirementsthat will have to be met. If a new facility will be constructed, projectmanagers will have to comply with the facility design and operatingrequirements established in DOE Order and Manual 435.1 (e.g.,performance assessments, disposal authorization statements, compositeanalyses).
This section highlights the major requirements for storage, wasteacceptance criteria, waste certification, treatment, packaging, anddisposal of radioactive wastes in both scenarios. Project managersplanning on constructing new facilities, however, should conduct a muchmore in-depth review of the DOE Manual 435.1 and its accompanyingDOE G435.1, which provides nearly 1,000 pages of technical assistance.
Central to compliance with DOE O 435.1 and its accompanying Manualis ensuring that all facilities (and, therefore, generators of radioactivewastes) operate in compliance with a radioactive waste managementbasis. This basis is comprised of the following elements:
For waste generators (e.g., project managers shipping waste to aradioactive waste management facility), the waste certification program;
For waste treatment facilities, the waste acceptance criteria and wastecertification program;
For waste storage facilities, the waste acceptance criteria and wastecertification program; and
for waste disposal facilities, the performance assessment, compositeanalysis, disposal authorization statement, closure plan, wasteacceptance criteria, and monitoring plan.
Each of these are described in more detail in the sections that follow.
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5.5.1 Storage Requirements
Storage requirements for TRU waste and LLW are outlined in theirrespective chapters of the DOE M 435.1. The minimum storagerequirements for LLW are:
• Wastes must be segregated based upon compatibility, safetycriteria, and hazards;
& Wastes must be stored in a manner that protects the integrity ofthe waste package for the expected time of storage;
& Wastes with an identified disposal path can not be stored longerthan a year prior to disposal, except for storage for decaypurposes;
� Wastes without an identified path shall be characterized toensure safe storage and to facilitate disposal;
� Characterization information shall be maintained;
� A process for low-level waste package inspection(s) andmaintenance shall be developed and implemented;
� Low-level waste storage shall be managed to identify andsegregate low-level waste from mixed low-level waste; and
� Staging of LLW for the purposes of accumulating appropriatequantities of waste material to facilitate transport, treatment anddisposal must not occur for a period longer than 90 days unlessall other requirements for LLW storage contained in SectionIV(N) and I (13) of DOE M 435.1-1 are met.
If soil contaminated with transuranic (TRU) waste is generated duringrestoration activities, it must be segregated to avoid co-mingling of non-compatible waste streams and must be monitored as prescribed by thefacility safety analysis to ensure that the wastes are maintained in a safecondition.
‘In addition, DOE M 435.1 III(H)(2) establishes that “TRU wastestreams with no identified path to disposal shall be generated only inaccordance with approved conditions which, at a minimum, shalladdress:
� Programmatic needs to generate the waste;
More information on TRUstorage requirements iscontained in Section III (N)of DOE Order M 435.1-1.
Storage requirements forTRU and LLW are containedin Sections III and IV N ofDOE M 435.1-1.[http://www.explorer.doe.gov:1776/htmls/currentdir.html].
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� Characteristics and issues preventing the disposal of the waste;� Safe storage of the waste until disposal can be achieved; and� Activities and plans for achieving final disposal of the waste.”
For project managers, this requirement may require consultation withmanagers of existing facilities to ensure that any TRU waste generatedcan be stored safely until final disposal options are available.
5.5.2 Waste Acceptance Criteria
Under DOE requirements, each treatment, storage, or disposal facilityreceiving waste is required to develop, maintain, and document WACthat will be used to evaluate waste received at its facility. Wasteacceptance criteria are fundamental elements of the radioactive wastemanagement basis established for all TRU and LLW managementfacilities and provide the physical, administrative and institutionalcontrols needed to protect workers, members of the public and theenvironment from radioactive releases from such facilities. The WACare established based on several facility-specific aspects: the facilitydesign, facility safety analysis, facility authorization basis, governingregulations, and other pertinent information. For waste TRU facilities, waste acceptance criteria includes the need toidentify waste as defense or non-defense in origin to prevent co-minglingof potentially non-compatible waste streams. For LLW facilities, wasteacceptance criteria address limits on the contact of waste material withwater, and prohibitions against excessive liquid content in wastematerial, restrictions on the generation of explosive, reactive, orflammable gases and toxic vapors from LLW material that may harmwaste handlers, members of the public or the environment and whichmay undermine the structural integrity of waste containers or thestructural integrity of waste management facilities.
The WAC are used by the receiving facility to evaluate waste received atits facility and should be used by the waste generating organization toprepare waste for shipment to the receiving facility.
Minimum waste acceptance criteria that facilities must incorporate toensure the health and safety of personnel include:
& Waste must not be packaged in cardboard or fiberboard boxes,unless such boxes meet DOT requirements and containstabilized waste with a minimum of void space;
& Wastes containing free liquid must be converted into a form thatcontains as little freestanding liquid as is reasonably achievable,but in no case shall the liquid exceed 1 percent of the waste
Additional waste acceptancecriteria governing LLW arementioned in SectionIV(G)(1)(d)(1-5) of DOE OrderM 435.1-1.
Waste acceptance criteria forTRU and LLW managementfacilities are discussed inSections III and IV G of DOEOrder M 435.1-1.[http://www.explorer.doe.gov:1776/htmls/currentdir.html]
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volume when the waste is in a disposal container, or 0.5 percentof the waste volume processed to a stable form;
& Waste must not be readily capable of detonation or of explosivedecomposition or reaction at normal pressures and temperatures,or of explosive reaction with water;
& Waste must not contain, or be capable of generating byradiolysis or biodegradation, quantities of toxic gases, vapors, orfumes harmful to the public or disposal facility personnel, orharmful to the long-term structural stability of the disposal site;
& Waste must not be pyrophoric; waste containing pyrophoricmaterials must be treated, prepared, and packaged to be non-flammable; and
� Low-level waste in gaseous form must be packaged such that thepressure does not exceed 1.5 atmospheres absolute at 20 degreesCelsius.
5.5.3 Waste Certification
Waste certification procedures for TRU waste and LLW provideappropriate assurance that authorized waste management officials havereviewed the characterization data for waste streams awaiting shipmentand have determined that a receiving facility’s acceptance criteria arebeing followed. As part of waste certification, calculations must bemade to ensure that waste streams will be handled in such a way thatpackaged material will maintain its certification for further managementafter it has left the original shipment location.
Waste certification is the responsibility of the generator or projectmanager of a environmental restoration project, in accordance with therequirements and procedures of the facility receiving the waste. Priorapproval of waste stream receipt by an authorized official at such areceiving facility is also required before waste shipping. Authorizedofficials at receiving facilities must be able to trace the waste streamback to its source of generation or shipment, and verify that allappropriate characterization and certification information is contained inthe documentation to accompany the waste shipment.
5.5.4 Treatment Requirements
The treatment requirements for soil contaminated with radionuclideswill primarily be driven by the waste acceptance criteria for the disposalfacility, as mandated by the radioactive waste management basis for
Waste certification requirementsfor TRU and LLW are discussedin Sections III and IV (I, J&K)of DOE M 435.1-1. [http://www.explorer.doe.gov:1776/htmls/currentdir.html]
Treatment requirements forTRU and LLW are discussed inSections III and IV (D)(2),(M)(2) and (O) of DOE OrderM 435.1-1.[http://www.explorer.doe.gov:1776/htmls/currentdir.html]
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TRU and LLW materials (discussed in Sections III and IV (D)(2) ofDOE Order M 435.1-1, and in 5.1 of Chapter 5 of this Guide). Technical requirements for facility design and the direct treatmentobjectives established for TRU waste and LLW, however, also have alarge impact on how environmental restoration wastes such as soils aretreated. Technical considerations for the treatment of radioactivelycontaminated soils (as part of other radioactive materials that aremanaged) are contained in the waste treatment facility designrequirements outlined in Sections III and IV (M)(2), that pertain toadequate waste confinement, ventilation of volatile gases and toxicvapors, decontamination capabilities for treatment facilities, andprovisions for leak detection, prevention, and monitoring mechanisms.
For TRU, waste material must be treated as necessary to meet the wasteacceptance criteria of the waste facility receiving the waste for storage ordisposal. For LLW, treatment may be required to provide a more stablewaste form and improve the disposal facilities’ long-term performancegoals.
5.5.5 Package and Transportation Requirements for RadioactiveWastes
Low-level waste (LLW) must be packaged in a manner that providescontainment for the duration of the anticipated storage period and untildisposal. When the LLW is packaged, the waste must be documented,marked, and labeled to identify the contents of the package and tofacilitate reporting on the waste manifest (DOE M 435.1-1). As part ofpackaging requirements for LLW, vents and other aeration measuresshould be provided if the potential exists for explosion, flammability, orpressure buildup within containers due to excessive gas concentration.
LLW must be transported to treatment, storage, or disposal facilities on aschedule coordinated in advance with the facility receiving the waste, aspart of waste transfer requirements contained in Section IV(K) of DOEOrder M435.1-1. Prior to waste transfer, characterization andcertification procedures must be undertaken to ensure that the wasteacceptance criteria of the receiving facility are met and that the wastepackage (and its contents) will maintain their certification status afterarrival. The subsequent number and volume of LLW shipments mustthen be minimized based on plans developed by the field as part of wastetransportation requirements.
Transuranic (TRU) waste must be shipped in compliance with site-specific requirements for on-site shipments and with Department ofTransportation (DOT) requirements for off-site shipments. Prior to anyshipments being released however, a waste transfer schedule must be
Waste packaging andtransportation requirements arefound in Section IV (L) of DOE435.1-1.[http://www.explorer.doe.gov:1776/htmls/currentdir.html]
Information on general wastecharacterization, certification andtransfer for TRU is contained inSection III (I, J, and K) of DOEOrder M 435.1-1. Packaging andtransport requirements arecontained under Section III (L).[http://www.explorer.doe.gov:1776/htmls/currentdir.html]
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The basic requirements for use ofthe TRUPACT-II for transuranicwaste are provided in the WIPPwaste acceptance criteriadocument, DOE/WIPP-069, Rev.5, 1996.
authorized in advance by officials at the receiving facility that is basedon waste characterization data, official certification and otherinformation that may be necessary to track a particular waste stream. Although off-site shipment of transuranic waste may be allowed in anyof several shipping packages approved by the Nuclear RegulatoryCommission and DOT, the only shipping container currently approvedfor shipment of transuranic waste to the Waste Isolation Pilot Project(WIPP) is the TRUPACT-II. The TRUPACT-II is only approved forcontact-handled transuranic waste. Remote-handled transuranic wastemust be shipped in an approved packaging system; the current plan forremote-handled transuranic waste shipment to WIPP is in the remote-handled-72B (RH-72B) cask/canister system. Other packaging systemsmay be approved, but the site will need to apply for package approvalthrough 10 CFR Part 71, Subpart D.
5.5.6 Disposal Requirements
The disposal requirements specified in DOE M 435.1 are designedprimarily for operators of these facilities and would apply as part ofenvironmental restoration waste management where a remediation-wastedisposal facility is built or operated. The DOE Manual specifiesminimum requirements for facility design and operation, performanceassessments, composite analyses, closure plan, and monitoring (inaddition to obtaining a disposal authorization statement).
To the degree that CERCLA actions have equivalent substantiverequirements, the requirements outlined in the DOE Order and Manualdo not have to be separately met and demonstrated. As outlined in DOEM 435.1, I (F)(5),
Environmental restoration activities using the CERCLA process(in accordance with Executive Order 12580) may demonstratecompliance with the substantive elements of DOE O 435.1,Radioactive Waste Management, and this Manual (including thePerformance Assessment and performance objectives, as well asthe Composite Analysis) through the CERCLA process. However, compliance with all substantive requirements of DOEO 435.1 not met through the CERCLA process must bedemonstrated. Environmental restoration activities which willresult in the off-site management and disposal of radioactivewaste must meet the applicable requirements of DOE O 435.1,Radioactive Waste Management, and this Manual for themanagement and disposal of those off-site wastes. Fieldelements performing environmental restoration activities
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involving development and management of radioactive wastedisposal facilities under the CERCLA process shall
(a) Submit certification to the Deputy Assistant Secretaryfor Environmental Restoration that compliance with thesubstantive requirements of DOE O 435.1 have beenmet through the application of the CERCLA process;and
(b) Submit the decision document, such as the Record ofDecision, or any other document that serves as theauthorization to dispose, to the Deputy AssistantSecretary for Environmental Restoration to approve.
It is important to note that activities taken under RCRA corrective actiondo not have the same equivalency clause as part of the DOE Order.
The remainder of this section describes the major elements associatedwith the design of a new disposal facility.
Site Evaluation and Facility Design Requirements
The provisions most relevant to the management and disposal ofradioactive soil wastes are contained in Sections IV (M)(1)(a)(2&3),which state that disposal facilities must not be located in flood plains,tectonically active areas, zones of water table changes, and in areaswhere contaminant migration pathways are unpredictable and erosionand surface runoff cannot be controlled.
Performance Assessments
Performance assessments serve to evaluate whether the radioactive doselimits for particular exposure pathways have been achieved and forsetting the point of compliance for the highest projected radioactivedoses surrounding disposed waste material. If LLW is disposed inburied units that are located near surface soils, the performanceassessment is a valuable instrument in determining whether near-surfacesoils have
become radioactively contaminated themselves, and if so, what levels ofradioactivity would be allowable so as to avoid any adverse impacts onwater sources, and what exposures potential human intruders wouldexperience if entering the disposal facility after closure. All suchcalculations of allowable radioactive releases from LLW disposal
Performance Assessments forLLW disposal facilities arediscussed in Section IV(P)(2&4)of DOE Order M 435.1-1.
Site Evaluation and FacilityDesign requirements for LLWfacilities are outlined in Section(M)(1) of DOE Order M 435.1-1.[http://www.explorer.doe.gov:1776/htmls/currentdir.html]
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facilities to the environment must demonstrate that any releases will beas low as reasonably achievable (ALARA).
Composite Analyses
LLW disposal facility performance assessments are complemented bycomposite analyses. Composite analyses achieve the following goalsrelative to waste disposal requirements: (1) They account for alladditional sources of radioactive material (including media such as soilsthat are surrounding closed disposal units) at DOE sites that may interactadversely with a closed disposal facility and further increase risks to thepublic and environment (2) The results of composite analyses must beused to reduce the likelihood that any further remediation will be neededat a site after closure. Both performance assessments and compositeanalyses undertaken for LLW disposal facilities must be updatedperiodically to address gaps in data, and to evaluate changes that couldaffect the performance or structural integrity of the disposal facility.
Closure Plan Requirements
LLW disposal facilities must develop closure plans. Preliminary closureplans are developed and submitted for review with disposal facilityperformance assessments and composite analyses, and must be updatedupon issuance of the disposal authorization statement, and during theoperational life of the facility. Such plans shall include the totalexpected inventory of wastes to be disposed at a facility over itsoperational life, and must have a description of the manner in which thefacility will be closed so as to achieve long-term stability and reduce theneed for active maintenance.
Final closure plans developed for LLW facilities shall include the finalinventory of waste in the disposal facility and designate institutionalcontrols and measures that will be integrated into land use andstewardship programs that will ensure the long-term stability of thedisposal facility following closure. The location and use of disposalfacilities must be filed with local authorities in charge of land use andzoning.
Monitoring requirements
Preliminary monitoring plans must be prepared simultaneously with theperformance assessment and composite analyses before the issuance ofthe disposal authorization statement and opening of the disposal facility. Updated monitoring plans are then issued one year after the approval andestablishment of the disposal authorization statement and must includetechnical designs for measuring and evaluating releases, migration of
Closure plan requirements forLLW disposal facilities arecontained in Section IV(Q) ofDOE Order M 435.1-1.
Monitoring plan requirementsfor LLW disposal facilities arediscussed in Section IV (R)(3) ofDOE Order M 435.1-1.[http://www.explorer.doe.gov:1776/htmls/currentdir.html]
For more information oncomposite analyses conductedfor LLW disposal facilities,refer to Section IV(P)(3) ofDOE Order 435.1-1.[http://www.explorer.doe.gov:1776/htmls/currentdir.html]
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The regulations for Federal PCBmanagement are promulgated in40 CFR Part 761, and specificrequirements for remediationwastes are found at 40 CFR761.61. Relevant guidance forPCB management includeDisposal Requirements for PCBWaste, EH-231-056/1294,December 1994, and a recentlypromulgated update to theregulations found at 63 FR 35383,June 29, 1998.
radionuclides, subsidence of the disposal facility and any changes thatmay affect the long-term performance of the disposal facility. Updatedmonitoring plans should be able to detect trends in facility performanceto allow application of any corrective action that may be necessary.
5.6 Basic Management Requirements During Pre-Treatment,Treatment, and Post-Treatment Phases for Mixed Waste
Environmental restoration soil wastes that are regulated as mixed wastesgenerally must meet the requirements of both the hazardous andradioactive waste requirements outlined in Sections 5.4 and 5.5. Mixedwastes must be managed in accordance with Sections III and IV (B)(1)of DOE Order M 435.1-1, and apply to TRU and LLW respectively.
Two areas in which unique considerations may be necessary for mixedwastes include testing and waste characterization requirements, andinspections. Waste characterization requirements are particularlyimportant to consider, since these standards serve as guides fordetermining whether a particular waste type is acceptable for release, isin a form stable enough to ensure safe handling and transport and istraceable to its source of generation. In addition, waste characterizationinformation is crucial for determining whether or not a potential receiving facility’s performance objectives can be met, based on thecharacteristics and compatibility of substances in the waste stream that isto be sent.
Mixed wastes may pose health and safety concerns that do not exist withhazardous wastes and require DOE managers to meet ALARA (as low asreasonably achievable) disposal facility performance assessmentrequirements in order to conduct the waste management activity. Formixed waste containing LLW material, ALARA principles would needto demonstrate that an LLW disposal facility handling mixed wastewould be capable of keeping releases of radionuclides within the wastematerial to the environment as low as reasonably achievable. To thisend, DOE has published a draft Technical Standard that is designed tohelp project managers evaluate ALARA considerations.
5.7 Managing PCB- and Asbestos-Containing Soil Wastes
In some cases, environmental restoration soil wastes are contaminated(or contain co-located materials) that are contaminated with PCBs orasbestos. As outlined in Chapter 3, these types of contaminants areregulated at the Federal level by the Toxic Substances and Control Act(although some States classify these materials as hazardous or othertypes of regulated wastes).
Waste characterizationrequirements for TRU and LLWare contained in Sections III andIV (I) of DOE Order M 435.1-1.
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See Regulatory RequirementsAffecting Disposal of Asbestos-Containing Material, EH-413-062/1195 (November, 1995) for moreinformation.[http://www.eh.doe.gov/oepa/ under “Policy and Guidance”].
5.7.1 Managing PCB-Contaminated Soils
PCB contaminated soils generated during environmental restorationactions are subject to the requirements of appropriate Federal or Stateregulations. In its 1998 regulation, EPA developed a self-implementingapproach to the remediation of PCB wastes, and allowed the RegionalAdministrator to tailor these requirements where practicable. The mainrequirements of these regulations are found in Exhibit 5-8.
5.7.2 Managing Asbestos-Contaminated Soils
Asbestos-containing materials must be disposed of in accordance withthe requirements in 40 CFR 61, Subpart M. Specific management anddisposal requirements include:
� Control of air emissions during operations that manageasbestos-containing materials and use of emissions controlsmeasures such as wetting asbestos-containing materials, turningfriable asbestos-containing materials into a non-friable form, orother methods for control approved by EPA;
� Disposal of materials as soon as possible in a facility inaccordance with the regulations;
� Maintaining records showing how materials were disposed; and
� Covering of the asbestos-containing materials during on-siteoperations at the end of each day.
Exhibit 5-8Summary of PCB Requirements for
PCB Remediation Waste
Category Requirements
Applicability. The requirements may not be used toclean up surface, ground waters, orsediments. The requirements also are notbinding on CERCLA and RCRAcorrective action cleanups.
Notification and certification 40 CFR 761.61(a)(3) specifiesrequirements and processes for notifyingand certifying cleanups under thissection.
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ARAR waivers are onlyappropriate for CERCLAresponse actions and may beapplicable for hazardous,radioactive, and mixed wastecontaminated soils.
Bulk PCB remediation waste Includes but not limited to non-liquidPCB remediation waste: soil, sediments,dredged materials, muds, sludges.
Bulk Remediation Waste: High occupancy areas
A cleanup level of 1 ppm is required. Where PCBs remain greater than 1 ppm,and less than 10 ppm, areas must becovered by a cap meeting therequirements of 40 CFR 761.61(a)(7)-(8).
Bulk Remediation Waste: Low occupancy areas
A cleanup level of 25 ppm is required. Where PCBs remain greater than 25 ppmand less than 50 ppm, the site must besecured by a fence and marked with asign.
Non-porous surfaces In high occupancy areas, surface cleanupstandard is less than 10 mg/100cm2 ofsurface area. In low occupancy areas, thestandard is less than 100 mg/100 cm2.
Porous surfaces Same standards apply for high and lowoccupancy areas as exist for bulkremediation waste.
Liquids Cleanup standards are set in 40 CFR761.79(b)(1).
5.8 Compliance Options for Managing Soil EnviromentalRestoration Wastes
Several compliance options exist that will drive the amount and type oftreatment. These options for hazardous contaminated soil include:
� ARAR Waivers;� Staging Piles;� RAPs;� Treatability Variances;� Site-Specific, Risk-Based LDR Treatment Variances;� Area of Contamination Policy;� Corrective Action Management Units; and� Temporary Units.
For radioactively contaminated soils, an option available is to determinethat the soil is no longer radioactive waste. This option is discussed inSection 8.9 of Chapter 5 of this Guide.
5.8.1 ARAR Waivers
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Staging piles were created as partof the HWIR-Media rulemaking,63 FR 65873, November 30, 1998.
RAPs were created as part of theHWIR-Media rulemaking, 63 FR65873, November 30, 1998.
Under CERCLA remedies, field managers can seek an exemption fromclean-up standards by invoking an ARAR waiver. The restrictions oninvoking waivers are codified in 40 CFR 300.430. ARAR waivers maybe granted for one of the following reasons:
& Compliance will create a greater risk to human health or theenvironment;
& Technical impracticability;& An alternative can result in an equivalent standard of
performance;& The state has inconsistently applied the requirement; or& The action is an interim action.
5.8.2 Staging Piles
Staging piles allow Remedial Project Managers (RPMs) to use short-term storage of hazardous wastes under circumstances that are protectiveof human health and the environment without the extensive set ofprescriptive standards that may be required for units in long-term use,such as liner requirements and meeting LDR treatment standards. Theregulation establishes that staging piles can accept all types of solid,non-flowing (non-liquid) remediation waste. Staging piles are alsoaddressed under Section IV (N)(7) of DOE Order M 435.1-1, as part ofrequirements governing interim storage of LLW. Under these standards,LLW such as radioactively contaminated soil may be staged for thepurposes of accumulating sufficient quantities of waste to allow foreasier transport, treatment or disposal. Any staging that occurs beyond90 days, if involving LLW or mixed waste containing LLW constituentsmust meet Section IV (N)(4) Waste Characterization for Storagerequirements.
5.8.3 Remedial Action Plans
Under the new HWIR-Media final rule, owner/operators can receive aRAP, rather than a traditional RCRA permit, for remediation wastemanagement activities that take place at the site. RAPs are limited toauthorizing the treatment, storage, or disposal of hazardous remediationwastes, and are generally limited to activities done in the area ofcontamination or areas in close proximity, unless managing theremediation waste off-site is more protective.
Because of the CERCLA 121(e) permit exemption, under which EPAhas concluded that the onsite portion of CERCLA cleanups do not needpermits or need to meet other administrative requirements, the RAP mayoffer only limited advantages for Superfund RPMs.
Staging requirements are discussedunder Section IV(N)(4) of DOEOrder M 435.1-1.
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See 40 CFR 268.44(h)(4),promulgated May 26, 1998 andassociated preamble at 63 FR28606-28608. Regulationsgoverning site-specific LDRtreatment variances are at 40CFR 268.44(h), August 17, 1988. Also refer to the memo, Use ofSite-Specific Land DisposalRestriction Treatability VariancesUnder 40 CFR 268.44(h) DuringCleanups.
See 55 FR 8758-8760, March 8,1990 and Use of the Area ofContamination Concept DuringRCRA Cleanups (EPA Memo,March 13, 1996).
See Corrective ActionManagement Units and TemporaryUnits, EH-2131-043/0394 (March1994),http://www.eh.doe.gov/oepaunder “Policy & Guidance.”
5.8.4 Treatability Variances
Generators whose wastes cannot be treated to the new treatmentstandards may still petition EPA for a treatability variance. For EPA togrant a treatability variance, the petitioner must successfully demonstratethat the waste differs significantly from the wastes evaluated by EPA indeveloping the treatment standards. The petitioner must alsodemonstrate that the waste cannot be treated to the level or by themethod specified as the treatment standard, or that the existing level ormethod is inappropriate for the waste. In granting a variance, EPA willestablish a new treatability group for that waste and set a new treatmentstandard.
5.8.5 Site-Specific, Risk-Based LDR Treatment Variance
Under 40 CFR 268.44(h)(3), variances from otherwise applicable LDRtreatment standards may be approved if it is determined that compliancewith the treatment standards would result in treatment beyond the pointat which short- and long-term threats to human health and theenvironment are minimized. This allows a site-specific, risk-baseddetermination to supersede the technology-based LDR treatmentstandards under certain circumstances. Alternative land disposalrestriction treatment standards established through site-specific, risk-based minimize threat variance should be within the range of values theEPA generally finds acceptable for risk-based cleanup levels.
5.8.6 Area of Contamination Policy
In what is typically referred to as the area of contamination (AOC)policy, EPA interprets RCRA to allow certain discrete areas of generallydispersed contamination to be considered RCRA units (usuallylandfills). Because an AOC is equated to a RCRA land-based unit,consolidation and in-situ treatment of hazardous waste within the AOCdo not create a new point of hazardous waste generation for the purposesof RCRA. This interpretation allows wastes to be consolidated ortreated in-situ within an AOC without triggering land disposalrestrictions or minimum technology requirements. The AOCinterpretation may be applied to any hazardous remediation waste(including non-media wastes) that is in or on the land. [Note that theAOC policy only covers consolidation and other in-situ wastemanagement techniques carried out within an AOC].
5.8.7 Corrective Action Management Units
The corrective action management unit rule, 58 FR 8658, February 16,1993, created a new type of RCRA unit–a Corrective Action
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See Corrective ActionManagement Units and TemporaryUnits, EH-2131-043/0394 (March1994) for more information.
Management Unit or CAMU–specifically intended for treatment,storage, and disposal of hazardous remediation waste. To obtain aCAMU, a project manager must demonstrate its advantages based onseven decision factors:
1. The designation will help implement a reliable, effective,protective, and cost-effective remedy;
2. Waste management activities associated with the CAMU willnot create unacceptable risks to humans or the environment;
3. In order to manage remediation wastes, the CAMU may includeuncontaminated facility areas only if doing so is more protectivethan managing such waste at contaminated facility areas;
4. Wastes remaining after CAMU closure will be managed orcontained to minimize future releases;
5. The designation will expedite the timing of remedial activityimplementation when appropriate and practicable;
6. The designation will allow the appropriate use of treatmenttechnologies to enhance remedial action by reducing thetoxicity, mobility, or volume of wastes that remain after CAMUclosure; and
7. The designation will minimize the facility’s land area uponwhich wastes will remain after CAMU closure.
Several DOE sites have used CAMUs effectively as part of remediationplans, including Sandia National Laboratory in Albuquerque and Fernaldin Ohio.
5.8.8 Temporary Units (TUs)
Temporary units, like corrective action management units, are RCRAunits established specifically for management of hazardous remediationwaste. The regulations for temporary units (TUs) were promulgated atthe same time as the regulations for corrective action management units. The TU regulations established non-land based units for treatment andstorage of hazardous remediation waste. Under the TU regulations, EPAand authorized states may modify existing Minimum TechnologyRequirements (MTR) design, operating and closure standards fortemporary tank and container units used to treat and store hazardousremediation waste. Temporary units may operate for one year, with anopportunity for a one year extension.
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Detailed guidance on releasingradioactive contaminated wastefrom management for itsradioactive content can be foundin Release of Hazardous WasteContaining Residual RadioactiveMaterial Implementation Guide,DOE G 435.1-2.
5.8.9 Determine Soil is No Longer Radioactive Waste
Soil that is contaminated with a small amount of radioactivity mayqualify to be managed as non-radioactive waste. To be managed as non-radioactive waste, the radioactivity level in the waste must be equivalentto background levels or be determined to be nondetectable using“reasonable methods.” The criteria for determining if a waste needs tobe managed as radioactive waste are:
& The waste must meet DOE Order 5400.5 requirements;
& Releases of the material must not cause a maximum individualdose in excess of one millirem per year or a collective dose ofmore than 10 person-rems per year;
& A procedure must exist to maintain records consistent with DOE5400.5 requirements; and
& ALARA process requirements must be achieved.
In addition, a soil that is contaminated with small amounts ofradioactivity may be managed as non-radioactive if it can also bedetermined that the contaminants will not be managed in a LLWmanagement facility, and are by-product or naturally occurringradioactive materials.
DOE Order O 435.1, Section 3(d)establishes exemptions for byproduct andnaturally occurring radioactive materialto be managed as “non-radioactive,”provided it is not managed in a LLWfacility.
Byproduct material is defined in DOE M435.1-1, Appendix 2 as: (1) anyradioactive material (except specialnuclear material) yielded in or otherwisemade radioactive by exposure to theradiation incident to the process ofproducing or utilizing special nuclearmaterial, and (2) The tailings or wastesproduced by the extraction orconcentration of uranium or thoriumfrom any ore processed primarily for itssource mineral content. [Source: AtomicEnergy Act of 1954, as amended, section11(e)].
EH-413 June, 2000
Page 4-3
Additional information onmanagement technologies isavailable from many EPA Guidesavailable through the TechnologyInnovation Office. Examplesinclude Technology ScreeningGuide For RadioactivelyContaminated Sites.
the environment is derived from the Atomic Energy Act asimplemented through DOE directives (e.g., DOE Order andManual 435.1-1, Radioactive Waste Management Manual, andDOE Order 5400.5, Radiation Protection of the Public and theEnvironment). DOE Order 435.1 and manual may be accessedat: http://www.explorer.doe.gov:1776/htmls/currentdir.html.
4.2 Summary of Ground Water Management Technologies
Exhibits 4-2 and 4-3 briefly describes some of the more commontreatment technologies for hazardous and radioactively contaminatedground water and any resulting waste residuals. The purpose of thetables is to identify the likely types of environmental restoration wastestreams that could require characterization and subsequent managementif the approach is selected (and not to evaluate the feasibility of anysingle technology option).
4.3 Basic Management Requirements During Pre-Treatment,Treatment, and Post Treatment Phases for HazardousWaste
The waste handling and storage requirements for ground water that ismanaged as hazardous waste differ significantly depending on theground water management approach selected. This section discusses therelevant planning considerations during initial waste handling activitiesas the ground water is generated, and requirements applicable during andafter treatment (including management of any residuals) for monitorednatural attenuation, active in situ, and ex-situ approaches.
Regardless of the management approach selected, contaminated groundwater will always require some degree of monitoring -- either to ensuretechnology performance or to determine if it meets other regulatoryrequirements. Ground-water monitoring requirements are specified inseveral Federal regulations and policies, and depend on the statute underwhich remediation is occurring, the site-specific conditions for whichmonitoring must occur, and the type of remedial action selected (and,therefore, the purposes of the monitoring). Exhibit 4-4, shown on page4-11 of this Guide, summarizes ground-water monitoring requirementsfor all management types and discusses when these requirementstypically apply.
EH
-413
June
, 200
0
Pag
e 4-
4
Exh
ibit
4-2
Typ
ical
Gro
und
Wat
er T
reat
men
ts f
or H
azar
dous
Was
tes
and
Res
ulti
ng R
esid
uals
Tre
atm
ent
Bri
ef T
echn
olog
y D
escr
ipti
onG
roun
d W
ater
Was
tes
Gen
erat
edR
esid
ual W
aste
s G
ener
ated
Fol
low
-On
Act
ivit
ies
I N-S
ITU
RE
ME
DIA
TIO
N O
PT
ION
S
Bio
rem
edia
tion
Sub
surf
ace
mic
roor
gani
sms
biod
egra
dehy
droc
arbo
ns b
y in
gest
ing
the
cont
amin
ants
and
conv
erti
ng th
em to
inno
cuou
s m
iner
al e
ndpr
oduc
ts.
Gro
und
wat
er is
not
extr
acte
d.R
esid
uals
gen
eral
ly d
o no
tre
quir
e fu
rthe
r tr
eatm
ent o
rm
anag
emen
t.
Gro
und-
wat
er c
ompl
ianc
em
onit
orin
g.
Soi
l Vap
or E
xtra
ctio
nA
ir is
use
d to
flu
sh o
ut v
olat
ile
orga
nic
cont
amin
ants
(in
clud
ing
non-
aque
ous
phas
eli
quid
s, N
AP
Ls)
fro
m g
roun
d w
ater
. The
cont
amin
ants
are
tran
sfer
red
to th
e ai
r an
dtr
ansp
orte
d to
the
surf
ace.
Gro
und
wat
er is
not
extr
acte
d.T
he a
ir d
isch
arge
may
req
uire
capt
ure
and
trea
tmen
t to
com
ply
wit
h ai
r em
issi
onre
quir
emen
ts (
40 C
FR
61
and
63)(
40 C
FR
264
and
265
).
Gro
und-
wat
er c
ompl
ianc
em
onit
orin
g.
Air
em
issi
on tr
eatm
ent.
Bio
vent
ing
Enh
ance
s ae
robi
c bi
odeg
rada
tion
of
petr
oleu
mhy
droc
arbo
ns a
nd c
hlor
inat
ed s
olve
nts
bysu
pply
ing
oxyg
en to
soi
l mic
robe
s. C
onta
min
ants
are
conv
erte
d to
inno
cuou
s pr
oduc
ts o
rtr
ansf
erre
d to
the
air.
Gro
und
wat
er is
not
extr
acte
d.C
aptu
re a
nd tr
eatm
ent o
fem
issi
ons
may
be
requ
ired
toco
mpl
y w
ith
air
stan
dard
s (4
0C
FR
61
and
63)(
40 C
FR
264
and
265)
.
Gro
und-
wat
er c
ompl
ianc
em
onit
orin
g.
Fil
ter
disp
osal
.
EX
-SIT
U R
EM
ED
IAT
ION
OP
TIO
NS
Air
Str
ippi
ngU
ses
vola
tili
zati
on to
tran
sfer
vol
atil
e or
gani
cco
ntam
inan
ts f
rom
the
grou
nd w
ater
to a
ir.
Tre
ated
gro
und
wat
er
is g
ener
ated
. V
olum
es m
ay b
esi
gnif
ican
t.
Air
str
eam
may
nee
d fi
ltra
tion
or tr
eatm
ent.
Pos
sibl
ese
cond
ary
trea
tmen
t of
effl
uent
req
uire
d.
Dis
posa
l of
wat
er.
Fil
ter
disp
osal
.G
roun
d-w
ater
com
plia
nce
mon
itor
ing.
Gro
und
Wat
erJu
ne, 2
000
Tre
atm
ent
Bri
ef T
echn
olog
y D
escr
ipti
onG
roun
d W
ater
Was
tes
Gen
erat
edR
esid
ual W
aste
s G
ener
ated
Fol
low
-On
Act
ivit
ies
Pag
e 4-
5
Gra
nula
r A
ctiv
ated
Car
bon
(GA
C)
Phy
sica
lly
sepa
rate
s co
ntam
inan
ts f
rom
gro
und
wat
er b
y ad
sorp
tion
ont
o ac
tiva
ted
carb
on.
App
lica
ble
to a
wid
e va
riet
y of
con
tam
inan
ts a
ndge
nera
lly
used
in c
onju
ncti
on w
ith
othe
rtr
eatm
ents
.
Ext
ract
ed g
roun
dw
ater
is
gene
rate
dan
d m
ust b
e m
anag
edin
acc
ord
wit
hre
quir
emen
ts tr
igge
red
by th
e se
lect
eddi
spos
al o
ptio
n
The
car
bon
filt
er c
an b
ere
acti
vate
d, r
egen
erat
ed, o
rdi
spos
ed.
If d
ispo
sed
the
carb
on m
ust b
e m
anag
ed a
s a
haza
rdou
s w
aste
if it
exh
ibit
sa
char
acte
rist
ic o
f or
“con
tain
s” a
haz
ardo
us w
aste
.
Dis
posa
l of
wat
er.
Fil
ter
disp
osal
.G
roun
d-w
ater
com
plia
nce
mon
itor
ing.
Che
mic
al O
xida
tion
Use
s ox
idiz
ing
proc
esse
s to
des
troy
or
rem
ove
cont
amin
ants
fro
m g
roun
d w
ater
.E
xtra
cted
gro
und
wat
er i
s ge
nera
ted
and
mus
t be
man
aged
in a
ccor
d w
ith
requ
irem
ents
trig
gere
dby
the
sele
cted
disp
osal
opt
ion.
Oxi
dati
on is
not
alw
ays
com
plet
e or
inte
rmed
iate
bypr
oduc
ts m
ay r
equi
rese
cond
ary
trea
tmen
t suc
h as
GA
C.
Dis
posa
l of
wat
er.
Gro
und-
wat
er c
ompl
ianc
em
onit
orin
g.
Aer
obic
Bio
logi
cal
Rea
ctor
sA
erob
ic b
iolo
gica
l rea
ctor
s us
e m
icro
orga
nism
sto
deg
rade
org
anic
con
tam
inan
tsE
xtra
cted
gro
und
wat
er i
s ge
nera
ted
and
mus
t be
man
aged
in a
ccor
d w
ith
requ
irem
ents
trig
gere
dby
the
sele
cted
disp
osal
opt
ion.
A s
ludg
e is
pro
duce
d th
atm
ay h
ave
conc
entr
ated
met
als
or r
ecal
citr
ant o
rgan
icco
mpo
unds
. T
he s
ludg
e m
ayne
ed to
be
man
aged
as
aha
zard
ous
was
te
Dis
posa
l of
wat
er.
Dis
posa
l of
slud
ge a
s a
haza
rdou
s w
aste
.G
roun
d-w
ater
com
plia
nce
mon
itor
ing.
Che
mic
al P
reci
pita
tion
Che
mic
ally
con
vert
s di
ssol
ved
met
al a
nd/o
r ot
her
inor
gani
c io
ns in
to a
n in
solu
ble
or le
ss s
olub
lepr
ecip
itat
e.
Ext
ract
ed g
roun
dw
ater
is
gene
rate
dan
d m
ust b
e m
anag
edin
acc
ord
wit
hre
quir
emen
ts tr
igge
red
by th
e se
lect
eddi
spos
al o
ptio
n.
The
con
tam
inan
ts a
rere
mov
ed b
y cl
arif
icat
ion
orfi
ltra
tion
and
the
resu
ltin
gre
sidu
e m
ay r
equi
re tr
eatm
ent
prio
r to
dis
posa
l.
Dis
posa
l of
wat
er.
Dis
posa
l of
resi
due.
Gro
und-
wat
er c
ompl
ianc
em
onit
orin
g.
EH
-413
June
, 200
0
Tre
atm
ent
Bri
ef T
echn
olog
y D
escr
ipti
onG
roun
d W
ater
Was
tes
Gen
erat
edR
esid
ual W
aste
s G
ener
ated
Fol
low
-On
Act
ivit
ies
Pag
e 4-
6
Ion
Exc
hang
e/A
dsor
ptio
nR
emov
es m
etal
s fr
om c
onta
min
ated
gro
und
wat
erth
roug
h a
gran
ular
sol
id th
at e
xcha
nges
sor
bed
ions
for
the
diss
olve
d co
ntam
inan
ts.
Ext
ract
ed g
roun
dw
ater
is
gene
rate
dan
d m
ust b
e m
anag
edin
acc
ord
wit
hre
quir
emen
ts tr
igge
red
by th
e se
lect
eddi
spos
al o
ptio
n.
Whe
n th
e io
n ex
chan
ge is
fill
ed, i
t can
be
rege
nera
ted
thro
ugh
back
flus
hing
. T
heco
ntam
inan
ts w
ill t
hen
beco
ncen
trat
ed in
the
back
flus
h,w
hich
wil
l nee
d to
be
trea
ted
to r
emov
e th
e m
etal
s or
man
aged
as
a ha
zard
ous
was
te if
it e
xhib
its
ach
arac
teri
stic
of
or “
cont
ains
”a
haza
rdou
s w
aste
.
Dis
posa
l of
wat
er.
Gro
und-
wat
er c
ompl
ianc
em
onit
orin
g.
Ele
ctro
chem
ical
Met
hods
Met
als
are
reco
vere
d fr
om a
queo
us s
olut
ions
by
appl
ying
an
elec
tric
al c
urre
nt to
two
imm
erse
del
ectr
odes
.
Ext
ract
ed g
roun
dw
ater
is
gene
rate
dan
d m
ust b
e m
anag
edin
acc
ord
wit
hre
quir
emen
ts tr
igge
red
by th
e se
lect
eddi
spos
al o
ptio
n.
Pre
cipi
tate
s w
ill f
orm
asl
udge
that
mus
t be
trea
ted
and/
or d
ispo
sed.
Dis
posa
l of
wat
er.
Dis
posa
l of
slud
ge a
s a
haza
rdou
s w
aste
.G
roun
d-w
ater
com
plia
nce
mon
itor
ing.
Gro
und
Wat
erJu
ne, 2
000
Pag
e 4-
7
Exh
ibit
4-3
Typ
ical
Gro
und
Wat
er T
reat
men
ts f
or R
adio
acti
ve W
aste
s an
d R
esul
ting
Res
idua
ls
Tre
atm
ent
Bri
ef T
echn
olog
y D
escr
ipti
onG
roun
d W
ater
Was
te G
ener
ated
Res
idua
l Was
te G
ener
ated
Fol
low
-On
Act
ivit
ies
Mem
bran
e F
iltr
atio
nU
ses
a se
mip
erm
eabl
e m
embr
ane
tose
para
te d
isso
lved
rad
ionu
clid
es o
rso
lid
radi
onuc
lide
fro
m th
e gr
ound
wat
er it
self
. Mem
bran
e fi
ltra
tion
has
been
dem
onst
rate
d to
be
effe
ctiv
e in
trea
ting
ura
nium
, rad
ium
, and
plut
oniu
m in
gro
und
wat
er.
Ext
ract
ed g
roun
d w
ater
is
gene
rate
d an
d m
ust b
e m
anag
ed in
acco
rd w
ith
requ
irem
ents
trig
gere
d by
the
sele
cted
dis
posa
lop
tion
.
Res
idua
l slu
dge
and
filt
erca
ke r
equi
re f
urth
er h
andl
ing,
trea
tmen
t, an
d/or
dis
posa
l.
Dis
posa
l of
slud
ge a
nd f
ilte
r ca
ke.
Ong
oing
mon
itor
ing
and
mai
nten
ance
of th
e tr
eatm
ent s
yste
m is
req
uire
d to
ensu
re lo
ng-t
erm
eff
ecti
vene
ss.
Car
bon
Ads
orpt
ion
Pum
ps g
roun
d w
ater
thro
ugh
a se
ries
of v
esse
ls c
onta
inin
g ac
tiva
ted
carb
on, t
o w
hich
dis
solv
edco
ntam
inan
ts a
dsor
b. W
hen
the
conc
entr
atio
n of
con
tam
inan
ts in
the
effl
uent
exc
eeds
a c
erta
in le
vel,
the
carb
on c
an b
e re
gene
rate
d in
pla
ce;
rem
oved
and
reg
ener
ated
at a
n of
f-si
te f
acil
ity;
or
rem
oved
and
dis
pose
dof
. Car
bon
adso
rpti
on h
as b
een
dem
onst
rate
d to
be
effe
ctiv
e in
trea
ting
ura
nium
, rad
on, a
nd c
obal
t in
grou
nd w
ater
.
Ext
ract
ed g
roun
d w
ater
is
gene
rate
d an
d m
ust b
e m
anag
ed in
acco
rd w
ith
requ
irem
ents
trig
gere
d by
the
sele
cted
dis
posa
lop
tion
.
Res
idua
l car
bon
adso
rpti
onun
it r
equi
res
furt
her
hand
ling
,tr
eatm
ent,
and/
or d
ispo
sal.
Dis
posa
l of
carb
on a
dsor
ptio
n un
it.
If d
ispo
sed
of, s
pent
car
bon
may
hav
eto
be
man
aged
as
a ha
zard
ous
was
te.
Ong
oing
mon
itor
ing
and
mai
nten
ance
of th
e tr
eatm
ent s
yste
m is
req
uire
d to
ensu
re lo
ng-t
erm
eff
ecti
vene
ss.
EH
-413
June
, 200
0
Tre
atm
ent
Bri
ef T
echn
olog
y D
escr
ipti
onG
roun
d W
ater
Was
te G
ener
ated
Res
idua
l Was
te G
ener
ated
Fol
low
-On
Act
ivit
ies Pag
e 4-
8
Aer
atio
nIn
ject
s ai
r in
to th
e gr
ound
wat
er,
form
ing
bubb
les
that
ris
e an
d ca
rry
trap
ped
and
diss
olve
d co
ntam
inan
tsto
the
wat
er s
urfa
ce. A
erat
ion
has
been
dem
onst
rate
d to
be
effe
ctiv
e in
trea
ting
rad
on in
gro
und
wat
er.
Ext
ract
ed g
roun
d w
ater
is
gene
rate
d an
d m
ust b
e m
anag
ed in
acco
rd w
ith
requ
irem
ents
trig
gere
d by
the
sele
cted
dis
posa
lop
tion
.
Res
idua
l was
te in
clud
es g
asem
issi
ons,
whi
ch m
ust
com
ply
wit
h C
lean
Air
Act
requ
irem
ents
.
An
air
trea
tmen
t sys
tem
may
be
requ
ired
to a
ddre
ss r
adon
gas
emis
sion
s.
Ong
oing
mon
itor
ing
and
mai
nten
ance
of th
e tr
eatm
ent s
yste
m is
req
uire
d to
ensu
re lo
ng-t
erm
eff
ecti
vene
ss.
Aer
atio
n is
oft
en a
pre
trea
tmen
t for
othe
r re
med
iati
on te
chno
logi
es, s
uch
as a
ir s
trip
ping
, and
can
be
foll
owed
by tr
eatm
ents
suc
h as
flo
ccul
atio
n,se
dim
enta
tion
, and
/or
filt
rati
on.
Ion
Exc
hang
eS
epar
ates
and
rep
lace
s ra
dion
ucli
des
in a
was
te s
trea
m w
ith
rela
tive
lyha
rmle
ss io
ns f
rom
a s
ynth
etic
res
inor
nat
ural
zeo
lite
(fo
r st
ront
ium
and
cesi
um),
ther
eby
prod
ucin
g a
clea
nst
ream
. Io
n ex
chan
ge h
as b
een
iden
tifi
ed a
s th
e B
est A
vail
able
Tec
hnol
ogy
(BA
T)
for
the
rem
oval
of
uran
ium
, rad
ium
-226
, and
rad
ium
-22
8; a
nd is
a d
emon
stra
ted
tech
nolo
gy f
or s
tron
tium
.
Ext
ract
ed g
roun
d w
ater
is
gene
rate
d an
d m
ust b
e m
anag
ed in
acco
rd w
ith
requ
irem
ents
trig
gere
d by
the
sele
cted
dis
posa
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Ground Water June, 2000
Page 4-10
For additional information onmonitoring requirements see FederalEnvironmental Monitoring Handbookavailable on the DOE OEPAhomepage at:[http://www.eh.doe.gov/oepa/ under“Policy and Guidance”].
EPA also recently released draftguidance on conducting 5-yearreviews as part of CERCLA actionsthat result in wastes left in place.
DOE Order M 435.1-1 establishesrequirements for TRU and LLWdisposal facility monitoring plansconducted under III(Q)(1-3) andIV(R)(1-3), respectively.
Exhibit 4-4 - Ground Water Monitoring Requirements
Regulation Application
NationalContingency Plan(NCP)
Monitoring requirements generally will be specified in theRecord of Decision (ROD) and are described in more detailin the remedial design and implementation documents.
CERCLA [40 CFR300.430(f)(4)(ii)]
If hazardous wastes remain in place, CERCLA requires theperformance of a five-year review. Project managers willneed to monitor during remedial actions to determine ifremedial action objectives (RAOs) are met or to determine ifa technical impracticability determination can be supported[40 CFR 300.430(a)(1)(iii)(F)]. The NCP does not specifyspecific time periods for monitoring, nor specific methods. These will be determined based on site conditions and thepurposes of the monitoring.
RCRA Subtitle CSubpart F (40 CFR264.100 (f))
The existing RCRA Subpart F regulations determine howground water must be monitored during corrective actionuntil standards have not been exceeded for a period of threeyears.
Interim StatusRequirements (40CFR 265)
The RCRA interim status subpart F requirements specify theground-water monitoring requirements that must be met atthis type of facility.
RCRA Subtitle Ccorrective actionrequirements(proposed at 55Federal Register30798, July 1990);withdrawn in 1999and never finalized
RCRA corrective action policies do not specify a uniformtime frame for demonstrating compliance. Rather, they leavethe type and frequency of monitoring to the RegionalAdministrator to specify the appropriate time frame on a site-specific basis.
Note: EPA has decided not to finalize the proposed SubpartS regulations, and is in the process of establishing newguidance to implement the corrective action program. ThisGuide reflects current Agency thinking, as it is available,about ground water monitoring and additional guidance isunder development
DOE Order M 435.1for RadioactiveWastes
For disposal facilities, a preliminary monitoring plan must besubmitted to Headquarters. The monitoring program shouldinclude measuring and evaluating effluent releases, migrationof radionuclides, disposal unit subsidence, and changeswhich may affect long-term performance. It should also becapable of detecting trends in performance that would affectmeeting performance objectives. All low-level wastefacilities must meet the requirements set out in M 435.1IV.R, which require monitoring for temperature, pressure(for closed systems), radioactivity in ventilation exhaust andliquid effluent streams, and flammable or explosive mixtureof gases.
EH-413 June, 2000
Page 4-11
Natural attenuation typicallydoes not generate environmentalrestoration waste or treatmentresiduals. Detailed informationabout use of natural attenuationcan be found in OSWERdirective, Use of MonitoredNatural Attenuation at Superfund,RCRA Corrective Action, andUnderground Storage Tank Sites,April 21, 1999, (9200.4-17P).
Plume monitoring requirementsunder a natural attenuationapproach can be extensive.
Air emissions may begenerated that will be subjectto the Clean Air Act or Statelaws. Emissions of volatileorganic contaminantsgenerated during RCRAcorrective action andCERCLA response actions,however, are exempt from therequirements in RCRASubpart CC under certaincircumstances, as specified in40 CFR 264.1080(b)(5),specifically when such wastesare placed in tanks orcontainers solely for on-sitetreatment as a result ofimplementing remediationactions.
4.3.1 Monitored Natural Attenuation - Hazardous Ground Water
Monitored natural attenuation (MNA) refers to reliance on naturalattenuation processes, including a variety of physical, chemical, orbiological processes that, under favorable conditions, act without humanintervention to reduce the mass, toxicity, mobility, volume, orconcentration of contaminants in soil or groundwater. In recent years,this approach has received extensive attention as a feasible remediationapproach. Natural attenuation is often used as a remediation strategy atsites where data indicate that natural processes will reduce contaminantsin ground water to levels protective of human health and theenvironment. Because managing the contaminated ground water bynatural attenuation is an in-situ approach and treatment method, noenvironmental restoration wastes or residuals are typically generated thatrequire management. (However, in some cases, natural attenuation mayresult in transformation products (e.g., vinyl chloride from TCEdegradation) that pose more risk to human health and the environmentthan the original chemical being treated).
Although managing contaminated ground water through monitorednatural attenuation generally does not create waste handling issues, thisremediation approach often requires a relatively long time forcompletion of the remedy and may involve extensive long-termmonitoring to ensure compliance with the cleanup standards. Accordingto EPA, MNA should be used very cautiously as the sole remedy atcontaminated sites. Therefore, consideration of monitored naturalattenuation may also lead to evaluating alternative in- or ex-situapproaches as contingency plans if performance requirements are notmet. Planning for handing of environmental restoration wastes mayneed to occur as a contingency when natural attenuation approaches areselected.
4.3.2 Active In-Situ Management - Hazardous Ground Water
There generally are not waste handling requirements for contaminatedground water managed in-situ because this type of remedy does notgenerate water. However, in-situ treatments that extract organiccontaminants as vapors do generate air emissions that are subject to theClean Air Act National Ambient Air Quality Standard restrictions orNational Emission Standards for Hazardous Air Pollutants. In addition,when residuals are extracted and captured through filters or otherequipment, the filters may become regulated themselves as hazardouswastes. Specifically, as a result of the concentration of certaincontaminants in a filter, the filter may exhibit a characteristic of ahazardous waste, or may remain a listed hazardous waste through thederived from rule [40 CFR 261.3(c)(2)(I)].
Ground Water June, 2000
Page 4-12
Materials not hazardousduring one phase of handlingmay become subject tohazardous wasterequirements during thetreatment process. Thisnecessitates that projectmanagers consider additionalcharacterization of wasteeach time contaminants aretransferred from one mediumor waste management systemto another.
Exhibit 4-5 summarizes the standards that may apply to residuals anddebris generated during use of active in-situ management options.
Exhibit 4-5Summary of Potential Standards for Hazardous Waste Residuals
Generated During In-Situ Management Actions
Type of In-Situ Residual Potentially ApplicableRegulatory Standard
Key ConsiderationsWhen Complying withStandard
Organic Vapors Air Emissionsrequirements underNESHAPs or under Stateair programs, or sitepermits to the degree thatremediation sources areincluded.
Short-term risk remedyselection criterion underCERCLA and RCRAcorrective action mayrequire evaluation todetermine if controls arewarranted.
1. Characterize emissionsto determine volume andnature to determine ifNESHAPs or otherrequirements apply, or ifcontrol technologies areneeded.
2. Evaluation of riskduring the remedialresponse may be requiredfor remediation decisiondocuments.
Spent Carbon Filters RCRA LDRs (40 CFR268) may applydepending on thematerials captured in thefilters. Either the filtersmay become listedhazardous waste throughthe derived from rule, orexhibit a characteristic ofa hazardous waste.
Filters may be recyclableby a permitted entity. Opportunities often existto integrate remediationmanagement needsequipment acquisitionassociated with existingon-site monitoringprograms.
Other filters or equipmentused during in-situextraction
Contact with hazardouswastes may causeequipment to becomehazardous waste (e.g.,debris).
Careful consideration ofdecontamination methodsmay be necessary tominimize furtherregulatory problems.
EH-413 June, 2000
Page 4-13
Wastes transported off siteare subject to both RCRAand DOT regulations. Wastes transported onsite aresubject to restrictionsoutlined in the site permitand site procedures. In allcases, corresponding Stateregulations may apply.
Hazardous wastes that areforbidden from off-sitetransfer are identified in 49CFR 172.101.
4.3.3 Ex-Situ Management - Hazardous Ground Water
Ground water that is managed ex-situ is subject to varying storage andhandling requirements depending upon several factors. These factorsinclude the 1) degree and level of contamination, 2) the quantity ofground-water environmental restoration waste generated, 3) the site’sexisting RCRA permit status, and 4) whether the ground water will betreated on site or off site.
Requirements During Initial Waste Handling Activities
In many cases, ground water is extracted and sent directly to a treatmentsystem without any temporary staging or storage in a separate unit. Thisdirect transport to treatment units eliminates many requirementstypically associated with storage of hazardous wastes.
In other cases, direct treatment of extracted ground water may not bepossible and the contaminated ground water is stored, resulting in certainregulatory requirements needing to be met (e.g., RCRA storagerequirements for hazardous waste). This is particularly true duringinvestigations when sampling of extracted ground water may be requiredbefore a waste management option can be used. Activities that mayoccur during pre-treatment of extracted ground water include:
& Transport (e.g., via pipe, truck);& Storage of ground water extracted from wells as a part of sample
collection activities (e.g., in tanks, containers); and& Compliance assurance and record keeping and other similar
requirements.
Transport Requirements
If environmental restoration waste that must be managed as a hazardouswaste is being transported to an off-site treatment facility, the projectmanager must comply with the manifest requirements of Federalgenerator requirements found at 40 CFR 262 (or an equivalent Stateprogram), which typically include:
& Identification of the hazardous waste (40 CFR 262.11);& Identifying the Treatment, Storage, and Disposal (TSD) facility,
transportation mode, and company handling the waste (40 CFR262.12);
& Properly packaging the waste (40 CFR 262.30);& Abiding by labeling, marking, and placarding requirements (40
CFR 262.30 -262.33); and& Completing and signing the manifest (40 CFR 262.20 -262.23).
The Federal requirements for the transporter of the waste are identified
Ground Water June, 2000
Page 4-14
Waste accumulation andstorage requirements changeif the site manages any wastesgenerated in a temporaryunit (TU) or obtains aremediation action plan(RAP) under the new HWIR-Media rule (63 FR 65873,November 30, 1998) . Thestreamlining available fromTUs and a RAP in managingcontaminated ground water isdiscussed in part 4.6.
in 40 CFR 263. In developing these regulations, EPA adopted most ofthe Department of Transportation’s requirements for transportinghazardous waste (49 CFR 171 - 179), although a transporter should alsorefer directly to the DOT regulations to ensure they are in compliance.
Storage Requirements
Sites that are storing contaminated ground water that is hazardous wastemust label the waste tanks or containers storing the water as hazardous, and comply with the regulations for tank systems (Subpart J of 40 CFRParts 264 and 265) or container systems (Subpart I of 40 CFR Parts 264and 265) while the waste is being stored onsite.
If ground water containing hazardous waste will only be transported toan on-site treatment facility, the RCRA transporter requirements are nottriggered, but on-site transport restrictions that may be included in theRCRA permit, order, compliance agreement, or operating procedure mayhave to be met.
Compliance Assurance and Record Keeping
Whenever hazardous wastes are generated or stored, they are subject toroutine inspection, record keeping, and reporting requirements. Theseare outlined in 40 CFR 262 or the corresponding State regulations. If theaction is taken under CERCLA and these requirements are ARARs, thanthe compliance assurance and record keeping requirements need to bemet.
Permit Considerations
The current RCRA permit status of a site where remediation is occurringwill often affect the subsequent need to obtain a permit or a permitmodification for managing hazardous ground water when it is anenvironmental restoration waste. Under RCRA, a project manager cangenerate and store environmental restoration waste without obtaining apermit provided certain quantity limits and accumulation timerestrictions are met. To generate and store environmental restorationwastes without a permit, the site can not store the wastes in tanks,containers, drip pads, or containment buildings for more than 90 days. Small quantity generators, those who generate 100 - 1000 kg per month,may store wastes without a permit for up to 180 days provided the totalquantity of waste onsite does not exceed 6,000 kg. EPA or the State maygrant extensions to these accumulation restrictions on a case-by-casebasis. Accumulation units must meet applicable design, operating,closure, and post-closure standards.
If the waste will be treated onsite then the site will need to comply with
EH-413 June, 2000
Page 4-15
If the contaminated groundwater will be treated on site,the facility at the site willneed a RCRA TSDF permit.
The exemption for ninety-dayaccumulations is found inregulations at 40 CFR 262.34;associated preamblediscussion is at 51 FR 10168(March 24, 1986).
a RCRA corrective action order, have a RCRA TSDF permit or interimstatus, comply with all the applicable sets of requirements in 40 CFRparts 264 and 265 for the specified treatment, or use one of thecompliance options discussed in Section 4.6. Alternatively, the unitmay be subject to RCRA’s permit-by-rule provisions (40 CFR 270.60),and will only have to be in compliance with these requirements to beconsidered permitted. The permit-by-rule provisions apply to thefollowing types of facilities:
& Underground injection wells with permits under the SafeDrinking Water Act (SDWA);
& POTWs with NPDES permits; and& Ocean disposal barges or vessels with ocean dumping permits.
Under CERCLA 121(e), project managers must only meet thesubstantive requirements of other laws and regulations for on-siteactions. This removes the need to require permits as part of a responseaction. Substantive requirements such as inspections and use of propercontainers still must be met.
Requirements During and After Remediation Activities
During treatment, the requirements for managing hazardous groundwater fall into two types of requirements:
& Ensuring that any regulatory requirements established asapplicable during the pre-treatment phase (e.g., related totransport, storage, or staging of wastes) continue to be met, particularly during any periods where treatment systems may beidle due to logistical problems or mechanical failures; and
& Evaluating the regulatory status of treated ground water and anyresiduals generated to ensure that post-treatment plans for wastehandling are still appropriate.
As remediation occurs and wastes are generated, issues for units treatingex-situ ground-water include proper handling of the residualcontaminants separated from the water and management of the treatedground water, as outlined below. In addition, units in which wastemanagement is no longer occurring will be subject to closure and post-closure care requirements.
Managing Residuals Generated During Treatment
Residuals from ground-water treatment typically have to be managed as
Ground Water June, 2000
Page 4-16
More information regardingstrategy and treatment of groundwater can be found inPresumptive Response Strategyand Ex-Situ TreatmentTechnologies for ContaminatedGround Water at CERCLA Sites,EPA OSWER Directive 9283.1-12, October 1996.
Extracted ground water can be:
1. reinjected;2. discharged through a NPDES permit;3. sent to a POTW or FOTW; or4. treated at an onsite wastewater treatment plant.
hazardous waste because the RCRA derived-from rule make them listedwastes or the contaminants present in the residuals result in the wasteexhibiting a hazardous characteristic. Examples of these residualsinclude carbon filters from granular activated carbon (GAC),precipitates, and sludges from treatment operations (See Exhibit 4-5).
Options for Managing Treated Water
Treated ground water typically is reinjected into an aquifer, dischargedthrough a National Pollutant Discharge Elimination System (NPDES)permit, sent to a Publicly Owned Treatment Works (POTW) or FederallyOwned Treatment Works (FOTW), or treated in an on-site wastewatertreatment plant. The selection of a management option will depend onregulatory considerations, characteristics of the treated ground water,availability of a management option, and local considerations about theuse of the treated ground water.
Requirements for each available option are described below.
1. Reinjection. If the ground water no longer exhibits a characteristic ofa hazardous waste or no longer “contains” a listed waste, then directreinjection of the ground water may be permitted in accordance with aState or local reinjection program. If the ground water wascontaminated with a listed hazardous waste (even in low concentrations)then it cannot be reinjected unless certain requirements are met (e.g., thewell can legally accept hazardous waste under a underground injectionprogram or other legal mechanism). If the ground water was extractedduring a RCRA corrective action or is managed off site under aCERCLA response action, then the ground water may have to undergo a“contained out” evaluation or formal delisting procedure before it can bereinjected.
Delisting (obtaining a regulatory determination that a waste is no longerlisted wastes because of the concentrations of the contaminants present)may be an option to consider for ground water with low concentrationsof listed wastes, as evaluated and determined by the EPA or StateAdministrator. “Low concentrations” are evaluated by comparing the concentration of constituents present to the leachate concentration asdetermined using the TCLP, or health-based levels such as MaximumContaminant Levels (MCLs). Ground water with higher concentrationsmay also be delisted based on fate-and-transport modeling results. If theextracted ground water was contaminated with a listed waste, removedduring a CERCLA response action, and managed on site, the fieldmanager will not need to undergo the delisting petition and rule-makingprocess. Compliance with the substantive delisting requirements shouldbe documented in the Record of Decision, Statement of Basis, orapplication for a permit modification.
EH-413 June, 2000
Page 4-17
Federal regulations governing discharges through a NPDESpermit are codified in 40 CFR122-125, 129.
Federal POTW pre-treatmentrequirements are codified in 40CFR 403.
For more information onFOTWs, please refer toFederal Facility ComplianceAct Implications for RCRACorrective Action, EH-231-015/0994, September 1994,
[http://www.eh.doe.gov/oepaunder “Policy andGuidance”].
2. National Pollutant Discharge Elimination System. In some cases,treated ground water can be directly discharged to surface waters under aNPDES permit. Extracted ground water discharged through a NPDESpermit will also be subject to state and federal water quality criteria. Ifthe extracted ground water is contaminated with radioactive mixed wasterather than hazardous waste, it cannot be discharged through a NPDESpermit without first applying the BAT for treating the radioactivecomponent in addition to meeting any requirements for hazardousconstituents that are present..
3. Publicly Owned Treatment Works and Federally Owned TreatmentWorks. In some cases extracted ground water can be discharged to aPOTW. Some discharges are directly prohibited or will require specialapproval. Discharges that are explicitly prohibited from all POTWsinclude:
& Pollutants that create a fire or explosion hazard;& Pollutants that are corrosive;& Solid or viscous pollutants;& Pollutants that will cause “ interference” with the POTW such as
oxygen demanding pollutants;& Heat in amounts that will inhibit biological activity;& Petroleum oils, nonbiodegradable cutting oil, or mineral oil
products; and& Pollutants that will cause toxic gases, vapors or fumes.
If the ground water originated from a CERCLA response action, the fieldmanager will need to confer with the Regional Offsite manager to ensurethat the POTW meets EPA’s criteria for an “acceptable” offsite facility. Extracted ground water originating from a RCRA corrective action is notsubject to the off-site rule (citation). The field manager will need to referto the requirements specific to the POTW to determine if any wastewateracceptance restrictions or pretreatment requirements exist.
The Federal Facilities Compliance Act modified RCRA Subtitle C toensure similar treatment for both municipal POTWs and FOTWs. The modified sections provide that FOTWs are exempted from RCRAregulations if one of the following criteria are met:
& Materials must be subject to a pretreatment standard undersection 307 of the Clean Water Act (CWA);
& Materials not currently covered by a pretreatment standard mustbe in compliance with an EPA promulgated pretreatmentstandard that was applicable before October 6, 1999;
Ground Water June, 2000
Page 4-18
DOE Order 5820.2A, the previousRadioactive Waste ManagementOrder, has been canceled andreplaced by DOE Order 435.1and DOE Manual 435.1 as ofJuly, 1999.
DOE Manual 435.1 establishesthat “environmental restorationactivities using the CERCLAprocess...may demonstratecompliance with the substantiveelements of DOE O 435.1...andthis Manual...through theCERCLA process.” In general,CERCLA actions will accomplishthis by ensuring protection ofhuman health and theenvironment and identifying theappropriate parts of the Manualthat are appropriate to meet.
& Materials not covered under either of the above criteria aretreated in accordance with applicable LDRs; or
& The generator is a conditionally exempt small quantitygenerator (CESQG).
4. On-site Wastewater Treatment. To treat the extracted ground wateron site, the site must have a RCRA treatment, storage, or disposalfacility permit (or meet permit-by-rule requirements) and must handlethe extracted ground water in accordance with the requirements for thepermit, generally by complying with the facility’s permit criteria andoperating plans about what wastes can be accepted.
4.4 Basic Management Requirements During Pre-Treatment,Treatment, and Post-Treatment Phases for RadioactiveWaste
This section outlines the requirements for extracted ground water thatcontains radioactive constituents and, therefore, that must be managed asa radioactive waste. The sections that follow describe the requirementsfor storage, treatment, and packaging of ground water transuranic andlow level environmental restoration wastes. More details about therequirements for constructing facilities for disposing of residuals fromthe treatment of contaminated ground water are found in Chapter 5 ofthis Guide.
4.4.1 Storage Requirements for Radioactive Wastes
In general, extracted radioactively contaminated ground water is unlikelyto be stored unless it is awaiting sampling and analysis results. Thisstorage would commonly occur in tanks or drums. Whenever storageoccurs, it must be done in accordance with site-specific operatingprocedures or site waste acceptance criteria for a storage facility or unit. DOE Order M 435.1-1 establishes general baseline storage requirementsfor all radioactive waste types in Section I (2)(F)(13). According tothese requirements all radioactive waste must be stored in a manner thatprotects the public, workers, and the environment in accordance with aradioactive waste management basis, and that integrity of waste storageis maintained for the expected time of storage and does not compromisemeeting the disposal performance objectives for protection of the publicand environment when the waste is disposed. DOE Order M 435.1-1also provides specific storage requirements for TRU and LLW.
The requirements for storage of TRU liquid wastes such as contaminatedground water are contained under the site facility design, storage andmonitoring requirements of DOE Order M 435.1-1, Sections III M, N,
EH-413 June, 2000
Page 4-19
A radioactive waste managementbasis includes elements such as awaste certification program andwaste acceptance criteria, and(for disposal facilities) theperformance assessment,composite analysis, disposalauthorization statement, closureplan, waste acceptancerequirements, and monitoringplan.
and Q respectively:
Site facility design:
• Engineering controls shall be incorporated in the design andengineering of TRU waste storage facilities to provide volumeinventory data and to prevent spills, leaks, and overflows fromtanks or confinement systems.
• Monitoring and/or leak detection capabilities shall beincorporated in the design and engineering of TRU wastestorage facilities to provide rapid identification of failedconfinement and/or other abnormal conditions.
Storage:
• TRU in storage should not be capable of detonation, explosivedecomposition, reaction at anticipated pressures or temperatures,or explosive reaction with water.
• TRU shall be stored in a location and manner that protects theintegrity of waste for the expected time of storage and minimizesworker exposure.
• If ground water contaminated with TRU is generated duringremediation (e.g., in tanks), it must be stored in a segregatedmanner to avoid commingling of non-compatible waste streams,and must be monitored as prescribed by the facility safetyanalysis to ensure wastes are maintained in a safe condition.
Monitoring:
• Parameters such as temperature, gaseous pressure (for closedsystems), radioactivity in ventilation exhaust and liquid effluentstreams and flammable or explosive mixtures of gases shall bemonitored at TRU storage facilities to ensure that passive andactive control systems have not failed.
• All TRU wastes in storage shall be monitored to ensure thewastes are being maintained in safe condition.
The requirements for storage of low-level liquid wastes such as contaminated ground water are in DOE Order M 435.1-1 SectionsIV (L)(1)(a), IV (M) and IV (N). Requirements for LLW storageinclude:
DOE Order M 435.1-1 SectionsIII M, N and Q containrequirements for storage ofTRU waste[http://www.explorer.doe.gov:1776/htmls/currentdir.html].
Ground Water June, 2000
Page 4-20
Interim storage of low-level wasteawaiting treatment or disposalwill be limited to 180 days unlessapproved by the field elementmanager.
Packaging:
• LLW shall be packaged in a manner that provides containmentand protection for the duration of the anticipated storage periodand until final disposal is achieved or until the waste has beenremoved from the container.
Site evaluation and facility design:
• Engineering controls shall be incorporated in the design andengineering of LLW storage facilities to provide volumeinventory data and to prevent spills, leaks, and overflows fromtanks or confinement systems.
• Monitoring and/or leak detection capabilities shall beincorporated in the design and engineering of LLW treatmentand storage facilities to provide rapid identification of failedconfinement and/or other abnormal conditions.
Storage and Staging:
• Waste in storage shall not be readily capable of detonation,explosive decomposition, reaction at anticipated pressures andtemperatures, or explosive reaction with water;
& Wastes must be segregated based upon compatibility, safetycriteria, and hazards;
& Wastes must be stored in a manner that protects the integrity ofthe waste package for the expected time of storage;
& Wastes with an identified disposal path cannot be stored longerthan a year prior to disposal except for storage for decaypurposes;
• Wastes without an identified path shall be characterized toensure safe storage and to facilitate disposal;
• Characterization information shall be maintained;
• A process for low-level waste package inspection(s) andmaintenance shall be developed and implemented to ensure thatcontainer integrity is not compromised;
• Low-level waste storage shall be managed to identify andsegregate low-level waste from mixed low-level waste; and
DOE Order M 435.1-1Sections IV (L)(1)(a), M andN contains requirements forthe storage of LLW liquidwaste. [http://www.explorer.doe.gov:1776/htmls/currentdir.html].
EH-413 June, 2000
Page 4-21
Treated ground water will alsoneed to comply with any RCRArequirements that are triggeredby the presence of hazardousconstituents prior to reinjectionor disposal.
• Staging, or interim storage of LLW for the purposes ofaccumulating sufficient waste quantities to facilitate transport,treatment and disposal, that occurs longer than 90 days shallmeet the waste storage requirements of Section IV of DOEOrder M 435.1-1.
4.4.2 Treatment Requirements for Radioactive Wastes
The treatment requirements for ground water contaminated withradionuclides will primarily be driven by the WAC of the treatmentand/or disposal facility. Because the major disposal facilities forradioactive waste cannot accept liquid radioactive waste, the groundwater generally must be treated to separate the radioactive constituentsfrom the contaminated ground water. [Exhibit 4-3 provided a descriptionof treatment technologies for radionuclides in ground water.]
Following treatment, the separated treatment residuals, which generallyare still radioactive wastes, can then either be disposed on site or sent toan on- or off-site facility. Similar to hazardous waste, the treated groundwater can then be reinjected, discharged through a NPDES, or sent to aPOTW or FOTW. The selection of a management option will depend onregulatory considerations, characteristics of the treated ground water,availability of a management option, and local considerations about theuse of the treated ground water.
If treatment facilities will be constructed and operated for radioactivewaste as part of an environmental restoration project (e.g., rather thanusing existing facilities on or off site), project managers must ensure thatthe requirements for new facilities (e.g., facility design) specified in theDOE Order must be met.
For example, TRU waste treatment facilities must provide engineeringcontrols and monitoring and/or leak detection capabilities to preventspills and monitor waste inventory, and for detection of failed wastecontainment and/or other abnormal conditions. Detailed monitoringrequirements for TRU storage facilities are defined under Section III(Q)(3) (Monitoring) of DOE Order M 435.1-1. These additionalprovisions require that facilities storing liquid TRU monitor liquid levels and/or waste volumes, along with significant waste chemistryparameters.
4.4.3 Package Requirements for Radioactive Wastes
If wastes will be shipped, appropriate packaging requirements will needto be used. Packaging requirements are generally appropriate forresiduals generated from treating ground water rather than the treated
LLW treatment requirements arecontained under Section IV (O) andunder related Sections IV (M)(2)(b)(Site evaluation and design), IV(M)(2)(d&e) (LLW Treatment andStorage Design), IV (N)(1) (Storageand Staging), IV (N)(6) (StorageManagement), and IV(R)(2)(Monitoring).
TRU treatment requirements arecontained under Sections III(M)(2)(d&e), III (N), III(O) andII(Q)(3) of DOE Order M 435.1-1;Instrumentation and ControlSystems, Storage, Treatment, andMonitoring requirements,respectively.[http://www.explorer.doe.gov:1776/htmls/currentdir.html]
Ground Water June, 2000
Page 4-22
A November 6, 1998, FederalRegister notice (63 FR 59989)extended EPA’s policy of usingenforcement discretion whenenforcing the RCRA Section3004(j) storage prohibition formixed wastes. This allows mixedwastes, prohibited from landdisposal, to continue to be storedas long as there are no availableoptions for treatment of disposal.
ground water itself.
TRU wastes must be packaged so that containment and protection of thewaste are provided for the duration of the projected storage period anduntil the waste is disposed or removed from the container. TRUpackaging must prevent pressurization or generation of reactive,explosive, or flammable gases within waste containers must be used. Containers of TRU must be inspected and maintained to ensure thatpackage integrity is not compromised. In addition, defense waste mustbe separated from non-defense waste during packaging to the extent thatit is feasible.
LLW also must be packaged in a manner that provides containment forthe duration of the anticipated storage period and until disposal. Whenthe LLW is packaged, the waste must be documented, marked, andlabeled to identify the contents of the package and for reporting on thewaste manifest. Safety measures such as vents and aeration devicesshould be used on waste packages if the potential exists forpressurization or generation of flammable or explosive concentrations ofgases within the waste container.
4.4.4 Disposal Requirements
Following any treatment, ground water that was contaminated withradionuclides can be disposed by methods such as reinjection to theaquifer or discharge. In either case, site- or unit-specific requirementswill govern the conditions under which the disposal will occur.
4.5 Basic Management Requirements During Pre-Treatment,Treatment, and Post-Treatment Phases for Mixed Waste
Mixed hazardous and radioactive wastes are subject to the requirementsof both RCRA (or the corresponding State program) and therequirements of DOE radioactive waste management orders. Therequirements under each of these legal and regulatory programs arespecified in Sections 4.3 and 4.4 of this chapter.
There are very few specific mixed waste requirements specified inFederal or State law because the authority to regulate these wastes issplit between different agencies and authorities (with each authorityestablishing requirements for its portion of the waste). In some cases,however, provisions of regulations do provide special accommodations for mixed wastes. For example, different time frames and approaches toregulation are often in effect for mixed wastes that are subject to RCRAland disposal restrictions because a shortage of management capacity hasled EPA to issue some extension to effective dates or adopt modifiedenforcement strategies. Mixed waste residuals that are generated from
LLW packaging requirements arecontained in Section IV (L)(1)(a-c)(Packaging and Transportation) ofDOE Order M 435.1-1.
TRU packaging requirements areoutlined in DOE Order M 435.1-1,Sections III(L)(1)(a-d) (Packagingand Transportation) and III (N)(3)(Storage Container Inspection). External radiation levels forpackages can not exceed 200millirem per hour of contact (49CFR 173.441).
EH-413 June, 2000
Page 4-23
Additional informationconcerning ARARs can befound in DOE’s Compendiumof Applicable or Relevant andAppropriate Requirements:Quick Reference Fact Sheetsand Directives (CERCLA)-005/1019.
treatment of ground water, therefore, may not currently be subject toLDR requirements even though an LDR treatment standard is in effectfor the corresponding RCRA waste code.
4.6 Alternate Compliance Options
Several compliance options exist that project managers can use toovercome barriers associated with management of contaminated groundwater. These options include:
4.6.1 Determination that hazardous wastes are no longer hazardouswastes;
4.6.2 ARAR waivers;4.6.3 Temporary units;4.6.4 Remedial Action Plan (RAP); and4.6.5 RCRA Section 3020 exemption.
Two other waivers – use of alternate concentration levels anddetermination of technical impracticability – directly apply to groundwater that is environmental restoration waste. However, rather thanalternative management approaches, these waivers provide projectmanagers with approaches to setting alternate cleanup levels for anaquifer.
4.6.1 Determination That Wastes are No Longer HazardousWastes
Hazardous wastes may be managed as non-hazardous if it isdemonstrated that after treatment for hazardous materials, extractedground water does not contain levels of hazardous constituents thatrequire further management as a hazardous waste. Generally, EPAguidance establishes the levels as health-based levels, based on thecontained-in policy (see Chapter 3).
Radioactive wastes are no longer subject to the requirements of DOEOrder 435.1 when they no longer require management for theirradioactive content. This will require a waste stream-specific evaluationto determine the nature of a treated (or untreated) liquid waste toevaluate whether it is still subject to management requirements.
4.6.2 ARAR Waivers
Under CERCLA remedies, field managers can seek an exemption fromclean-up standards by invoking an ARAR waiver. The restrictions oninvoking waivers are codified in 40 CFR 300.430. ARAR waivers aregenerally granted for the following reasons:
& Compliance will create a greater risk to human health or the
Ground Water June, 2000
Page 4-24
For example, see PresumptiveResponse Strategy and Ex-situTreatment Technologies forContaminated Ground Water atCERCLA Sites, October 1996,EPA 540/R-96/023.
EPA established RAP underthe new HWIR-Media rule(63 FR 65873, November 30,1998).
environment;& Technical impracticability;& An alternative can result in an equivalent standard of
performance;& The state has inconsistently applied the requirement; or& The action is an interim measure.
Extensive EPA information exists on obtaining a technicalimpracticability waiver for ground water. For example, EPA hasrecently issued its presumptive response strategy for ground water.
4.6.3 Temporary Units
Temporary units (40 CFR 264.552) and corrective Action ManagementUnits (CAMUs) (40 CFR 264.553) were promulgated jointly andprovide regulatory flexibility when managing environmental restorationwastes. Generally, CAMUs are not useful for the remediation ofcontaminated ground water, but temporary units may be appropriate toconsider.
A TU, however, may be useful in facilitating treatment of contaminatedground water. The advantages of using a TU are that the ground watercan be stored for a longer period of time before treatment, and the tankor storage container does not have to meet strict requirements forsecondary containment. Using TUs to store extracted ground water canreduce the costs of storage containers, allow for the actualization ofeconomies of scale when selecting off-site treatment options, andprovide greater flexibility in the timing of ground-water treated ordisposed of on site.
4.6.4 Remedial Action Plans
EPA developed regulations allowing remedial action plans (RAPs) withsix objectives in mind:
1. RAPs should be suited to the specifics of managing remediationwaste in the context of cleanup, both in procedure and insubstantive requirements;
2. RAPs should ensure compliance with the applicablerequirements for safe hazardous remediation waste management;
3. RAPs should provide certainty and protection to the permittedparty, as appropriate;
4. the RAP approval process should provide opportunities formeaningful public involvement;
5. because RAPs constitute RCRA permits, the RAP approval
EH-413 June, 2000
Page 4-25
For more information on theexemption for reinjection ofcontaminated ground water,see RCRA Section 3020(b),OSWER Directive 9234.1-06,Applicability of Land DisposalRestrictions to RCRA andCERCLA Ground WaterTreatment ReinjectionSuperfund Management Review:Recommendation No. 26,November 27, 1989.)
process must, at the least, follow the statutory minimumrequirements for obtaining a permit; and
6. RAPs, and the RAP approval process should accomplish theprevious objectives through the most streamlined, reasonable,and understandable regulations possible.
The RAP requirements:
• significantly reduce procedural steps in permitting, whileretaining the minimum statutory public participationrequirements and certain basic permitting steps or conditions(for example, permit appeal procedures);
• replacing the detailed requirements of §§ 270.3-270.66 withbroader performance standards;
• significantly reducing and focusing information requirements;and
• removing the requirement for facility-wide corrective action.
RAPs are limited to the treatment, storage, or disposal of hazardousremediation wastes. As the preamble to the HWIR media rule discusses,the definition of remediation waste is limited to wastes that are managedto implement cleanup. This definition does not include “as-generated” process waste or wastes from any activities that are notspecifically implemented for the purposes of cleanup.
4.6.5 RCRA Section 3020 Exemption
EPA has developed an exemption for the reinjection of contaminatedground water. Under RCRA Section 3020(a), disposal of hazardouswaste into or above a formation that contains an underground source ofdrinking water is generally prohibited. RCRA Section 3020(b) providesan exception for underground injection carried out in connection withcertain remediation activities. Under RCRA Section 3020(b), injectionof contaminated ground water back into the aquifer from which it waswithdrawn is allowed if (1) such injection is conducted as part of aresponse action under Section 104 and 106 of CERCLA or a RCRAcorrective action intended to clean up such contamination; (2) thecontaminated ground water is treated to substantially reduce hazardousconstituents prior to reinjection; and, (3) the response action orcorrective action will, on completion, be sufficient to protect humanhealth and the environment. Approval of reinjection under RCRASection 3020(b) can be included in approval of other cleanup activities,for example, as part of approval of a RCRA Statement of Basis orCERCLA Record of Decision.
Ground Water June, 2000
Page 4-26
For more information refer to,Technical ImpracticabilityDecisions for Ground Water atCERCLA Response Action andRCRA Corrective Action Sites,DOE/EH-413/9814, August, 1998,[http://www.eh.doe.gov/oepa/under “Policy and Guidance”].
ACLs can be used under bothCERCLA and RCRAremediations but are interpreteddifferently under the two statutes. More information concerningACLs can be found in EPAOSWER Directive 9283.1-2, 1988and in Use of AlternateConcentration Limits (ACLs) toDetermine Cleanup or RegulatoryLevels Under RCRA andCERCLA, DOE/EH-413-9912-1,December, 1999,[http://www.eh.doe.gov/oepa/under “Policy and Guidance”].
Two other variances exist that may affect the management ofremediation waste:
• RCRA technical impracticability waiver• Alternate Concentration Limits
4.6.6 RCRA Technical Impracticability
The RCRA proposed Subpart S § 264.525 (d)(2)(iii) requirements[withdrawn October 7, 1999, 64 FR 54604] allowed the RegionalAdministrator to determine that media cleanup standards do not need tobe met when remediation is technically impracticable. A RCRAdetermination of technical impracticability can be made where the“nature of the waste and the hydrogeologic setting would prevent orlimit the effectiveness of a pump-and-treat system”, or when remediationmay be “possible but the scale of operations required might be of such amagnitude and complexity that the alternative would be impracticable”(55 Federal Register 30830, July 1990). It should be noted that a waiverfor technical impracticability does not relieve the site of ultimateresponsibility for the contaminated media.
4.6.7 Alternative Concentration Limits (ACLs)
ACLs are intended to provide flexibility in establishing ground-watercleanup levels. Under CERCLA, ACLs can be used as the mediacleanup standard in place of MCLs if the following criteria are met:
& The ground water has known or projected points of entry intosurface waters;
& There are no “statistically significant” increases of contaminantconcentrations in the surface water at the point of dischargedownstream; and
& Institutional controls can be reliably used to prevent humanexposure to the contaminated ground water. [CERCLA§121(d)(2)(B)(ii)]
If an ACL is established then an ARAR waiver will not be required.
In the existing RCRA Subpart F requirements, ACLs are one of threemethods allowed for developing concentration levels for contaminants inground water. The factors that the Regional Administrator mustconsider in establishing ACLs are extensive and are listed in 40 CFR264.94 (b). Unlike the use of ACLs under CERCLA remediations,RCRA does not limit ACLs to cases where ground water discharges tosurface waters.
Although the nomenclature of ACLs is not specifically used in the
EH-413 June, 2000
Page 4-27
proposed Subpart S regulations, they do allow the RegionalAdministrator to develop “alternate measures” to protect human healthand the environment if:
& The contamination originated from a source other than a SolidWaste Management Unit (SWMU);
& The ground water is not a potential source of drinking water; andis not hydraulically connected with waters where the constituentwould exceed an action level; or
& Remediation is technically impracticable. (55 FR 30878, July1990)
EH-413 June, 2000
Page 6-1
This chapter is organizeddifferently than Chapters 4 and 5because unique handlingrequirements exist for hazardousdebris.
Chapter 6Management of Contaminated Debris During
Environmental Restoration Actions
This chapter summarizes the primary technical and regulatoryrequirements for the treatment, storage, and disposal of contaminateddebris when it is an environmental restoration waste. It also provides anoverview of the options for managing contaminated debris. Types ofdebris waste covered in this section include hazardous, radioactive, andmixed wastes as well as other types of debris such as PCBs and asbestos-containing waste. It is organized in the sections shown in Exhibit 6-1.
Exhibit 6-1Summary of Chapter Sections
Section Summary of Contents
6.1 Summary of Major Requirements(page 6-1)
A summary of the major requirementsassociated with managing hazardous,radioactive, and mixed waste debris.
6.2 Concepts and Definitions (page 6-2) Provides key definitions needed tocomply with debris requirements.
6.3 Management Options for HazardousDebris (page 6-3)
Describes two options for managinghazardous debris: (1) meeting LDRtreatment standards; or (2) meetingalternate debris-specific standards. Alsodescribes how to manage treatmentresidues and requirements for facilitiestreating debris.
6.4 Management of Radioactive, MixedWaste, and Other Types of Debris(page 6-10)
Describes requirements for radioactive,mixed waste, PCB, and asbestos debris.
6.5 Exemptions for Managing Debris(page 6-13)
Describes available exemptions formanaging contaminated debris.
6.1 Summary of Major Requirements
The following are the major requirements and approaches for managingdebris when it is an environmental restoration waste:
• Mixtures of debris and other materials, such as soil or sludge,are regulated as debris if the mixture is comprised primarily ofdebris (by volume) based on visual inspection. A distinctionproject managers will need to make early when managing debrisis whether it will be subject to RCRA or an equivalent Statehazardous waste program (i.e., because it is a hazardous waste or
Debris Environmental Restoration Management Guide
1 NOTE: On January 12, 2000, the Secretary of Energy placed a moratorium on the Department’s release of volumetricallycontaminated metals pending a decision by the Nuclear Regulatory Commission (NRC) whether to establish national standards [News Release –Energy Secretary Richardson Blocks Nickel Recycling at Oak Ridge]. Therefore, the Department will not allow the release of scrap metals forrecycling if contamination from DOE operations is detected using appropriate, commercially available monitoring equipment and approvedprocedures. Consequently, the unrestricted release for recycling of scrap metals from radiation areas is suspended until improvements in releasecriteria and information management have been developed and implemented. Additionally, on July 13, 2000, the Secretary [SecretarialMemorandum-Release of Surplus and Scrap Materials] directed further action in four areas: (1) improvement of the Department’s release criteriaand monitoring practices; (2) expansion of efforts to promote reuse and recycling within the complex of DOE facilities; (3) improvement of theDepartment’s management of information about material inventories and releases; and, (4) the accelerated recovery of sealed sources asdescribed in the July 13, 2000, Secretarial memorandum. While updated release criteria and record keeping procedures are being developed andimplemented, the Department will undertake several activities to promote internal reuse and recycling. Finally, when revised directives andguidance are in place, the Department will require each DOE site to have local public participation before the site may resume the unrestrictedrelease for recycling of scrap metals from radiation areas.
Page 6-2
The debris-specific RCRA LDRrequirements are promulgated at40 CFR 268.45.
For example, see DOE Order5400.5 for generic unconditionalrelease criteria for surfacecontamination. For an exampleof determining when debris is nolonger considered subject toradioactive waste requirements,see Draft Handbook forControlling Release for Reuse orRecycling of Non-Real PropertyContaining Residual RadioactiveMaterial, June, 1997,[http://www.eh.doe.gov/oepa/under “Policy and Guidance”].
See http://www.eh.doe.gov/oepa/under “Policy and Guidance” formore information on determininghow to manage PCB and asbestosmaterials.
contains a hazardous waste), is radioactive, or is anotherregulated type of debris (e.g., PCB, asbestos-containing). Ifdebris is not hazardous or radioactive waste, it generally can bemanaged as solid waste in accordance with generally much lessstringent State or local industrial waste, construction waste, orother non-hazardous waste requirements.
• The primary drivers for management of debris that is hazardousare the RCRA LDR requirements. These regulations providedebris-specific treatment requirements that apply whenhazardous debris is generated during a remediation action andland disposed.
• In several cases (such as when specified decontaminationapproaches are used for non-porous debris), once LDR treatmentstandards are met for hazardous debris, the debris is no longersubject to RCRA hazardous waste requirements.
• Debris that is contaminated with radioactive materials1 is subjectto DOE Orders for waste management. In addition, itsmanagement requirements are often determined by any healthand safety or worker or public dose requirements. Establishingthat debris is no longer radioactive waste requires a case-by-caseevaluation of the debris and its contaminants against a variety ofpolicies and procedures because a single, promulgated “belowregulatory concern” or “non-contaminated level” does not existfor radioactively contaminated materials.
• Mixed waste debris is subject to both the RCRA and radioactivewaste requirements. This may require compliance with both theLDR treatment requirements and consideration of radioactivewaste facility WAC.
• PCB and asbestos-containing materials are managed consistent
EH-413 June, 2000
Page 6-3
For definitions of listed andcharacteristic hazardous wastesand the contained-in policy, seeChapter 3 of this Guide:Characterization ofEnvironmental Restoration.
EPA has identified severalcommonly encountered types orcategories of debris. Theseinclude glass, metal, plasticrubber, brick, cloth, concrete,paper, pavement, rock, and wood.
Intact containers of hazardouswaste are not considered debrisand are regulated under 40 CFR261.7.
with other PCB and asbestos-containing wastes, namely inaccordance with TSCA requirements for what levels must beattained and how they must be disposed.
6.2 Concepts and Definitions
There are several key concepts and definitions critical to understandinghow to manage hazardous debris. The main regulatory drivers formanaging hazardous debris are the LDRs and the “contained-in” policyfor debris. The LDRs apply to debris that is contaminated with either alisted or characteristic hazardous waste. The LDR regulations for debrisbegin with the following definitions:
Debris means any solid material exceeding a 60 mm particle size that isintended for disposal and that is either a manufactured object, plant oranimal matter, or natural geologic material. A mixture of debris that hasnot been treated to the standards provided by 40 CFR 268.45 and thatcontains other material is subject to regulation as debris if the mixture iscomprised primarily of debris, by volume, based on visual inspection [40CFR 268.2(g)].
Hazardous debris means debris that contains a hazardous waste listed inSubpart D of Part 261, or that exhibits a characteristic of hazardouswaste identified in Subpart C of Part 261 [40 CFR 268.2(h)].
The following materials are specifically excluded from the definition ofdebris:
& Any material for which a specific treatment standard is providedin Subpart D of 40 CFR Part 268, namely lead acid batteries,cadmium batteries, and radioactive lead solids;
& Process residuals such as smelter slag and residues from thetreatment of waste, wastewater, sludges, or air emissionresidues; and
& Intact containers of hazardous waste that are not ruptured andthat retain at least 75% of their original volume.
6.3 Management Options for Hazardous Debris
Project managers have two available options for managing hazardousdebris when it is generated as environmental restoration waste and issubject to the RCRA LDR treatment standards: (1) treat the debris tomeet the LDR waste-specific treatment standards for the waste or wastescontaminating the debris, or (2) treat the debris using the appropriate
Debris Environmental Restoration Management Guide
Page 6-4
Waste-specific treatmentstandards are promulgated in 40CFR Parts 268.41 and 268.43.
alternative treatment standard promulgated at 40 CFR 268.45. Underthe second option, project managers also have a possibility of having thetreated debris no longer be considered hazardous waste subject to RCRASubtitle C standards as a result of the contained-in interpretation.
Treatment standards for each kind of debris (e.g., concrete, metal) andeach contaminant found in a mixture of debris types must be met unlessthe debris is converted into a treatment residue as a result of thetreatment process. Debris treatment residues are subject to the waste-specific treatment standards for the waste contaminating the debris. Forexample, any lead dust removed from concrete through scabbling must,in turn, be evaluated for RCRA compliance and managed in accordancewith the appropriate treatment standard for lead (not lead-contaminatedconcrete).
If reducing the particle size of the debris to meet the treatment standardsresults in material smaller than the 60 mm particle size limit for debris,this material is subject to the waste-specific treatment standards for thewaste contaminating the material, unless the debris has been cleaned andseparated from contaminated soil and waste prior to size reduction. At aminimum, simple physical or mechanical means must be used to providesuch cleaning and separation of non-debris materials to ensure that thedebris surface is free of caked soil, waste, or other non-debris material.
6.3.1 Option 1: Meet Waste-Specific Treatment Standards
The first option for managing hazardous debris is to treat the debris tomeet the existing LDR treatment standards for the waste or wastescontaminating the debris. These waste-specific treatment standards arepromulgated in 40 CFR §§268.41 and 268.43 for each hazardous waste.Debris may not be land disposed if the contaminant levels, for which ithas been treated, exceed these waste-specific standards.
This option may only be utilized for debris contaminated with a listedwaste. If this option is selected, the derived-from rule continues to applyto the debris (and any residues generated) after treatment. This meansthat debris contaminated with a listed waste would still carry the listedcode after treatment and thus would be subject to RCRA Subtitle Cregulations.
(Note: Debris contaminated by a characteristic waste must be treated tothe alternative treatment standards using one of the extraction,destruction, or immobilization technologies listed in Exhibit 6-2.)
6.3.2 Option 2: Meet Alternative Treatment Standards
EH-413 June, 2000
Page 6-5
Regulations for delistinghazardous debris after it has beentreated using an approvedextraction or destructiontreatment technology are codifiedin 40 CFR 261.3(f)(1).
The second option for managing hazardous debris is the use ofalternative treatment standards that EPA has promulgated at 40 CFR268.45. These treatment standards are an alternative to the waste-specific treatment standards promulgated in 40 CFR §§268.41 and268.43. EPA established these alternative treatment standards, whichare based on using specified technologies to meet existing waste-specificstandards, because it is often too difficult to get a representative sampleof debris for waste characterization.
Seventeen treatment technologies are BDAT for hazardous debris,falling into three general categories: extraction, destruction, andimmobilization.
& Extraction technologies are subdivided into three groups -physical, chemical, and thermal.
& Destruction technologies include biodegradation, chemicaloxidation, chemical reduction, and thermal destruction.
& Immobilization technologies include macroencapsulation,microencapsulation (stabilization), and sealing.
To ensure effective treatment of the debris, the treatment must beconducted in accordance with specified performance and/or design andoperating standards. The performance and/or design and operatingstandards must be met for all debris surfaces that are contaminated witha hazardous waste. The alternative treatment standards for hazardousdebris are outlined in Exhibit 6-2.
Under Option 2, most characteristic and/or listed hazardous debris canbe treated using specific treatment technologies. Debris that ishazardous because it exhibits an ICR characteristic (i.e., ignitability,corrosivity, or reactivity) must be treated to deactivate the characteristicusing one of the technologies identified in Exhibit 6-2. In actualpractice, this constraint may be of little concern because almost nodebris will be ignitable (because most ignitable wastes are liquids) andno debris will be corrosive (because corrosive wastes are either aqueousor liquid).
Debris that exhibits the characteristic of reactivity from the presence ofcyanide must be treated to the waste-specific cyanide standards in 40CFR 268.43. If debris is hazardous because it exhibits the characteristicof toxicity, the debris must be treated to meet the standards set forth inthe toxicity characteristic leaching procedure.
Debris contaminated with a listed hazardous waste that has not been
Required BDAT for treating hazardousdebris include: extraction, destruction andimmobilization.
Debris Environmental Restoration Management Guide
Page 6-6
treated to the waste-specific standards in either 40 CFR §§268.41 or268.43 must be treated using the alternative treatment standardsspecified in Exhibit 6-2. EPA has established that the alternativetreatment standards may be used, regardless of whether the listed wastehas concentration-based or specified-method treatment standards.
EH
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June
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es u
sing
sim
ple
phys
ical
or
mec
hani
cal m
eans
. Pri
or to
fur
ther
trea
tmen
t, su
ch r
esid
ue m
ust m
eet t
he w
aste
-spe
cifi
c tr
eatm
ent s
tand
ards
for
orga
nic
com
poun
ds in
the
was
te c
onta
min
atin
g de
bris
.
The
rmal
des
orpt
ion:
All
debr
is:
Sam
e as
abo
ve; a
nd m
ust o
btai
n an
“E
quiv
alen
t Tec
hnol
ogy”
appr
oval
und
er §
268.
42(b
).
Bri
ck, c
loth
, con
cret
e, p
aper
, pav
emen
t , r
ock,
woo
d: D
ebri
s m
ust b
e no
mor
e th
an 1
0 cm
in o
ne d
imen
sion
, exc
ept t
hat t
his
thic
knes
s li
mit
may
be
wai
ved
unde
r an
“E
quiv
alen
t Tec
hnol
ogy”
app
rova
l und
er §
268.
42(b
).
Hig
h-te
mpe
ratu
re m
etal
s re
cove
ry:
Deb
ris
cont
amin
ated
with
a d
ioxi
n-lis
ted
was
te:
Obt
ain
an “
Equ
ival
ent T
echn
olog
y”ap
prov
al u
nder
§26
8.42
(b).
The
rmal
des
orpt
ion:
All
debr
is:
Met
als
othe
r th
an m
ercu
ry.
Deb
risE
nviro
nmen
tal R
esto
ratio
n M
anag
emen
t Gui
de
Tec
hnol
ogy
Per
form
ance
and
/or
Des
ign
and
Ope
rati
ng S
tand
ard
Con
tam
inan
t R
estr
icti
ons
P
age
6-8
DE
STR
UC
TIO
N T
EC
HN
OL
OG
IES
Bio
logi
cal D
estr
uctio
n: in
clud
esbi
odeg
rada
tion
onl
y.A
ll de
bris
: O
btai
n an
“E
quiv
alen
t Tec
hnol
ogy”
app
rova
l und
er §
268.
42(b
);tr
eate
d de
bris
mus
t be
sepa
rate
d fr
om tr
eatm
ent r
esid
ues
usin
g si
mpl
eph
ysic
al o
r m
echa
nica
l mea
ns, a
nd, p
rior
to f
urth
er tr
eatm
ent,
such
res
idue
mus
t mee
t the
was
te-s
peci
fic
trea
tmen
t sta
ndar
ds f
or o
rgan
ic c
ompo
unds
inth
e w
aste
con
tam
inat
ing
debr
is.
Bri
ck, c
loth
, con
cret
e, p
aper
, pav
emen
t , r
ock,
woo
d: D
ebri
s m
ust b
e no
mor
e th
at 1
.2 c
m in
one
dim
ensi
on, e
xcep
t tha
t thi
s th
ickn
ess
lim
it m
ay b
ew
aive
d un
der
an “
Equ
ival
ent T
echn
olog
y” a
ppro
val u
nder
§26
8.42
(b).
All
debr
is:
Met
al c
onta
min
ants
.
Che
mic
al D
estr
uctio
n: in
clud
es c
hem
ical
oxid
atio
n an
d ch
emic
al r
educ
tion
.S
ame
as a
bove
.S
ame
as a
bove
.
The
rmal
Des
truc
tion
Tre
ated
deb
ris
mus
t be
sepa
rate
d fr
om tr
eatm
ent r
esid
ues
usin
g si
mpl
eph
ysic
al o
r m
echa
nica
l mea
ns, a
nd, p
rior
to f
urth
er tr
eatm
ent,
such
res
idue
mus
t mee
t the
was
te-s
peci
fic
trea
tmen
t sta
ndar
ds f
or o
rgan
ic c
ompo
unds
inth
e w
aste
con
tam
inat
ing
debr
is.
Bri
ck, c
oncr
ete,
gla
ss, m
etal
, pav
emen
t,ro
ck:
Met
als
othe
r th
an m
ercu
ry, e
xcep
t tha
tth
ere
are
no m
etal
res
tric
tion
s fo
r vi
trif
icat
ion.
Deb
ris
cont
amin
ated
with
dio
xin-
liste
dw
aste
: O
btai
n an
“E
quiv
alen
t Tec
hnol
ogy”
appr
oval
und
er §
268.
42(b
), e
xcep
t tha
t thi
sre
quir
emen
t doe
s no
t app
ly to
vit
rifi
cati
on.
I MM
OB
ILIZ
AT
ION
TE
CH
NO
LO
GIE
S
Mac
roen
caps
ulat
ion
Enc
apsu
latin
g m
ater
ial m
ust c
ompl
etel
y en
caps
ulat
e de
bris
and
be
resi
stan
t to
degr
adat
ion
by th
e de
bris
, its
con
tam
inan
ts, a
nd m
ater
ials
into
whi
ch it
may
com
e in
to c
onta
ct a
fter
pla
cem
ent.
Non
e.
Mic
roen
caps
ulat
ion
Lea
chab
ility
of
the
haza
rdou
s co
ntam
inan
ts m
ust b
e re
duce
d.N
one.
Seal
ing
Seal
ing
mus
t avo
id e
xpos
ure
of th
e de
bris
sur
face
to p
oten
tial
leac
hing
med
ia, a
nd s
eala
nt m
ust b
e re
sist
ant t
o de
grad
atio
n by
the
debr
is, i
tsco
ntam
inan
ts, a
nd m
ater
ials
wit
h w
hich
it m
ay c
ome
into
con
tact
aft
erpl
acem
ent.
Non
e.
EH-413 June, 2000
Page 6-9
Regulations for equivalencydemonstrations are codified in 40CFR 268.42(b).
Debris that is contaminated with two or more hazardous contaminantsmust be treated for each contaminant using one or more of the treatmenttechnologies identified in Exhibit 6-2. If an immobilization technologyis used in a treatment train, it must be the last treatment technology used.
The alternative treatment standards presented in Exhibit 6-2 must beachieved for each type of debris contained in a mixture of debris types. Again, if an immobilization technology is used in a treatment train, itmust be the last treatment technology used.
Mixtures containing more than one type of debris, or more than onecontaminant, must be treated to meet the standards for each contaminantand each type of debris. If a single technology is not appropriate for allcontaminants and debris types present in the mixture, a sequentialtreatment train must be used. If an immobilization technology is used inthe treatment train, it must be the last treatment technology used.
The LDR regulations prohibit the use of some technologies to treatspecific types of contaminants. Generators and treaters of hazardousdebris may select any treatment technology in Exhibit 6-2 that is notrestricted for the contaminant subject to treatment, as indicated in thethird column of the exhibit.
In some cases, EPA was not able to establish performance and/or designand operating requirements for a particular extraction or destructiontechnology listed in Exhibit 6-2 that would be entirely protective ofhuman health and the environment. This subject became a particularpoint of concern because it meant that treated debris may no longer begoverned by Subtitle C controls. In such cases, the alternative treatmentstandards require the owner or operator of the treatment unit to make an“equivalency demonstration.” To fulfill these requirements, the facilityoperator must:
1. Document that the technology being used treats thecontaminants to a level equivalent to the other technologiesspecified in Exhibit 6-2, and
2. Show that residual levels of hazardous contaminants may notpose a hazard to human health and the environment, absentRCRA Subtitle C regulatory control.
Generators and treatment facility operators can also attempt to make asimilar demonstration for an alternative treatment technology not listedin Exhibit 6-2. If the generator or treater shows the alternativetechnology performs as well as the technology specified in Exhibit 6-2, EPA or an authorized state can approve use of the alternate technology.
Debris Environmental Restoration Management Guide
Page 6-10
An extensive definition of “cleandebris surface” can be found in40 CFR 268.45.
After the hazardous debris has been treated, it may be land disposed. Ifthe debris is treated using an approved extraction or destructiontechnology, it will not have to be managed as a hazardous waste and,therefore, may be disposed of in a Subtitle D (solid waste) facility. However, hazardous debris contaminated with a listed waste that istreated with an immobilization technology must be disposed of in aSubtitle C (hazardous waste) facility. This debris is not excluded fromSubtitle C regulation because contaminants are not removed or destroyedduring immobilization; they are simply contained indefinitely.
6.3.3 Treatment Residues
Residues from the treatment of hazardous debris (e.g., dusts, materialsextracted from debris) must be separated from the debris using simplephysical or mechanical means. The separation process does not need toproduce a “clean debris surface.” The debris surface must only be freeof caked residues or non-debris material, such as soil or waste. Theseresidues are then subject to the waste-specific treatment standards for thewaste contaminating the debris.
The residues from treated debris contaminated with listed hazardouswastes remain hazardous unless they are delisted via a site-specificdelisting petition. If the residues are not separated from the treateddebris, the debris remains a hazardous waste and must be disposed of ina Subtitle C (hazardous waste) facility.
The LDR regulations for hazardous debris include special requirementsfor three types of treatment residues:
1. Residues from the treatment of ignitable, corrosive, or reactivecharacteristic debris, not contaminated with a prohibited listedhazardous waste, cyanide, or a toxic constituent, must bedeactivated prior to land disposal.
2. Residues from the treatment of debris that is reactive because ofcyanide must meet the treatment standards for D003 reactivecyanide waste promulgated in 40 CFR 268.43.
3. Ignitable non-wastewater residues containing > 10% totalorganic content (TOC) are subject to the technology-basedstandards for D001 wastes. In other words, ignitable residuesmust be treated to recover organic constituents, incinerated,substituted for fuel in a boiler or industrial furnace, or treated bynon-combustive high-temperature organic destruction.
LDR regulations for hazardous debrisinclude requirements for non-hazardousresidues from ignitable, corrosive orreactive characteristic debris, residuefrom debris that is reactive due tocontact with cyanide, and ignitable non-waste water residues containing lessthan or equal to 10% total organiccontent (TOC).
EH-413 June, 2000
Page 6-11
In some cases, treatmentconducted in tanks may beeligible for the wastewatertreatment unit exemption codifiedin §§264.1(g)(6), 265.1(c)(10), and270.1(c)(2)(v).
If the storage conditions of 40CFR 262.34 are met, the wastemay be accumulated for up to 90days without a permit.
6.3.4 Facility Standards Applicable During Hazardous DebrisTreatment
Treatment of hazardous debris (other than in 90-day accumulation units)is currently subject to the applicable interim status and permit standardsof 40 CFR Parts 264, 265, 266, and 270. Existing facility standards thatare likely to apply to common debris treatment options are:
1. Debris treatment conducted in tanks, such as high-pressuresteam and water spraying, chemical extraction, andbiodegradation, is subject to the tank standards in Subpart J of40 CFR Parts 264 and 265.
2. Debris treatment conducted in incinerators is subject to SubpartO of 40 CFR Parts 264 and 265.
3. Debris treatment conducted in high temperature metals recovery(HTMR) furnaces is conditionally exempt from the Boiler andIndustrial Furnace (BIF) regulations in 40 CFR Part 266,Subpart H.
4. Debris treatment conducted in thermal desorbers and thermaldestruction units is subject to either the incinerator standards (40CFR Parts 264 and 265, Subpart O) or the thermal treatmentstandards (40 CFR Part 264, Subpart X or Part 265, Subpart P).
EPA has also established its position on permit requirements duringdecontamination of a building prior to demolition, and on the holding ofremoved contaminants within the building. This situation arises whenphysical extraction technologies are used to treat debris in place. EPAruled that an intact building that is scheduled to be discarded istechnically not yet a solid waste, and therefore, physical extraction ofcontaminants would not constitute hazardous waste treatment.
Where hazardous debris treatment does require a permit, temporaryauthorizations can be obtained to conduct short-term treatment or storageactivities. EPA may grant temporary authorizations, for up to 180 days,that may be renewed once. To obtain a temporary authorization, facilityowners or operators must demonstrate compliance with the applicable 40CFR Part 264 standards and must specifically meet the criteria of 40CFR 270.42(e).
6.4 Management of Radioactive, Mixed Waste, and Other Typesof Debris
Five types of debris may pose unique regulatory concerns: asbestos
Debris Environmental Restoration Management Guide
Page 6-12
See Regulatory RequirementsAffecting Disposal of Asbestos-Containing Waste, EH-413-062/1195, November 1995, foundat: [http://www.eh.doe.gov/oepa/under “Policy and Guidance”].
A discussion on EPA’s inherentlyhazardous debris rule and how itrelates to scrap metal, can befound in 57 FR 37237 (August1992).
See http://www.eh.doe.gov/oepa/“Policy and Guidance” forinformation briefs sheets onmanaging PCBs.
DOE Order 5820.2A forRadioactive Waste Managementis replaced by DOE Order 435.1.[http://www.explorer.doe.gov:1776/htmls/currentdir.html].
debris, inherently hazardous debris, PCB-contaminated debris,radioactive debris, and mixed waste debris. The regulations applicableto these unique types of debris are summarized below.
6.4.1 Asbestos Debris
The treatment standards for hazardous debris also apply to asbestosdebris. EPA acknowledges that many of the treatment technologiesidentified in Exhibit 6-2 are not practical for treating asbestos debrisbecause workers may be exposed to the asbestos particles or becauseasbestos may be released to the environment. However, EPA believesthat several of these treatment technologies can be used to treat asbestos-containing debris in compliance with applicable Occupational Safety andHealth Administration (OSHA), National Emission Standards forHazardous Air Pollutants (NESHAP), and TSCA standards if filtrationdevices are used to control air and water emissions.
6.4.2 Inherently Hazardous Debris
Inherently hazardous debris is debris that, even after decontamination,fails the TCLP because of inherent metal content (e.g., lead pipes). OnJanuary 9, 1992, EPA proposed that debris fabricated from D004-D011metals that exhibits both the TCLP and Extraction Procedures (EP)toxicity characteristics as fabricated should either be immobilized,disposed of in a hazardous waste landfill, or recycled (e.g., as scrapmetal). If the inherently contaminated debris also contains othercontaminants subject to treatment, it must be treated for thosecontaminants first (prior to being immobilized or recycled).
6.4.3 PCB-Contaminated Debris
PCB-contaminated debris is already subject to decontamination and/ordisposal requirements promulgated under TSCA and codified in 40 CFR§§761.60 and 761.125. Hazardous debris that is also a PCB waste issubject to both RCRA and TSCA regulations. Persons treating ordisposing of these wastes must satisfy those requirements which aremore stringent.
6.4.4 Radioactive Debris Requirements
Debris that is contaminated solely with radionuclides must be managedas radioactive waste in accordance with the Atomic Energy Act of 1954,as amended and DOE Orders for Radioactive Waste Management (i.e.,DOE O 435.1 and DOE M 435.1-1). For project managers ofenvironmental projects that generate radioactively contaminated debris,
EH-413 June, 2000
Page 6-13
See Waste Acceptance Criteriafor the Waste Isolation PilotPlant, April 1996 (DOE/WIPP-069, Revision 5 Chg. 2December 1996).
Facility decommissioning isconsidered a CERCLA non-timecritical removal action under a1995 EPA/DOE memorandum ofUnderstanding. Debris iscommonly generated as part ofdecommissioning actions.
Debris contaminated with one ofthese four categories of mixedwaste does not meet the definitionof debris and are thereforesubject to the waste-specifictreatment standards.
the waste acceptance criteria, waste characterization, certification andtransfer requirements of a facility to which debris will be sent forstorage, treatment, or disposal often determine the specificconsiderations that must be a part of project planning.
According to DOE M 435.1, waste acceptance criteria must specifyallowable activities or concentrations of specific radionuclides,package requirements, and any applicable restrictions that wouldimpact waste handlers or compromise facility or package performance,among others. Sections III and IV (G)(1)(b&c) of DOE Order M435.1-1 provide a full listing of the elements that must be specified forwaste acceptance criteria for TRU and LLW facilities.
A final consideration when considering radioactive debris requirementswill be health and safety restrictions that, in turn, determine howradioactive wastes such as debris must be handled. For example, asoutlined in the DOE Standard 1120-98, Integration of Environment,Safety, and Health into Facility Disposition Activities, projects includingradioactive materials may trigger key nuclear safety and hazard analysisfor all aspects of planned work and waste management.
6.4.5 Mixed Waste Debris Requirements
Mixed wastes are those wastes that have both radioactive and hazardouscomponents. The radioactive components of the waste are regulatedunder the Atomic Energy Act (AEA) of 1954, as amended, while thehazardous components are regulated under RCRA. These wastes poseparticular problems under the RCRA program because few commercialfacilities are permitted to accept mixed waste. Safety and healthconcerns associated with radioactive components also rule out manyconventional hazardous waste management techniques.
On June 1, 1990, EPA promulgated treatment standards for foursubcategories of mixed waste under 55 FR 22520 :
& Specific high-level wastes,
& D008 radioactive lead solids,
& Mixed wastes containing elemental mercury, and
& Mercury-containing hydraulic oil contaminated with radioactivematerials.
EPA also asserted that “all promulgated treatment standards for RCRA
For more information on treatmentstandards for various categories of mixedwaste, refer to 55 FR 22520, June 1990.
Waste acceptance criteria for TRUand LLW facilities are outlined inSections III and IV (G)(b&c) ofDOE Order M 435.1-1. Wastecharacterization, certification andtransfer requirements are outlinedin Sections III and IV (I, J & K) ofDOE Order M 435.1-1.
Debris Environmental Restoration Management Guide
2 See note on page 6-2.
Page 6-14
Treatment by immobilizationdoes not exempt debris fromSubtitle C regulation.
More information on thesepolicies and procedures may befound in Draft Handbook forControlling Release for Reuse andRecycling of Non-Real PropertyContaining Residual RadioactiveMaterial, June 1997, [http://www.eh.doe.gov/oepa/under “Policy and Guidance”].
Many of these requirements arecontained in draft regulations, 10CFR 834, which, whenpromulgated, will codify many ofthe current policies in DOEOrder 5400.5.
listed and characteristic wastes apply to the RCRA hazardous portion ofmixed radioactive (high-level, transuranic, and low-level) wastes, unlessEPA has specifically established a treatability group for that specificcategory of mixed waste.” (55 FR 22520, June 1990).
Although hazardous debris that is, or contains, mixed waste is subject tothe debris treatment standards, the definition of debris specificallyexcludes any material for which a specific treatment standard is providedin 40 CFR Part 268, Subpart D. Therefore, wastes in the four mixedwaste subcategories mentioned in the previous paragraph do not meetthe definition of debris, and as such, the waste-specific standards forhazardous and radioactive constituents apply.
6.5 Exemptions For Managing Debris2
Depending on the technology used to remove hazardous contaminantsfrom certain waste materials and whether allowable radionuclide releaselimits have been established for materials managed at radioactive wastefacilities, debris that is generated or collected during environmentalrestoration activities may be exempted from treatment as either ahazardous or radioactive substance. The demonstrations that must bemet to earn such exemptions are listed below.
6.5.1 Hazardous Waste
In addition to setting treatment standards, the LDR regulations addressthe issue of when treated debris is a hazardous waste and when it is not. Debris may be excluded from Subtitle C regulations in two ways. First,the debris may be excluded if it is treated to meet the alternativetreatment standards for debris by using an extraction or destructiontechnology listed in Exhibit 6-2 and if the treated debris does not exhibita hazardous characteristic [see 40 CFR 261.3(f)(1)]. Treatment using animmobilization technology does not qualify a listed debris for exclusionbecause the contaminants are not removed or destroyed; they are simplycontained indefinitely.
Second, debris contaminated with a listed hazardous waste can beexcluded from Subtitle C regulation via a case-by-case basisdetermination by EPA that the debris no longer contains hazardouswaste at significant levels [see 40 CFR 261.3(f)(2)]. Untreated debrisand debris treated by a technology other than an extraction ordestruction technology can be excluded in this manner. Thisdetermination will be made by EPA or authorized State. This approach,
EH-413 June, 2000
3 See note on page 6-2.
Page 6-15
in effect, codifies the Agency’s “contained-in” policy as it relates tohazardous wastes that are contained in or mixed with debris.
6.5.2 Exemptions From Managing Debris as Radioactive Waste3
Debris is classified as a type of non-real property (as opposed to realproperty, such as land). Neither DOE or the Nuclear RegulatoryCommission (NRC) have a single process to exclude radioactivelycontaminated non-real property from regulation as radioactive wastes. Previous attempts to establish “below regulatory concern” levels by theNRC were not successful. Therefore, DOE relies on both DOE Order5400.5 (Radiation Protection of the Public and the Environment) and itsimplementing policy and guidance to establish processes and limitsunder which non-real property may be released for reuse or recycling.
In general, existing policy establishes 10 steps for evaluating whethermaterials can be released: (1) characterize and describe the non-realproperty proposed for release; (2) do release limits exist? (3) definerelease limits needed; (4) develop release limits; (5) compile and submitapplication for DOE Field Office approval; (6) document approvedlimits in public record; (7) implement approved limits; (8) conductsurvey measurements; (9) does property meet limits? (10) releaseproperty.
Further, the guidance outlines that release limits are based onimplementing an ALARA (as low as reasonably achievable) process,under which DOE considers alternatives involving different managementapproaches, developing dose calculations for maximally exposedindividuals, and focusing on actual and likely use as well as worstplausible use.
In addition, as shown in Exhibit 6-3, DOE has put forth guidance thatoutlines surface activity guidelines, describing the allowable totalresidual surface activity in order to release non-real property.
Additional information on the use ofALARA principles is contained inSection IV (P)(2) of DOE Order M435.1-1.
Debris Environmental Restoration Management Guide
Page 6-16
Exhibit 6-3: Surface Activity GuidelinesAllowable Total Residual Surface Activity (dpm/100 cm2)2
Source: Response to Questions and Clarification of Requirements and Processes: DOR 5400.5, Section II.5 andChapter IV Implementation Requirements Related to Residual Radioactive Material, November 17, 1995
Radionuclides3 Average4/5 Maximum6/7 Removable7
Group 1 - Transuranics, 1-125, I-129, Ac-227, Ra-226, Ra-228, The-228,Th230, Pa-231
100 300 20
Group 2 - The-natural, Sr-90, I-126, I-131, I-133, Ra-223, Ra-224, U-232,The-232
1,000 3,000 200
Group 3 - U-natural, U-235, U-238, and associated decay products, alphaemitters
5,000 15,000 1,000
Group 4 - Beta-gamma emitters (radionuclides with decay modes otherthan alpha emission or spontaneous8 fission)
5,000 15,000 1,000
Tritium (applicable to surface and subsurface)9 N/A N/A 10,000
2As used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material asdetermined by counts per minute measured by an appropriate detector for background, efficiency, and geometricfactors associated with the instrumentation.3 Where surface contamination by both alpha- and beta-gamma-emitting radionuclides exists, the limits establishedfor alpha- and beta-gamma-emitting radionuclides should apply independently.4 Measurements of average contamination should not be averaged over an area of more than 1 m2. For objects ofsmaller surface area, the average should be derived for each such object.5 The average and maximum dose rates associated with surface contamination resulting from beta-gamma emittersshould not exceed 0.2 mrad/h and 1.0 mrad/h, respectively, at 1 cm.6 The maximum contamination level applies to an area of not more than 100 cm2.7 The amount of removable material per 100 cm2 of surface area should be determined by wiping an area of that sizewith dry filter or soft absorbent paper, applying moderate pressure, and measuring the amount of radioactivematerial on the wiping with appropriate instrument of known efficiency. When removable contamination on objectsof surface area less than 100 cm2 is determined, the activity per unit area should be based on the actual area and theentire surface should be wiped. it is not necessary to use wiping techniques to measure removable contaminationlevels if direct scan surveys indicate that the total residual surface contamination levels are within the limits forremovable contamination.8 This category of radionuclides includes mixed fission products, including the Sr-90 which is present in them. Itdoes not apply to Sr-90 which has been separated from the other fission products or mixtures where the Sr-90 hasbeen enriched.9 Property recently exposed or decontaminated, should have measurements (smears) at regular time intervals toensure that there is not a build-up of contamination over time. Because tritium typically penetrates material itcontacts, the surface guidelines group 4 are not applicable to tritium. The Department has reviewed the analysisconducted by the DOE Tritium Surface Contamination Limit Committee (“Recommended Tritium SurfaceContamination Release Guides,” February 1991), and has assessed potential doses associated with the release ofproperty containing residual tritium. The Department recommends the use of the stated guideline as an interimvalue for removable tritium. Measurements demonstrating compliance of the removable fraction of tritium onsurfaces with this guideline are acceptable to ensure that non-removable fractions and residual tritium in mass willnot cause exposures that exceed DOE dose limits and constraints.
