By: Amy Bauer
As the part of the compliance and auditing service line for EHS Support, a full-service environmental, health, safety, and security (EHS&S) consulting firm, we handle issues with the management of investigation derived waste (IDW) for our clients. In addition, we also answer questions for our field personnel and managers working on investigation and remediation projects. Managing IDW requires careful planning, communication, and training prior to mobilization of field activities. On behalf of our clients and colleagues, we often need to answer questions such as, “What are the potential characteristics of the waste to be generated,” and, “How will the waste be managed once it is removed from the ground?”
Let us begin with the most important question: What is IDW? Field investigation activities (e.g., remedial investigation/feasibility studies and remedial designs) could result in the generation of waste materials that may pose a risk to human health and the environment. These IDW can include:
- Drilling muds, cuttings, and purge water from test pit and well installation
- Purge water, soil, and other materials from collection of samples
- Residues (e.g., ash, spent carbon, well development purge water) from testing of treatment technologies and pump and treat systems
- Contaminated personal protective equipment (PPE)
- Solutions (aqueous or otherwise) used to decontaminate non-disposable protective clothing and equipment.
Once we determine IDW will be generated from the field activity, we need to understand the following information prior to commencing field work.
- Is the IDW anticipated to be hazardous based on chemicals released and historical analytical testing? Is additional testing needed?
- Is the IDW anticipated to contain a listed or characteristic waste?
- What are the potential management and disposal options? Can it potentially be disposed of onsite?
- What are the client-approved management and disposal options for the IDW? Do we need to seek approval for an alternative treatment, storage, or disposal facility?
- How will the waste be stored and transported for offsite disposal? Will the containers be protected from the weather and are suitable materials available in case of a spill?
- If containerized IDW will be temporarily stored at the site, have facility personnel been alerted?
- Will field personnel have adequate numbers and types of containers and labels? Will there be a secure location for temporary storage/accumulation of the wastes? If the waste will not be transferred to different containers for shipment, are the containers approved by Department of Transportation (DOT) for transportation?
- When waste is picked up for transportation offsite, who will be there prior to pick up to ensure the waste is properly prepared for shipment (i.e., packaging, labeling, marking, placarding)? Who will sign the manifest?
Further consideration must be given to compliance with internal and client EHS&S programs, procedures, and plans; segregation of waste; inclusion of IDW in the investigation and remediation work plan; and if necessary, obtaining permission from the facility, client, and regulatory agency for management and disposal options.
Amy. Bauer has 15 years of experience conducting and managing environmental site assessments, regulatory compliance audits, environmental investigations, and regulatory compliance support…. Read More