When it comes to managing removal of non-haz oil contaminated soil, gasoline contaminated soil, contaminated historic fill, and other types of non-haz petroleum contaminated soils, remediation firms have access to a variety of recycling methods which include, Asphalt Batching, Thermal Desorption, Soil Blending, and Bioremediation.
Contaminated soil recycling may often be the most cost effective T&D option for fuel oil contaminated soil and other categories of petroleum contaminated soils, but in many cases, low cost beneficial reuse may be suitable as a lower cost alternative if the contaminant concentration levels meet the acceptance criteria at the reuse facilities.
What are the most common methods for offsite disposal of Hazardous and Non-Hazardous contaminated soils, and how do they compare in cost?
Contaminated soil remediation costs can often be minimized by utilizing offsite Transportation & Disposal. The disposal options for non-hazardous contaminated soils include the following methods, listed by order of most costly to least costly: Sub-title D Landfill Disposal, Reuse as Landfill Cover, Soil Recycling, and Beneficial Re-use.
The disposal options for RCRA Hazardous contaminated soils include: Sub-title C Landfill Disposal, Incineration, Pozzalonic Treatment, Chemical Oxidation, and Bioremediation. Costs for each category will vary depending upon the contaminant type and concentration levels.
Soils are classified as RCRA Hazardous if they have been directly impacted by a listed hazardous waste, or if they exhibit one or more of the following characteristics: ignitability (flash point), corrosivity (pH)
, reactivity (cyanide/sulfide), or toxicity (TCLP).
Fuel oil contaminated soil and other petroleum contaminated soil categories are typically classified as non-hazardous, since they rarely exceed the TCLP limits, and typically do not contain listed hazardous compounds.
During the past three decades, the southern New York, New Jersey, eastern Pennsylvania corridor has become a mecca for contaminated soil related activities, where well established industry standards have evolved to include a number of non-hazardous soil disposal
categories including: Reuse as New Jersey Residential, Reuse as New Jersey Non-Residential, Reuse as New York Part 375, Reuse as Pennsylvania Clean Fill, Reuse as Pennsylvania Regulated Fill, Reuse as Landfill Cover, Recycling as ID-27, and Sub-Title D Landfill Disposal of Residual Waste.
Contaminated soil remediation costs can vary widely, and as such it is the role of the remediation company to navigate the maze of available disposal facility options, with the goal of identifying the compliant T&D options that are most cost effective, given the specifics of any project.
This requires expertise in interpreting analytical data, as well as a comprehensive understanding of the varying acceptance criteria that apply at disposal facilities located within closest proximity to the job site.
This process begins with determining soil waste classification and subsequent targeting of best-case disposal options, based upon evaluating a set of project-specific factors that include: site location, contaminants detected, contaminant concentrations, volume, geotechnical characteristics, site history, debris, gradation size, odor, and moisture content.
When managing contaminated soil disposal, the dual mission is to ensure regulatory compliance, along with achieving cost minimization – in which there exists one singular best-available comprehensive solution that can be identified for any given project.
Historic fill defined as non-indigenous material that includes soil, construction & demolition (C&D) debris, dredge spoils, incinerator residue, fly ash, or non-hazardous solid waste. This category of material disposal is prevalent throughout the northeastern United States, and may often be suitable for soil recycling or low cost reuse when meeting the acceptance criteria at the facilities.
Environmental remediation at commercial properties may be required when soil or historic fill is contaminated with Petroleum Hydrocarbons (TPH/EPH), Toxic Metals, PCB’s, Solvents, Herbicides, Pesticides, Coal Tar, Industrial Chemicals, Asbestos, Ash and Debris.
Soil remediation companies will routinely conduct onsite soil sampling services and subsequent interpretation of the analytical data to determine the best case disposal options given the specifics of each project.
In general, the greater the tonnage of contaminated soil or historic fill at a commercial or industrial property, the higher the likelihood that more than one category of soil classification will be identified. This may necessitate the need for the remediation contractor to target more than one disposal facility option in order to minimize soil transportation & disposal (T&D) costs.
Yes, especially in cases where larger volumes of contaminated soil are present, onsite treatment may be a cost effective alternative to offsite trucking & disposal. The most prevalent onsite treatment categories include, thermal oxidation of solvent contaminated soils, pozzolanic treatment of metals contaminated soils, proprietary reagent treatment of metals contaminated soils, and bioremediation of VOC contaminated soils.
Onsite soil treatment may also be a cost effective option for petroleum contaminated soils, as well as soils containing PCB’s at high concentrations.
The sequence of events for contaminated soil management begins with, 1) sampling and analysis for waste classification to satisfy a set of specific testing requirements; 2) evaluation of the soil waste classification data and other site specific conditions to determine best case disposal facility selection; 3) completion of the profile documents specific to the targeted disposal facility or facilities; 4) obtaining facility approval(s); 5) generating truck manifests for the project; 6) scheduling of the load out; 7) upon completion, the soil remediation companies will forward copies of fully executed truck manifests and weight tickets to the client.
Lead contaminated soil is defined by the EPA as RCRA hazardous when TCLP-Lead is detected in concentrations greater than or equal to 5 mg/L, in which case the soil would carry a D008 RCRA waste code. Lead contaminated soils containing TCLP-Lead at concentrations less than 5 mg/L are classified as non-hazardous if they contain no other Underlying Hazardous Constituents.
Under EPA’s RCRA law, if there is a known or documented source of release of a listed
hazardous compound detected in soil at any concentration – for example, from a leaking tank, or leaking drums of stored solvent, or from a known surface spill – then any of these conditions would cause the soil to be classified as a listed hazardous waste.
If the source of release is unknown but the soil fails the TCLP, then it would be classified as a characteristically hazardous waste.
Such soils can also carry a combination RCRA waste code, such as F002/D039 when classified as both listed hazardous as well as characteristically hazardous.
Soils generated at dry cleaner properties may contain the cleaning solvent, Perchloroethylene, aka Tetrachloroethylene, Perc, or PCE. These soils are classified as listed hazardous when the following two conditions are met: 1) there is a known or documented source of release of PCE, and, 2) PCE has been detected in any concentration, via Totals (dry weight) analysis.
Soils are classified as characteristically hazardous when PCE is detected at concentrations greater than or equal to 0.7 mg/L via TCLP (leachate) analysis.
Dry cleaner contaminated soils can also carry a combination RCRA waste code, such as F002/D039 when classified as both listed hazardous as well as characteristically hazardous.
Such soils are classified as non-hazardous when there is no KNOWN source of a PCE release or spill, and also no TCLP-PCE detections greater than or equal to 0.7 mg/L.
Similar to dry cleaner soils, pesticide contaminated soils are classified as listed hazardous when a listed hazardous pesticide compound such as Chlordane, Heptachlor, Lindane, Methoxychlor or Toxaphene is detected in any concentration, via Totals (dry weight) analysis.
Pesticide contaminated soils are classified as characteristically hazardous when a pesticide is detected at concentrations greater than or equal to its respective RCRA limit, via TCLP analysis.
Pesticide contaminated soils can also carry a combination RCRA waste code, such as U036/D039 when classified as both listed hazardous as well as characteristically hazardous.
Such soils are classified as non-hazardous when there is no KNOWN source of a pesticide release or spill (excluding pesticide detections resulting from normal spraying applications), and also no TCLP PCE detections greater than or equal to 0.7 mg/L.
Perfluoroalkyl and polyfluoroalkyl substances (PFAS) are a group of man-made compounds including, PFOA, PFOS, GenX, and other chemicals. PFAS are found in a wide range of consumer products such as cookware, pizza boxes and stain repellents. Certain PFAS can accumulate and remain in the human body for long periods of time, and there is evidence that exposure to PFAS can adversely affect human health, according to the EPA.
PFAS contaminated soil remediation guidelines are expected to be issued in the near future by the various regulatory agencies.