Proper Waste Characterization Tips; Common Pitfalls for Soil Recycling

Waste comes in many forms, one being contaminated soil. To help navigate the soil disposal process, a site generating this waste may use a disposal and recycling company’s waste characterization services to accurately characterize each of its waste streams.

Understanding the basic waste characterization principles is key to ensuring a vendor is providing the services needed while remaining in full compliance. Even with the help of a vendor, the waste generator is solely responsible for proper characterization, handling, and recycling or disposal. For this reason, it’s critical to determine the correct waste disposal or recycling option to then choose the best site or facility for the waste stream.

Determining the Correct Waste Disposal or Recycling Option

In order to identify waste disposal and recycling options for contaminated soil, generators and their dedicated partner should review historical data as well as site history and the type of contamination. From here, multiple facilities are often selected for potential approvals.

There are a few key contaminants that should be considered to determine if the material is a good candidate for soil recycling such as heavy metals, Polychlorinated Biphenyls (PCBs), PolyAromatic Hydrocarbons (PAHs) and Total Petroleum Hydrocarbons (TPH). Also, consider if the project falls under the federal Superfund program or if the site is overseen by a state environmental agency to determine if recycling or direct beneficial use is an option.

Generally, hazardous waste soil can go only to Resource, Conservation and Recovery Act (RCRA) Treatment, Storage and Disposal Facilities (TSDFs) except Manufactured Gas Plant (MGP) waste:

• MGP soil with Toxicity Characteristic Leaching Procedure (TCLP) Benzene >0.5 mg/l can go to Pennsylvania thermal soil recycling facilities, if none of the metals exceed TCLP limits. Total Petroleum Hydrocarbons (TPH) must also be within the facility permit limits.
• Facilities in Delaware cannot accept TCLP Benzene >0.5 mg/l because Delaware does not recognize the MGP TCLP exemption.

When deciding between disposing or recycling contaminated soil, additional factors to keep in mind include debris, moisture, odors, ash/cinders, geotechnical characteristics and the origin of contamination.

Comparing Beneficial Use and Fixed-Treatment facilities

Beneficial use (BU) sites are typically a less expensive option to recycle soil but can only accept non-hazardous materials. BU sites typically receive material with low-level contamination or soil meeting state residential criteria.

BU sites often have strict geotechnical specifications, limiting debris, clay, topsoil and organic matter from being included in the material. As they are outdoor operations, BU sites have limited hours for receiving, and are susceptible to impacts of weather events.

Each BU site has its own unique site-specific Material Acceptance Protocol (MAP) or acceptance analytical requirements. To expedite shipments to BU sites, it is important to have a clear understanding of the sampling requirements, including frequency and sample types. You should also:

• Understand that EnCore cartridges (or similar) are required for VOC sampling at all BU sites.
• Consider historical site investigations, Phase II reports, geotechnical data and soil boring logs.
• Provide a geotechnical sample (if required). In some cases, the engineer for the beneficial use site may require a site visit prior to issuing an approval.
• Note that BU sites require delineation of adjacent material exceeding the site acceptance limits.
• Submit a complete application, sampling maps, sampling descriptions, laboratory reports and historical site investigation reports. Often, spreadsheets comparing site results to BU criteria are required.

At fixed-treatment facilities, the price varies based on the processing required. The level of contamination a facility can receive varies from facility to facility and is typically a higher cost than BU sites due to the required processing and/or treatment.

Fixed-treatment facilities also have limits on the types and percentage of debris allowable. However, unlike BU sites, these facilities can screen the material to remove debris that could not be separated on site. Additionally, fixed-treatment facilities may offer more flexible hours, and weather typically does not impact the processing of soil.

Waste Characterization Tips and Pitfalls

To ensure proper characterization, work with your recycling/disposal company upfront in the planning phase. Together, research the site’s history and review historical information including chemical and geotechnical data, collection methodology and sample location. It’s important to discuss the source and data with the disposal facility to ensure proper sampling.

It’s critical to know the facility sampling requirements. Also, sample collection must be performed throughout the proposed excavation area - length, width and depth - to fully and accurately represent the soil. Remember that site characterization is not the same as waste classification and that it is important to work with the disposal site to ensure that the required number of samples are collected prior to shipment.

Clean Earth’s upfront waste characterization process presents a multitude of benefits. First and foremost is the environmental benefit. Through proper waste classification conducted by a team of environmental experts, Clean Earth identifies more soil that can be beneficially reused or recycled versus the less environmentally friendly option of disposing of the soil directly in a landfill.

Second, this characterization process can provide cost savings to the customer. Clean Earth has numerous beneficial use, recycling and treatment locations available to service a single project, providing a full-service solution for projects that have various contaminants and levels of contamination.

Learn more about Clean Earth’s soil services and environmental support here.

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