Overview
When it comes to any environmental remediation or any other activities that require touching the environment, such as drilling or sampling, it is essential to practice proper waste management. That is because all unnecessary samples are rendered as waste.
Therefore, these still need to be disposed of properly for a healthier environment and safer public health. This process is referred to as investigation derived waste management. If you want to know more about it, continue reading below and learn all that you need to know.
What is Investigation-Derived Waste (IDW)?
Simply put, IDW is a type of waste that is created during site investigation activities. A site investigation occurs only when there is a presence of contamination on said site.
Additionally, since it is a type of waste, there must be a proper waste management planning prior to the site investigation or environment remediation. This can greatly help solve the problem of waste disposal.
It is vital that there is proper management of IDW not only because of the potential negative effects on the environment, but also because it is regulated by the state. So, as stated earlier, the disposal of IDW must be already planned even before the start of an investigation. That is because this process can be quite time consuming.
Examples of IDW
Now that we have briefly discussed the definition of IDW, you might be wondering about what are the kinds of wastes produced during a site investigation.
See all the examples on the list below:
- Mud from any drilling involved
- Cuttings from drilling
- Any excess samples from site
- Personal protective equipment or PPE
- Purge water from tracking of well development or test borings
- Water or any type of fluid that was produced by sampling or tooling equipment
- Drill fluids
- Development water
- Decontamination fluids
Apparatus or Equipment Used
As stated earlier, prior planning for environmental investigations is essential. This includes the procurement of necessary tools or equipment. Most of which are easily obtainable. That said, any sort of equipment, materials, or supplies that are for the containment of IDW are generally selected based on the characteristics, components, and elements found in solid and liquid wastes. For today, we will be splitting it into two categories. One is for equipment used for decontamination. The second is for disposal of waste.
The Equipment Used For Decontamination
- Washing Solutions
- Any paper or cloth towels
- Big galvanized tubs
- Rinsing Solutions
- Any long-handled brushes
- Cans or drums that are made out of plastic or metal
- Any brush that have soft bristles
- Soap solutions
- Plastic drop cloths or any object with the same materials
The Supplies Needed for the Disposal of Waste
- Containers for trash
- Garbage bags
- Any metal or plastic containers or buckets that can store as well as dispose of decontamination solutions
- Drums that can contain at least 55-gallons
- Pails that can hold 5-gallons
Reagents Used for IDW
One of the fastest ways to determine contamination within a site is by the use of reagents. However, for IDW, the only type of reagent needed are solutions that are specifically engineered for decontamination. Hence, there are only a handful of solutions that can be used for decontaminating a contaminated site or environment. These include the following:
- Pesticide grade Acetone
- Pesticide grade Hexane
- Methanol
- 10% Nitric Acid
Is IDW Hazardous?
Since a site investigation became necessary, it is easy to assume that IDW is hazardous because there is proof of contamination, right? Well, it is not wrong to assume that. However, not all of it is hazardous, only some of IDW are considered hazardous. Generally speaking, though, those “contaminated” environmental samples are not under the Resource Conservation and Recovery Act or RCRA laws and regulations.
According to the Environmental Protection Agency or the EPA, RCRA is a public or state law that creates a structure for proper management of hazardous and non-hazardous solid waste. The RCRA law discusses the waste management program that is mandated by Congress. Basically, it gives the EPA authority to develop the RCRA. Now that you know a brief definition of the RCRA, what kind of IDW falls under its laws and regulations?
As stated earlier, most IDW is considered as non-hazardous bi-products. However, an environmental sample can fall under the jurisdiction of the RCRA if the samples or media contain hazardous waste. According to the standards of the EPA, an environmental media can be classified as hazardous if it exhibits one or all of the following:
- The sample is polluted with high concentrations of hazardous elements. These might come from the hazardous waste that contains high amounts of dangerous components that exceed levels that are considered safe for a person.
- If it shows signs of characteristics that are commonly found in contaminated hazardous wastes. These so-called characteristics include corrosivity, ignitability, toxicity, or reactivity.
If site samples does not include one or all of the mentioned above, then it does not fall under the RCRA laws and regulations. Therefore it can simply be stored in ordinary waste containers and delivered to solid waste landfills. If, however, it does contain those mentioned, then proper management of waste disposal is necessary.
Active IDW Management and Point of Generation
Since IDW has two classifications – hazardous and non-hazardous, we will be dividing the management into two parts. This provides a clearer picture on how to manage IDW bi-products properly and keep it within state regulations.
Hazardous IDW Management
Any waste sample or media that is deemed hazardous or suspected to be should always be approved by its Sampling and Analysis Plan or SAP or the Quality Assurance Project Plan or QAPP (from the EPA) prior to any site investigation. The disposal of IDW must be in line with the current regulations of the USEPA.
However, in the case of waste being available for treatment, they can be sent to the proper treatment facilities. After correct treatment is done, that is when these types of wastes can be disposed of on the site of origin. Nevertheless, the right personnel must deem these wastes as safe, and should not negatively affect the overall health of the environment or people.
Needless to say, because they are suspected of hazardous waste, proper testing must be done in order to rightly determine it. If found to be hazardous and cannot be disposed of on site, these IDW must be stored in the right container and labeled accordingly. In accordance with the EPA, these hazardous wastes can be stored on-site for a maximum length of 90 days. These wastes must be delivered to the right treatment or disposal facility within that specific time period.
Hazardous IDW must always be expected when conducting site investigations. This, again, strengthens the fact of proper waste disposal planning beforehand. Planning should include the right transportation, labeling, containerization, and, of course, the USEPA regulated treatment and disposal of these hazardous wastes.
Saying all of the above, the generation of IDW should be kept minimal, but there are some exceptions, such as purged groundwater and spent solvent. This can be done by decreasing the use of solvents for cleaning equipment. The best way to do this is by using solvent-free materials for cleaning and environmental decontamination.
If, however, the use of solvent is necessary, then one should only spend the right amount in order to keep the utilization at a minimum. Another method that should also be observed is by capturing residual solvents from the aqueous decontamination fluids. These include water rinses and detergent or wash water mixes.
We know that gathering all the information above can be time consuming. So, we decided to summarize everything for you. The summary of the requirements for the proper management of hazardous IDW are as follows:
- All determined hazardous IDW must be put into the proper container.
- The right handling and disposal of these hazardous IDW should be discussed and finalized before the start of the site activities.
- One should have proper authorizations or inform the right personnel regarding leaving any spent solvents on site.
Non-Hazardous IDW Management
The proper disposal of non-hazardous IDW should be mentioned on the SAP or the QAPP, before proceeding to the investigation. One thing to note is the use of reusable containers, such as the aforementioned 55-gallon drum. This helps in the reduction of the total amount of IDW that is transported back to the Field Equipment Center or FEC.
If the waste, such as PPEs, any paper material, and/or disposable equipment, is from an active site, the right personnel should grant permission for you to dispose of these wastes to the proper site dumpsters. Another way for these wastes to be disposed of is through delivery to a licensed landfill. If there is a large volume of waste, one may contact waste hauling services to help with transportation.
The cuttings or mud from drillings, purged groundwater or developmental water, decontamination wash water, and any other non-hazardous IDW should always be stated on the SAP or QAPP. The EPA recommends that these wastes must be put into permitted landfills and/or sanitary sewer systems. The agency also restricts the disposal of these wastes into the dumpsters within the site or facility. One should only place non-hazardous IDW within the site or facility if said site or facility has the right treatment system.
Spreading of drill cuttings around the borehole may also be viable, or, if well is made to be temporary, those drill cuttings can also be put back into the borehole. Well purge and/or development water may also be poured down the incline of the monitoring well if possible. Regarding active private portable wells, these may also be released on the ground.
Like we did with the hazardous IDW management, we will also be summarizing the contents of the non-hazardous IDW management for you. So, the minimum requirements are as follows:
- The process of gathering, managing, and disposing of non-hazardous IDW must be stated on the approved SAP or QAPP.
- All soap and water decontamination fluids and the like, must never be put into any body of water. These must be collected and sent to the FEC for disposal.
- Non-hazardous IDW that are liquid or sediment in nature may be put on the ground. One can also return it to the original source as long as it does not pose any risk factors regarding the health of a human being or the environment. It also should not violate any state regulations in the process.
- In relation to the previous point, monitoring well purge water should never be put back into the place of origin.
How to Manage IDW or Remediation Waste
When it comes to managing IDW or Remediation Waste, the planning beforehand is the most vital process. During that stage is where one discusses the factors involved for site investigation. Most importantly, it discusses the disposal of IDW.
As stated earlier, one must separate IDW into hazardous and non-hazardous before disposal. These are mandated by state and also by the EPA. So, it should always be followed in order to avoid any liabilities and/or lawsuits.
So, to make the handling of IDW simple and straightforward for you and your organization, you may follow these recommendations:
- All IDW should be stored in their correct containers with proper labeling. Always remember to segregate hazardous and non-hazardous wastes.
- The containers where you store IDW must be approved by the Department of Transportation or DOT to avoid any liability issues.
- One must make sure that all contained IDW are placed in a specific location that is easily accessible for any waste transportation service to pick-up. This avoids incomplete pick-up of waste because of an inaccessible or inconvenient location. This would also help you avoid any additional charges, making it more cost-effective.
Conclusion
We understand that managing Investigation Derived Waste is quite a complex and overwhelming process. Most often, this is due to the large amount of laws and regulations. However, we also know that with proper understanding and observing of state laws regarding IDW, one can always keep up with it and maintain a healthy environment that is safe for humans.
