Contaminated Debris under RCRA

As with contaminated soil, debris is very different in physical form from the process wastes that EPA evaluated when establishing LDR treatment standards. The definition of debris in §268.2(g) is:

"Debris means solid material exceeding a 60 mm particle size that is intended for disposal and that is: a manufactured object; or plant or animal matter; or natural geologic material. However, the following materials are not debris: any material for which a specific treatment standard is provided in Subpart D, Part 268, namely lead-acid batteries, cadmium batteries, and radioactive lead solids; process residuals such as smelter slag and residues from the treatment of waste, wastewater, sludges, or air emission residues; and intact containers of hazardous waste that are not ruptured and that retain at least 75% of their original volume. A mixture of debris that has not been treated to the standards provided by §268.45 and other material is subject to regulation as debris if the mixture is comprised primarily of debris, by volume, based on visual inspection."
Several aspects of the debris definition warrant discussion:

1. Debris is material that is bigger in one dimension than 2.5 inches (60 mm).
2. Debris is material that is intended for disposal. When manufacturing operations are shut down, a very common material that is encountered is metallic equipment and components that might be contaminated with hazardous constituents. If this material is recycled instead of disposed, it is not "debris" subject to the LDR debris standards. In other words, recycling rather than disposing material may eliminate the need to comply with the debris standards.
3. Examples of manufactured objects that are "debris" are gloves and other personal protective equipment, solder paste wipes, pipes, pumps, valves, etc. that will be disposed (perhaps due to radioactive contamination that makes them nonrecyclable). [RO 14660]
4. An example of plant material that would be "debris" is a tree stump.
5. An example of geologic material that would be "debris" is a rock.
6. The language about intact containers addresses drums that might be dug up as part of a remediation project. If the drums contain hazardous waste and are intact, the contents of the drums must be treated to meet §268.40 standards for whatever waste codes are associated with the contained wastes. In other words, intact drums of hazardous waste are not eligible for the more lenient alternative treatment standards for debris. On the other hand, if a ruptured drum is excavated, it may be managed under the debris standards.
7. The language about material being primarily debris based on visual inspection implies that it is not necessary to run a sieve analysis to determine if a waste is mostly debris, as opposed to something else (e.g., soil). A visual assessment is all that is required.

 

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Citadel Expands Environmental Geology Group and Opens San Diego Office

We are excited to announce Citadel's acquisition of the San Diego-based staff of Barajas and Associates, a strategic acquisition that will expand Citadel's well-established Environmental Geology capabilities, as well as provide a local office in the San Diego, California market. 
What this means to our Clients:

Our newest employees have extensive environmental assessment, design, and remediation experience as part of an on-going $20 million IDIQ Environmental Services contract with the U.S. Naval Facilities Engineering Command, Southwest Division (Navy) in San Diego for the past eight years, plus a wealth of private industry experience.  While our clients have been able to rely on our staff to complete complex projects, the public sector skill set and educational qualifications that our new staff members bring to Citadel take our abilities to an even higher level.  There are few projects in complexity and size that Citadel can't handle from transactional projects to Superfund site clean-ups.

  

Eli Vedagiri, M.S., P.E.

Eli has been the program manager for the Navy contract since 2004.  During this time, Eli managed an extensive amount of work, which included:  environmental, legal and real estate issues of property transfer and development; fuel tank closures; complex contaminant characterization; remediation and Operations and Maintenance (O&M) projects; landfill maintenance, construction, monitoring, and drainage improvements; RCRA and CERCLA related activities, geotechnical surveys, and many more projects.  Prior to this, he worked directly for the Navy beginning in 1994, and in that time built an excellent rapport with Navy Remedial Project Managers (RPMs), Lead RPMs, Base Realignment and Cleanup (BRAC) Environmental Coordinators (BEC), Base Closure Managers, and Remedial Technical Managers.  He has managed projects at almost every Navy and Marine Corps Installation in California, Nevada, and Arizona and has developed long-term relationships with base environmental, public works, and facilities personnel as well. Eli began his career in Environmental Engineering in 1991 working with numerous other public agencies such as Walnut Valley Water District, City of San Diego, Port of San Diego, US Army Corps of Engineers; private sector clients included vehicle rental and real estate companies.  Eli holds a Master's of Science in Environmental Engineering from Oklahoma State University, as well as a Bachelor of Civil Engineering from India.

Parveen Kumar, M.S., P.E.  

Parveen joined the IDIQ Environmental Services contract team in 2005, upon completion of his Masters of Science in Environmental Engineering at Oklahoma State University.  During this time, Parveen directly managed over $7 million in environmental engineering projects including simple fuel tank closures projects, to complex contaminant characterization, and providing cost effective solutions for environmental remediation.  He also has experience in performing evaluation of groundwater hydrology and modeling of groundwater flow in describing fate and transport of environmental contaminants using 2D & 3-D finite-element models. He is well versed in performing statistical and spatial evaluation of environmental data using GIS, spatial analysis tools, and risk assessment tools. He has completed the requsite training for Quality SWPPP Developer/Quality SWPPP Practitioner (QSD/QSP) and the registration pending with Regional Water Quality Control Board. Parveen also holds a Bachelor degree in Civil Engineering from India.

Alisa Seneor  

Alisa Seneor joined the Barajas team in 2004 as the Office Manager / Project Assistant.  She is responsible for assisting with the preparation of proposals, reports, and handling the day to day office needs, as well as day to day project management from an operations standpoint.  Alisa will continue this role for our San Diego operations, and also utilize abilities to assist the Citadel Sales and Marketing team throughout the Western United States.  She has completed the requirements for a Bachelors Degree in Psychology at San Diego State University.  

 

EPA Classifieds Trichloroethylene as a Human Carcinogen

The U.S. Environmental Protection Agency (EPA or Agency) just released its Toxicological Review of Trichloroethylene (EPA/635/R-09/011F, September 28, 2011) (Toxicological Review). This publication represents the first time that EPA has classified trichloroethylene (TCE) (CASRN 79-01-6) as a human carcinogen regardless of the route of exposure. TCE had previously been classified as a "possible human carcinogen."

     

According to the Agency, the purpose of the Toxicological Review is to provide scientific support and rationale for the hazard and dose-response assessments given in its Integrated Risk Information System (IRIS) pertaining to chronic exposure to TCE. TCE is a volatile chemical widely used by industry as a chlorinated solvent; and unfortunately, it is also widely found at contaminated sites, including hundreds of Superfund facilities across the country.

The Toxicological Review concludes that based on the available human epidemiologic data and experimental and mechanistic studies, "TCE poses a potential human health hazard for noncancer toxicity to the central nervous system, kidney, liver, immune system, male reproductive system, and the developing fetus. The evidence is more limited for TCE toxicity to the respiratory tract and female reproductive system."

The chief impact of this new hazard classification will likely be on the developing vapor intrusion standards and on groundwater remediation projects.  

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Navigating Through The Fog - Loren Witkin

A friend asked me the other day about my opinion on tax reforms and which direction I thought that Feds should take.  I responded that the issue of importance to me wasn't if taxes would remain the same, be raised, or even lowered (a guy can hope, right); what was at issue was the need for predictability.  As the president of an employee-owned business, and as an environmental, health, safety and sustainability consultant that clients rely for my advice, it is difficult to create a plan or provide sound advice when the target continues to move.

It doesn't matter if it is health care, taxes, interest rates, or environmental regulations/incentives, all of which are in flux right now. Business leaders need to be able to assess the situation, formulate a game plan, and implement their plans without hesitation and with as much clarity as is possible.  Drastic reforms in health care, a rise in interest rates, and increased regulations, while maybe not preferable, are all manageable when we all know what we are facing and what we have to take into account.

Unfortunately, there is a tremendous amount of "fog" in all of the above right now and clarity does not seem to be on the horizon due to a real or perceived lack of political leadership, partisan fighting, and issues (sovereign debt, Iran, etc.) beyond our control.  Navigating a course through the fog is difficult, but we have no choice to chart some course.

My advice to clients when it comes to managing their environmental, health and safety risks, and implementing their sustainability programs (and business in general) during these uncertain times, is to develop as reasonable of a plan as you can, and follow that course with conviction.  While others are waiting on the sidelines or in safe harbors, take advantage of the fog,  stand out, and lead.  Continue implementing your sustainability programs as others are retracting theirs, garner attention for these projects while no one else is, purchase and remediate brownfields when real estate and clean-up costs are at rock-bottom, and enhance your corporate governance  image with the public and your employees, and minimize liabilities by re-affirming your commitment to your environmental, health and safety programs.  It's just as easy to be recognized right now for doing the right thing as it is the wrong thing as everyone is standing still waiting for the fog to clear.

Judge Cancels Order Prohibiting Use of SCAQMD Emission Credits

A Los Angeles Superior Court judge has revoked her 2008 order prohibiting the South Coast Air Quality Management District (AQMD) from granting emission offsets to essential public facilities including police, fire, wastewater treatment and landfills, as well as exempt sources such as business with low emissions.

"This action will ensure that in the future essential public facilities can expand to accommodate population growth and businesses can grow to support the region's economy," said Barry Wallerstein, AQMD's executive officer. "It will also help ensure our continuing progress toward clean air for all Southland residents."

Judge Ann I. Jones this month granted a motion by AQMD to revoke her previous order prohibiting AQMD from providing its emission offsets to essential public services and exempt sources such as low-emitting businesses. In her order Jones rejected arguments by environmental groups that claimed AQMD did not adequately address issues raised in her original decision.
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