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Soil is different.
When cleaning up contaminated soil that contains a listed waste or exhibits a RCRA characteristic, a new set of rules and issues comes into play. Here’s a few tips to keep in mind:
- If you are unsure whether soil is hazardous, manage it as hazardous waste (e.g., in a 90-day unit) until you can determine otherwise via analytical and/or knowledge.
- Don’t put hazardous soil in a pile, unless it’s a defined unit (e.g., waste pile or staging pile). Use roll-off boxes instead.
- Use the alternative land disposal restrictions (LDR) treatment standards for soil in §268.49.
- Check with your state before putting treated soil back on the ground. Often it must be landfilled.
- Don’t forget about the G5 site remediation MACT. If you trigger this Part 63, Subpart GGGGG standard, additional CAA requirements will apply. Here’s a white paper.
For more compliance morsels, visit our website.
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McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with any guidance provided above. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which such guidance may conflict. Any guidance above is general in nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with environmental regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.
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