Managing excavation of contaminated soil during an environmental remediation project can be a complex process. Whether you are remediating old industrial land or specifically excavating soil as part of an incident involving a spill, having a solid strategy in place will help to manage your contaminated soils.
Failure to manage contaminated soils correctly could result in large fines and delays due to incorrect management and transport of soil as per Federal and State laws. Having strategies in place to manage your contaminated soils can be broken down into three steps;
Step 1: Waste Profiling
Before transporting any materials, a waste profile should be undertaken. This will determine what type of waste you have; non-hazardous, hazardous or special waste.
This should include;
Core samples taken across the area to be sampled to help identify any differences in contaminates such as VOCs, heavy metals or hydrocarbons.
Having a certified environmental lab carry out TCLP tests to give you the correct waste code.
Ensure the waste profile has been accepted by the waste facility or TSDF.
Step 2: Transport Planning & Carrier Selection
Transporting contaminated soils will require specialist equipment and processes to be followed when using highways. Using a specialist transport company with the right equipment will reduce risk of spillage, dust and any issues with the transport.
Things to look for when selecting a carrier;
Correct equipment – Ensure they are using lined roll off boxes, sealed end dumps or covered tandem trucks.
They have valid permits – Ensure they have valid DOT permits, EPA numbers and state environmental transport permits.
Drivers are trained – Ensure drivers hold their OSHA 40 hour HAZWOPER certificate and are trained on spillage.
Engineering teams often work with specialist transport companies such as Envirotest Transport when undertaking large scale excavation.
Step 3: Manifest
Having a full paper trail will help to reduce any risks in the future. A shipping manifest will show where the soils have been transported.
Things to consider;
Ensure the correct amount of soil has been recorded. This includes correct weight tickets, waste codes and generator details as per the waste profile.
GPS tracking – Ensure your fleet are using GPS tracking to show they have travelled the correct route.
Manifests should be obtained quickly. Obtain copy of record manifests with signatures from the waste facility within the required time frames.
Final Thoughts
Soil remediation can rely heavily on how you manage the transport. By ensuring you have the correct waste profiling, carrier selection and manifest tracking in place you can help to protect the public, reduce any risk of getting fined and keep your project running smoothly.
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