Wednesday, October 26, 2016

Investigation-derived waste

I haven't had any field rants recently, so I spent a couple minutes brainstorming, and I realized: I haven't complained about investigation-derived waste (IDW), one of my biggest management headaches! How did that happen?

So. When we do an environmental investigation, we are poking around for sample material - anything from scratching the surface with a trowel to drilling boreholes hundreds of feet deep to install monitoring wells. Inevitably, we will end up with stuff that came out of the ground which may be contaminated. Depending on the jurisdiction and the level of contamination (and how much we know about the site already), we may be able to discharge water to the ground surface or dump the soil back in the hole we got it from. We may not. So it gets put into drums or stockpiles or tanks for characterization and disposal.

The real problem is with the smaller sites, which have much less room for this stuff and aren't on any contractors' priority list because of the small volume involved. For smaller jobs, you wait until the end of the field project, so that you aren't generating more stuff after characterization. So you try to arrange the characterization (sampling for disposal), get it all approved with the client and the regulatory regime and the disposal place, and try and get someone with signing authority who will be available at the same time as the transport/disposal people. By the time all these pieces are in place,  the IDW has been sitting quietly in a corner with nobody around to keep an eye on it, because all the active work has finished. And inevitably, neither the signing person nor the transport/disposal contractor have been to the IDW storage area before, and there will be some sort of access or technical problem (the drums froze overnight! The ground thawed and the drums disappeared into a frost heave! A fleet of trucks is parked in front of the drums! Something got mislabeled and your drum count is wrong!) that causes everything to grind to a halt.

I have had more headaches with trying to get IDW properly staged for disposal, approved, and carted off site than with any other phase of an investigation.

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