What can be done with excess soil generated during site redevelopment activities which cannot be reused onsite? Determining how to manage this excess soil is a complicated process, even for those who deal with the issue daily. The costs associated with properly managing excess soil can vary greatly depending on the contents of the soil and the paperwork associated with finding and approving a facility to accept the material often takes at least a month. To minimize these costs and avoid unexpected delays, it is best to hire an environmental consulting firm, such as Cooperstown Environmental, prior to breaking ground. Adequate soil characterization prior to breaking ground enables facilities to approve soil for acceptance prior to excavation, avoiding project delays. Pre-characterization of the soil also allows for strategic segregation or potential on-site reuse of more costly soils, reducing “disposal” costs. Finding a problem after soils have been excavated often results in cross-contamination of cleaner soils, higher disposal costs, and project delays.
In order to determine how to properly manage the soil, one must first classify the soil. How the soil is classified determines where the soil can be reused, recycled, or disposed of and the regulatory requirements which must be met throughout the soil management process. These requirements often include waste manifests, report submittals, soil handling and stockpiling methods, and/or dust monitoring during soil disturbance activities. The requirements are all dependent upon what’s in the soil. Below are some of the most common soil classifications:
- If the soil is a hazardous waste, it must be managed as a Hazardous Waste.
- If the soil contains asbestos, it must be managed as an Asbestos Containing Material.
- If the soil contains solid waste, it must be managed as a Solid Waste.
- If the soil contains concentrations of any compound above the applicable Reportable Concentrations (RCs) established in the Massachusetts Contingency Plan (MCP), it must be managed as Remediation Waste under the MCP.
- If the soil contains concentrations of any compound above the applicable MCP RCs, but the RC exceedances are exempt from reporting, this soil is considered unregulated, but could result in a notifiable release dependent on where the soil is “disposed”.
- If the soil originates from an MCP Site but does not contain concentrations of any compound above the MCP RCs, the soil must be managed per the MCP and Similar Soils Provision Guidance.
- If the soil does not originate from an MCP Site and contains concentrations of any compound above the MCP RCS-1 RCs but below the RCS-2 RCs, the soil is considered unregulated, but could result in a notifiable release dependent on where the soil is “disposed”.
- If the soil does not originate from an MCP Site and does not contain concentrations of any compound above the MCP RCS-1 RCs, the soil is considered unregulated, but will still be subject to the acceptance criteria of the desired acceptance facility.
As you can see from the abbreviated list above, there are many nuances that can affect how soil is classified and thus also affect the costs and procedures which are required to properly manage the soil. Soil at a property can fall into more than one of these categories and sorting out which category and regulations apply requires intimate knowledge of the regulations and years of experience. Once the soil has been classified, the type of contaminants present in the soil further determines where the soil can be accepted. Additionally, any soil which originates from an MCP site requires the oversight of a Licensed Site Professional (LSP).
For a flow chart which will help you navigate soil classification, please see the Massachusetts Department of Environmental Protection’s (MassDEP’s) Soil Management Flow Chart:
Cooperstown Environmental has extensive experience with soil management and close relationships with many of the soil acceptance facilities. Cooperstown currently has four LSPs on staff, as well as an extensive support team. We can help you minimize your soil management costs and present you with the options to best meet your project needs while maintaining regulatory compliance. Let us worry about the complexities of how to handle your soil, so you don’t have to.