ASTM-E3274 › Standard Guide for Management of Investigation-Derived Waste Associated with PFAS
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Scope
1.1 Existing guidance on the management of investigation-derived waste is focused upon cuttings, purge water, personal protective equipment, and other miscellaneous solid waste generated at property that may be impacted by the release of hazardous materials and hazardous substances. These hazardous substances include, but are not limited to, heavy metals, petroleum, petroleum byproducts, solvents, polycyclic aromatic hydrocarbons, organic and inorganic corrosives, radioactive material, and explosives. Guidance on the management of investigation derived waste generated at sites that may be impacted by releases of perfluoroalkyl and polyfluoroalkyl substances (PFAS) is limited. This standard guide addresses this deficiency
1.2 This guide describes best practices for managing investigation-derived waste associated with PFAS that are consistent with federal and state policies and regulations at the date of issuance. The user is advised to determine if new regulations or rules have been promulgated by the state, federal, or tribal regulatory agency having jurisdiction over the property.
1.3 This guide describes considerations to prevent the unintended and unauthorized disposal of liquid investigation-derived waste that may contain PFAS into wastewater treatment plants or systems that are not permitted to receive these waste streams.
1.4 This guide describes considerations to prevent the unintended and unauthorized disposal of solid investigation-derived waste that may contain PFAS into landfills or other solid waste disposal facilities that are not permitted to receive these waste streams.
1.5 This guide describes several stormwater pollution prevention best management practices applicable to investigation-derived waste.
1.6 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety, health, and environmental practices and determine the applicability of regulatory limitations prior to use.
1.7 This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
Significance and Use
4.1 Perfluoroalkyl and polyfluoroalkyl substances (PFAS) are a family of more than 4700 synthetic organic chemicals. PFAS can withstand high temperatures and survive highly corrosive environments. They are used in the manufacture of coatings, surface treatments, and specialty chemicals in cookware, carpets, food packaging, clothing, cosmetics, and other common consumer products. PFAS also have many industrial applications and are an active ingredient in certain types of fire-fighting foams (aqueous film-forming foams, or AFFF). PFAS coatings resist oil, grease, and water. PFAS are persistent compounds. Therefore, PFAS should be considered for purposes of managing investigation-derived waste where PFAS is known or suspected to be present in environmental media.
4.1.1 PFAS are emerging contaminants for which environmental regulations and guidance are dynamic and are being developed simultaneously at federal, state, local, and international levels as more is learned about their characteristics, environmental fate, and management/treatment. Therefore, site-specific rules, regulations, and guidance should be evaluated for options and restrictions on management of PFAS investigation-derived waste. For example, the Massachusetts Department of Environmental Protection has determined that PFAS wastes are “hazardous materials” subject to the Massachusetts Oil and Hazardous Material Release Prevention and Response Act (M.G.L. Chapter 21E) and the Massachusetts Contingency Plan. Other states and jurisdictions may have or will develop and implement similar determinations that affect the on-site management, storage, and labeling and off-site transportation requirements for PFAS investigation-derived waste.
4.1.2 Given the characteristics and persistence of PFAS compounds, PFAS investigation-derived waste presents special handling and treatment/disposal considerations. EPA recently issued Interim Guidance on the Destruction and Disposal of Perfluoralkyl and Polyfluoralkyl Substances and Materials Containing Perfluoralkyl and Polyfluoralkyl Substances (2020) (1)5. This interim guidance focuses on technologies for treatment and disposal that have the potential to destroy PFAS by breaking the carbon-fluorine bonds or controlling migration of PFAS in the environment (for example, secure landfilling). Although the interim guidance focuses on the destruction and disposal of residuals and wastes/waste byproducts from manufacturing activities, the guidance should be considered when evaluating treatment or disposal options for PFAS investigation-derived waste.
Note 1: The Department of Defense issued a new policy in July 2023 addressing the management of PFAS-contaminated material, including IDW (2).
4.1.3 PFAS investigation-derived waste may also contain other nonhazardous or hazardous substances or materials that may impact the options and requirements for management. The associated substances should be considered for proper characterization of the investigation-derived waste and in selecting containerization, labeling, handling, transportation, and disposal options. (3)
4.2 Field investigation activities result in the generation of waste materials that may include PFAS. Investigation-derived waste may include monitoring well development water, purge water, soil cuttings from boreholes, sediments, soil or fill from excavation activities, solutions from decontaminating sampling equipment, personal protective equipment, and other sampling wastes (for example, paper towels, plastic sheeting).
4.2.1 Soil cuttings, excess sample spoils, and excavated soil that are returned to the borehole/excavation may not be considered investigation-derived waste on sites in jurisdictions where regulations and guidance allow for this management option.
4.2.1.1 The user must determine the disposal options for these materials in conjunction with the property owner, responsible party, and the regulatory agency.
4.3 The primary objectives for managing investigation-derived waste during field activities include:
4.3.1 Leaving the site in no worse condition than existed before field activities,
4.3.2 Removing wastes that pose an immediate threat to human health or the environment,
4.3.3 Segregating wastes above background or threshold concentrations,
4.3.4 Complying with federal, state, local, regulations,
4.3.5 Minimizing the quantity of investigation-derived waste, and
4.3.6 Properly containerizing, managing, and disposing of investigation-derived waste.
4.4 Container Labeling:
4.4.1 In accordance with the OSHA Hazard Communication Standard (4) or other applicable jurisdictional requirements, an “investigation-derived waste container” or “Waste Awaiting Designation” label shall be applied to each drum, intermediate bulk container, portable tank, or other container using indelible marking. Labeling or marking requirements for investigation derived waste are as detailed below and should be referenced in the site’s Health and Safety Plan and Sampling and Analysis Plan.
4.4.1.1 Include the following information on labels and markings: project name, generation date, location of waste origin, container identification number, sample number (if applicable), and contents (that is, decontamination water).
4.4.1.2 Apply each label or marking to the upper one-third of the container at least twice, on opposite sides.
4.4.1.3 Position labels or markings on a smooth part of the container. The label must not be affixed across container bungs, seams, ridges, or dents.
4.4.1.4 Use weather-resistive material for labels and markings and permanent markers or paint pens capable of enduring the expected weather conditions. If markings are used, the color must be easily distinguishable from the container color.
4.4.1.5 Secure labels in a manner to ensure that they remain affixed to the container.
4.4.2 Labeling or marking requirements for containers of investigation-derived waste that is determined to be hazardous material and is expected to be transported offsite must be in accordance with the requirements of U.S. Department of Transportation (DOT) hazardous material regulations (see 49 CFR 172). Wastes determined to be hazardous waste or subject to state, provincial, or tribal regulation will be staged onsite in accordance with the requirements of U.S. EPA hazardous waste regulations (40 CFR 262) or other applicable jurisdictional requirements regarding labeling and marking until disposal options are determined by the property owner, responsible party, or the site operator.
4.5 Investigation-derived waste Container Movement Predetermine staging areas for investigation-derived waste containers in accordance with the site’s Health and Safety Plan and Sampling and Analysis Plan. Determine the methods and personnel required to safely transport investigation-derived waste containers to the staging area before field mobilization. Handling and transport equipment will be consistent with the associated weight for both lifting and transporting. Transportation of investigation-derived waste that is considered to be DOT hazardous material offsite via a public roadway is prohibited unless the requirements of 49 CFR 172 or applicable national regulations are met.
4.6 Investigation-derived waste Container Storage
4.6.1 Stage containerized investigation-derived waste awaiting results of chemical analysis at a pre-determined location on the site.
4.6.2 Store containers such that the labels can be easily read.
4.6.3 Provide a secondary/spill container for liquid investigation-derived waste storage (for example, drums and intermediate bulk containers shall not be stored in direct contact with the ground). In addition, liquid IDW should be staged in secondary containment that conforms to the applicable, federal, provincial, state, or tribal regulations for hazardous waste accumulation areas.
4.6.4 The user must determine if federal, state, local, provincial, or tribal regulations impose additional requirements for the temporary storage of investigation-derived waste, including those pertaining to storage requirements and limitations for hazardous materials or hazardous wastes. These requirements may include periodic inspections of the containers and implementation of stormwater pollution prevention Best Management Practices (see 5.6).
Keywords
best management practices (BPMs); container labeling; investigation-derived waste; PFAS; waste disposal;
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Document Number
ASTM-E3274-24
Revision Level
2024 EDITION
Status
Current
Modification Type
Revision
Publication Date
March 28, 2024
Document Type
Guide
Page Count
6 pages
Committee Number
E50.04