Can you theoretically dispose of the stabalized lead soil at a municipal Class D landfill?
Absolutely!
On the federal level, 40 CFR 261.3(f) is often referred to as the "Contained-in Rule" - basically it addresses cases where environmental media (soil, groundwater, surface water and debris) are subject to Land Disposal Restrictions under 40 CFR 268.
Many states have developed thier own criteria (under EPA's guidance) to develop a road map that is referred to as the "Contained-
OUT policy". Such policies have been developed to make it easier for people who are generators of contaminated media that is hazardous by virtue of either listing or characteristic to treat (stabilize) to a certain level whereby that media becomes NON-HAZARDOUS and therefore may be disposed of in a Subtitle D landfill (Class I lined landfill).
Florida has such a policy,
Management of Contaminated Media Under RCRA, dated August 9, 2006. This most recent update includes a few updates from the previous policies and includes updated 'treatment standards' promulgated by the Department during rulemaking. I would encourage you (or anyone) to take a look at the policy if you have any interest in how you can take contaminated media that are considered 'hazardous' and render them 'stabilized' or 'non-hazardous' so that they may be disposed of in a Subtitle D landfill. It is a pretty twisted and tortuous path so be prepared to have a copy of the federal register handy.
As far as lead is concerned, I think I mentioned earlier that I got my start with lead stabilization from evaluation and disposal of lead contaminated soils and outdoor shooting ranges. There is a very good understanding of the lead precipitates and thier relative stability - so much so that 'prescriptive' treatments have been recognized as stabilization measures for Subtitle D landfill facilities. In the case of THIS particular project, the soil is being taken off-site pursuant to the contaminated media policy because the property is going to be re-developed as a residential community. As you indicated, by virtue of applying this policy and getting concurrence from the regulatory agency, this particular responsible party has been able to substantially reduce the Transport and Disposal costs to make the clean-up FEASIBLE - from a cost and implementability perspective.
In the end, that is really the driving reason for such policy - to achieve a technically RATIONAL basis for AFFORDABLE disposal of contaminated media that become hazardous because of the point-of-generation issues (
e.g. excavation, treatement).
One of my primary job responsibilities is rendering 'Contained-Out' determinations based on history and analytical data. If you would like to know more, please feel free to PM me - I think this topic would make most roll-over and want to die if I continued any further! :lmao: :lmao:
Regards,
JR
