DEEP: Management of Contaminated Environmental Media - FAQs

Management of Contaminated Environmental Media
Frequently Asked Questions

What are contaminated environmental media?

Contaminated environmental media are actively managed (excavated, dredged, pumped, or otherwise collected) rocks, soil, sediments, groundwater, or surface water that have been affected by a release of a substance. Upon excavation, dredging, or other manner of collection, contaminated environmental media are subject to waste management regulations. Contaminated environmental media include actively managed "polluted soil" as defined by Connecticut’s Remediation Standard Regulations ("RSR")1.

How are contaminated environmental media regulated?

Contaminated environmental media in the ground (in-situ) are not solid wastes and therefore cannot be Resource Conservation and Recovery Act ("RCRA") hazardous wastes. However, since contaminated environmental media may pollute the waters of the state, the contamination must be treated and/or removed. Upon removal from the ground, whether for remedial, construction, or other purposes, the ex-situ media must be characterized2 and managed accordingly as hazardous waste, solid waste, or clean fill.

How do I categorize contaminated environmental media?

The categories of contaminated environmental media are

Contaminated environmental media that: Manage as: Applicable regulations
Exhibit a RCRA HW Characteristic or Listed constituents exceed "contained-in" levels RCRA Hazardous waste CT Hazardous Waste Management Regulations
Exceed RSR criteria and cannot or will not be re-used per RSR re-use requirements Solid waste   CT Solid Waste Management Regulations
Meet the RSR criteria for a receiving site and will be re-used per the RSR3 Clean fill "Clean fill" definition in CT Solid Waste Management Regulations CT Remediation Standard Regulations

1 "Polluted soil" means soil affected by a release of a substance at a concentration above the analytical detection limit for such substance in accordance with RCSA 22a-133k-1(a)(45).

2 "Characterized" means to have conducted a hazardous waste determination pursuant to RCSA 22a-449(c)-102(a)(2)(A) and (B), incorporating with changes 40 CFR 262.11.

3 Any soil excavated from a release area that is intended to be re-used shall be managed in accordance with RCSA 22a-133k-2(h) Use of Polluted Soil and Reuse of Treated Soil.

When would media need to be managed as hazardous waste?

Contaminated environmental media are managed as hazardous wastes when the media exhibit a hazardous waste characteristic or if the media contain RCRA-listed hazardous constituents above "contained-in" levels. Refer to the Department’s "Contained–in Policy," dated May 2002. Contaminated environmental media must be characterized as soon as possible after collection or excavation. In some circumstances, existing analytical data acquired during site investigation may be used for waste characterization purposes.

If during the investigation of a contaminated property it is determined that environmental media contain hazardous waste (i.e., Hot Spots) then such contaminated environmental media must be managed separately upon excavation as hazardous waste, and comply with all Hazardous Waste Management Regulations.

What are the storage requirements for contaminated environmental media?

All contaminated media should be stored in a secure manner to prevent exposure to people and the environment, such as placement in a container, tank, on an impervious surface, or in a containment building. When not in use, containers, tanks, and stockpiles should be closed or covered to minimize the infiltration of precipitation, volatilization of contaminants, and in the case of stockpiles, erosion. Any cover material used should be properly secured and possess the necessary physical strength to resist tearing by the wind. The stockpiling or consolidating of contaminated media near sensitive human health receptors such as public or private water supply wells or sensitive environmental receptors such as wetlands, surface water bodies, or marine environments should be avoided.

What are the labeling requirements for contaminated environmental media?

The Department recommends that the container or stockpile be labeled: "contaminated soil [groundwater], awaiting analytical results, initial accumulation date: xx/xx/xx [add date when collection/excavation initiated]." If it is determined that the media must be managed as hazardous waste, you must mark the container or stockpile with the words "hazardous waste" and a description of the contents.

What are the time limits for storing contaminated environmental media in containers or stockpiles?

Non-Hazardous contaminated environmental media must be removed from the site within 45 days from the initial accumulation date. If the contaminated environmental media contain hazardous waste, then they must be removed from the site within the time limits (typically 90 days) prescribed in the Regulations of Connecticut State Agencies 22a-449(c)-102(a), which incorporates by reference: 40 CFR 262.34(a).

What permit do I need to dispose of non-hazardous contaminated soil at a Connecticut landfill?

A special waste disposal authorization is required.  An application may be obtained by calling the Waste Engineering and Enforcement Division at 860-424-3023 or from the DEEP web site.  Download the Authorization Application for Disposal of Special Waste.

This document is designed to answer general questions and provide basic information. You should refer to the appropriate statutes and regulations for the specific language. It is your responsibility to comply with all applicable laws. The information contained in this guidance document is intended only to acquaint you with certain aspects of the solid waste program. For further information please contact the Waste Engineering and Enforcement Division at (860) 424-3366.

Content Last Updated January 31, 2013