In July, new updates were adopted to highlight better land disposal practices in the area covered by the San Francisco Regional Water Board. Order R2-2020-0023 (June 2020) – General Waste Discharge Requirements (WDR) amendment applies to all active Region 2 landfills and sets new criteria for disposal of soils, and requires each landfill to submit an updated Waste Acceptance Plan
The amendment goal is to protect the local environment better while highlighting effective and efficient practices in sampling, reporting, and interpreting what is deemed clean, acceptable, and unacceptable material.
These critical updates primarily affect those participating in the board land disposal program, landfills, import/export sites, contractors, construction companies, and consultants seeking to represent those involved in a property transaction in the local area.
What’s in the New Requirements?
Changes to requirements for acceptance of contaminated soils and guidance for the importation of fill include:
- Addressing the misuse of ESLs and previous lack of understanding of their application as the reason for updating practices. Thresholds for soils with an average, contaminant-specific concentration that does not exceed a Regional Screening Level (RSL)1 for residential sites established by the U.S. Environmental Protection Agency (USEPA) may be considered ‘acceptable’, for example. Geographic considerations presented include upland placement in relation to sensitive habitats and how best to identify material that may not be ‘clean’ as potentially ‘acceptable’ based on lines of evidence.
- Clarification and modification to landfills requirements to maintain and impose the fill import plan typically require the involvement of a consultant. Additionally, the need to identify potential fill sources will need to be done in careful consideration of the known requirements.
- Generators of material must now submit an acceptance letter covering the sampling plan, data generated, evaluation of that data for use/placement, and a report summarizing this. Additionally, digital formatting of the data characterizing the material will need to be uploaded to a state data management system, Geotracker.
What Do the Updates Mean for Your Program?
Understanding how to distinguish viable paths for the material being imported or exported will require a much deeper comprehension of how clean, acceptable, and unacceptable are defined. Knowing how to classify and present your findings properly has become essential to maintaining the project timeline and budgetary goals. There is now more to consider than just chemical concentrations, and with each facility having its own plan, there will not be uniformity in practices.
If you deal with development and fill handling in the Region 2 area, a knowledgeable staff around these requirements and who is beholden will be key when making quick and informed decisions on project work. Simultaneously an internal quality assurance plan should be developed by any party participating in this work as sample quantity, location, methodology, and analytical practices will all be relative to the origin and/or destination of materials.
The right lab team will not only provide a trusted report and data management system but should also be able to help interpret the appropriate methodology, targets, and limits needed to decide the final approval of your material.
There are time, money, and liability to be saved in working more closely with your local laboratory and environmental professionals. For more information, start a conversation with us now.