Waste Management for oily debris & sludge from the BP Oil Spills

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1 Waste Management for oily debris & sludge from the BP Oil Spills Albert V. Condello III University of Houston Downtown Engineering Technology Department Houston, Texas Abstract In this abstract, the author helps to transform education of engineering technology students to be aware of the precautions implemented with regard to the recovery efforts related to the BP Deepwater Horizon Crude Oil Spill. This incident of national consequence required the collaboration of EPA, State Environmental Agencies, and US Coast Guard to ensure the protection of groundwater aquifers from contaminated sludge. Unique insight is shared with regards to successful practice involving environmental and civil engineering principles to address this challenge. The overall goal of this abstract is to identify those critical success factors necessary to put into practice during any man-made or natural disaster. Session Numbers 1. Introduction: The goal of this research paper will be to provide insight into how coordination is being achieved for each of the five states (Alabama, Florida, Louisiana, Mississippi, & Texas) MSW landfills. These MSW landfill have been adversely affected from the BP Oil Spill and resulting Environmental catastrophe. Lessons learned will be shared in how to provide a quality environment for future generations. Examples as well as discussion on what options are available will be cited. Insight into how to make linkage with an integrated solid waste management program will be discussed. 2. Background: The concerns of the citizens of Alabama, Florida, Mississippi, & Louisiana that oily & dispersant soaked debris might end up untreated and improperly buried at their sanitary municipal waste (MSW) landfills could happen. Such concerns are warranted as if this is allowed to be done; the result could be pollution to groundwater and soils allowing further contamination of drinking water aquifers. According to Luis A. Soto, a deepwater biologist with the University of Miami, Crude oil does contain toxic compounds known as PAH polycyclic aromatic hydrocarbons, which are not easily absorbed by bacteria. As Dr. Mervin Fingas states, Currently, restrictions under HSWA 40 CFR 268 prohibit the land disposal of hazardous waste unless the waste meets treatment standards established by EPA. (Cox & Borgas, p. 676) 1

2 Dr. Stephen Humphrey with University of Florida says, One of the striking controversies about the massive BP Deepwater Horizon oil well blowout has been alarm raised about chemical dispersants used to hold spilled crude oil deep in the Gulf of Mexico. Use of dispersants on the BP spill reportedly began on April 27, 2010, but Corexit 9527A (which contains 2-butoxyethanol) and has acute toxicity (e.g. hemolysis and tumors in rats) was soon discontinued in favor of Corexit 9500 (kerosene based). (Lustgarden, ProPublica) The exact makeup of the Nalco dispersants is kept secret under competitive trade laws, but a MSDS worker safety sheet for one product, called Corexit 9527A, says it includes 2- butoxyethanol, a compound associated with headaches, vomiting and reproductive problems at high doses. (Lustgarden) 3. Methods: A. Explain what is integrated waste management and how this is being achieved related to the BP Oil Spill. Integrated Solid Waste Management (ISWM) is a comprehensive waste prevention, recycling, composting, and disposal program. An effective ISWM system considers how to prevent, recycle, and manage solid waste in ways that most effectively protect human health and the environment. ISWM involves evaluating local needs and conditions, and then selecting and combining the most appropriate waste management activities for those conditions. (EPA Fact Sheet) B. Explain the options for solid waste management and which of those are being utilized by BP and its waste hauling contractors WM and Heritage. The major ISWM activities are waste prevention, recycling and composting, and combustion and disposal in properly designed, constructed, and managed landfills. (EPA Fact Sheet) C. Will mention those according to Exxon-Mobil Oil Spill Response Field Guide Chapter 14 Waste Management 14.6 Disposal Methods options for disposing of oiled and hazardous waste include: 1. Industrial Landfarming 2. Landfarming 3. Open Burning 4. Portable Incineration 5. Commercial Incineration 6. Reprocessing 7. Reclaiming/recycling 2

3 4. Results: D. Will also mention those according to IMO Section IV Combating Oil Spills Manual on Oil Pollution. Chapter 11 Management and disposal of oil and oily debris Waste Disposal Methods p Reclamation of oil 2. Stabilization of oiled beach materials 3. Direct disposal p. 168 when burying oil or oily debris in landfill sites, extreme care must be exercised to prevent oil leaching into aquifers or surface waters. 4. Incineration 5. Bioremedation 6. Dune disposal E. Refer to BEAC for specific environmental standard. F. Perform observations when next time deployed to BP Oil Spill. G. Conduct interview with WM and Heritage personnel at each of the MSW landfills Present the findings from the implemented method chosen for implementation. Identify the risks. Share the results from sampling studies for sediments that have been collected. Include Table 10 Examples of Common LDR treatments specified in 40 CFR (Cox & Borgas, p. 679) Mention what are the chemicals of concern that are part of the LDR land disposal restrictions. EPA is visiting each staging/decontamination area and landfill that is receiving oilcontaminated waste from the Gulf oil spill cleanup. EPA will visit each staging and decontamination area once per week. EPA will visit each landfill two times per month. Any concerns identified during site visits will be referred to the appropriate state waste agency. EPA Landfill Site Visits Alabama, Florida, Louisiana, Mississippi, and Texas environmental regulatory agencies have approved solid waste programs. The landfills receiving waste resulting from this incident are permitted by the states to accept the waste. EPA intends to support the states during their inspections and maintain a presence at these landfills. A. EPA will visit each landfill receiving oil-contaminated waste from cleanup operations from the BP Oil Spill two times per month. 3

4 B. EPA personnel and contractors will complete a landfill site visit evaluation form during each landfill site visit and post these results on the EPA Gulf Oil Spill website. C. To the extent feasible, EPA will conduct its visits jointly with the state. D. EPA will seek to obtain state landfill site visit reports and where available, post them on the EPA Web site. 5. Conclusion: BP is using a holistic approach to managing solid waste streams from the oil spill. There has been on negative impact on the landfills in each of the four states so far. EPA and US Coast Guard have developed a directive as an effective strategy to ensure an integrated approach is in place and being followed. EPA will be posting waste sampling data from BP's waste staging areas on the EPA webpage after analysis and quality review has been completed. EPA has approved the Waste Analysis plan and has demonstrated that LDR standards are not being exceeded and compliance is being achieved. According to Cox & Borgas, residuals not meeting standard must be removed annually. (Cox & Borgas, p. 678) EPA has been assisting local communities and each of the State environmental agencies to find what is the most environmentally acceptable approach to see is being put in place and adhered to by BP and its waste hauling contractors. Perform website a search from LA DEQ, ADEM, FDEP, and MDEQ with follow-up phone interview to list what are the concerns for these state environmental agencies at this present time. EPA has observed odor-causing pollutants associated with oil on the shore in the gulf region at low levels. Some of these chemicals may cause short-lived effects like headache, eye, nose and throat irritation, or nausea. Some people may be able to smell several of these chemicals at levels well below those that would cause short-term health problems. EPA surface water samples collected on July 14, and 15, along the Gulf Coast found no compounds exceeding chronic water benchmarks. These results include data for compounds found in dispersants in samples. EPA sediment samples collected on July 14, 2010 along the Gulf Coast found no compounds exceeding chronic sediment benchmarks. To date, waste sampling results do not exceed regulatory limits for the disposal of oil waste in state permitted landfills. These landfills have already been identified for disposal of BP's 4

5 collected oil waste and material in the Waste Management Plans approved by the U.S. Coast Guard in consultation with EPA and the States involved in this response. In summary, the sites where direct disposal of the oily debris should be adequately lined to contain any leachates and test wells at the site should be established so that water quality monitoring can take place to be sure that oil is not leaching into groundwater. (IMO, p. 168) References ATSDR (Sept. 1996) ToxFAQs for Polycyclic Aromatic Hydrocarbons Agency for Toxic Substances and Disease Registry - Division of Toxicology and Environmental Medicine Atlanta, GA accessed on July 24, 2010 from Lustgarden, Abraham (April 30, 2010) ProPublica website. Chemical Meant to Break up BP Oil Spill Present new environmental concerns. Accessed on July 24, 2010 from Cox, Doye B. & Borgas, Adriane P. (2005) Hazardous Materials Management Desk Reference 2 nd Edition, Academy of Certified Hazardous Materials Managers, Rockville, MD. Chapter 41 RCRA Overview: A Generator Perspective - Treatment Standards p Johnson, Tim (May 20, 2010) Gulf Recovered from last big oil spill, but is this one different? McClatachy Newspaper - Washington Bureau accessed on July 24, 2010 from EPA Website (May 2002) What is Integrated Solid Waste Management? Fact Sheet US Environmental Protection Agency Publication EPA530-F a (5306W) Solid Waste and Emergency Response accessed on July 24, 2010 from Exxon Mobil (2008) Oil Spill Response Field Manual ExxonMobil Research and Engineering Company. Chapter 14 Waste Management 14.6 Disposal Methods p thru IMO (2005) Manual on Oil Pollution Section IV Combating Oil Spills. 2 nd Edition International Maritime Organization London. Publication IA569E Chapter 11 Management and Disposal of Oil and Oily Debris Waste Disposal Methods P. 165 Levin, Alan (June 17, 2010) USA Today BP s Next Challenge: Disposal of Tainted Sludge Accessed on July 24, 2010 from Fingas, Mervin F. (2000) The Basics of Oil Spill Cleanup, 2 nd Edition CRC Press 5

6 Placeholders Biographical Information Albert V. Condello III is a lecturer / visiting associate professor with the University of Houston Downtown with their Engineering Technology Department since the fall 2008 semester. He is presently pursuing a Masters degree in Occupational Safety and Health with a concentration in Environmental Engineering from Columbia Southern University. Condello has worked with Nuclear Power Institute developing outreach programs allowing students to move into utility training programs. He is also an authorized OSHA Outreach Instructor for both General Industry and Construction Standards. Foreign teaching assignments have been in such areas as in Ndola, Zambia, Africa offering a course on Soil and Groundwater Remediation and in London, England teaching Environmental Control for Oil and Gas Exploration. 6

7 Notes Reducing waste at the source means that oily covered solid waste is separated by the cleanup crews. Reuse is not an option as all of the marketable light ends of the weathered crude oil have volatilized. The oil sludges cannot be put back into production. Land farming is not an option according to Mervin Fingas. Recycling of the sand and water once oily sediment is separated is an option. Frac trucks at the locations where boom is decontaminated allow for this. All pits are HDPE lined with sumps to pump and capture any leachate and solvent uses. Combustion to treat oily covered sand to rid it of hydrocarbons and allowing the sand to be returned is a thermal treatment is being done. No use of chemicals methods such as Corexit 9580 for shoreline cleanup is being allowed. As of Friday, 7/16/ Miles of Gulf Coast Beaches have been affected from the BP Oil Spill mostly with tarballs. LA 333 miles MS 108 miles AL 68 miles FL 71 miles (61,000 pounds of oily sand collected) According to Vesilind et al, Sludges are dried and applied on land, not into a landfill. (Vesilind et al, p. 33) Monitoring landfills, p

8 Appendix A Map of staging / decontamination sites in LA, MS, AL, and FL Source: EPA Website EPA Waste Site Visit Plans and Results (July 22, 2010) accessed on July 24, 2010 from 8

9 Appendix B - EPA Waste Sampling Protocols & Methods Samples will be collected, handled, and analyzed in accordance with the appropriate EPA Regional policy and protocol. Solid waste will be analyzed for: Toxicity Characteristic Leaching Procedure Volatiles by SW-846 Method 1311/8260B Toxicity Characteristic Leaching Procedure Semivolatile Compounds by SW-846 Method 1311/8270D Toxicity Characteristic Leaching Procedure Resource Conservation and Recovery Act List Metals by SW-846 Method 1311/6010C and SW-846 Method 1311/7470A Free Liquids by SW-846 Method 9095B Paint Filter Liquids Test Liquid waste will be analyzed for: Toxicity Characteristic Leaching Procedure Volatiles by SW-846 Method 1311/8260B Toxicity Characteristic Leaching Procedure Semivolatile Compounds by SW-846 Method 1311/8270D Toxicity Characteristic Leaching Procedure Resource Conservation and Recovery Act List Metals by SW-846 Method 1311/6010C and Method 1311/7470A Ignitability by SW-846 Method 1010/1020 EPA, or its contractors, will collect samples of waste that are temporarily collected at selected waste staging areas to ensure that all the waste is properly characterized. A representative sample of the following waste streams (if available) will be collected at each of the chosen staging areas: 1. Oily solid waste 2. Liquid waste, this includes: Liquids sent for underground injection, and/or Non-reclaimable liquids sent for disposal. 9

10 The daily waste tracking information submitted by BP, which contains the type and quantity of waste handled at each staging area, will serve as the basis for selecting staging areas for sampling. 10

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