ESMI FAQ's
Helpful Links
General:
What needs to be done before I can bring soils to ESMI?
Can ESMI accept hazardous waste?
Can the ESMI facilities accept RCRA Subtitle D wastes?
What types of materials are not acceptable at ESMI?
Why is excessive moisture an issue?
What are the best ways to control excessive moisture?
Why is wood or other combustible material an issue?
Do you accept plastic used to cover stockpiles?
What are your receiving hours?
Does ESMI accept concrete?
Does ESMI provide trucking services?
What size trucks will you send?
What type of shipping documents do I need to use?
What is a minimum load charge?
Do you accept soil in drums?
What other services does ESMI offer?
What are your compound specific limits for VOC and SVOC?
Do you take material contaminated with Lead?
Do you accept soils contaminated with PCB's?
What size rock can the facility accept?
Do you take material with fly or bottom ash?
Who is responsible for determining if my waste is hazardous or not?
How much time should I plan for scheduling purposes?
If material is from a previously approved site, do I need to provide a profile and data?
Portable Plant:
What volume of contaminated soil is required before an onsite plant is feasible?
What types of material does an onsite plant treat?
What size area do I need to enable a portable plant to set up at my site?
What other utilities may be required?
General-Fixed facilities
What needs to be done before I can bring soils to ESMI?
Prior to shipping soils to ESMI, the generator is required to provide the information outlined in ESMI’s Waste Analysis Plan. This information includes, but is not limited to: A generator waste profile, that provides information regarding the source of soil, as well as the generator certification that the materials are not a hazardous waste. In addition, the facility will require, in most cases, analytical data representative of the soils to be transported to ESMI. The data required will depend on the type of contaminant and the total quantity of soil. ( See ESMI’s Technical Info for Details)
Can ESMI accept hazardous waste?
The fixed facilities in New York and New Hampshire cannot generally accept Federal or State regulated hazardous waste, although some special conditions do exists. These would include, but are not limited to: materials that have been determined to be non hazardous as part of a “contained in” determination and/or other materials like MGP waste that may contain elevated benzene level, which are exempt in New York and New Hampshire. Certain conditions may apply for the shipment and manifesting of these materials. Please contact our compliance department for details. The ESMI Companies also has a portable plant that can be permitted to perform hazardous and non-hazardous on-site treatment.
Can the ESMI facilities accept RCRA Subtitle D wastes?
Yes, ESMI’s facilities are located in states that are authorized by EPA to implement and manage the federal RCRA program. Each facility is permitted by their respective states to receive, store and treat non-hazardous solid wastes.
What types of materials are not acceptable at ESMI?
As defined by ESMI’s Waste Analysis Plan the following materials are not acceptable:
Materials include waste containing:
- Listed hazardous wastes,
- Characteristic hazardous wastes,
- Reactive wastes,
- Free liquids,
- Infectious wastes,
- Compressed gasses,
- Explosive materials,
- Municipal solid waste,
- Construction and or demolition wastes,
- TSCA PCB remediation waste,
- and other materials not amenable to thermal treatment. (including combustible materials such as hay, wood, paper, and other organic matter, etc.)
Why is excessive moisture an issue?
Media with excessive moisture, typically >18% on a dry wt basis causes the soil to become difficult to stockpile, and pre-process. Additionally the higher the water content in the contaminated media, the greater the fuel usage required by the thermal treatment process. The ESMI Companies reserves the right to surcharge or reject loads that have moisture content greater than agreed to contractually.
What are the best ways to control excessive moisture?
ESMI Companies prefers the use of lime kiln dust (LKD) or quick lime to control excessive moisture. The addition of LKD or quick lime makes the soils easier to handle without any of the drawbacks of other materials. ESMI Companies do not recommend the use of; sawdust, polymers, and in most cases cement kiln dust.
Why is wood or other combustible material an issue?
Since the ESMI Companies heat the soils on average up to 800 F, during treatment any wood or combustible material could catch on fire and/or smolder and produce smoke. Small, incidental amounts of wood or combustible material may be removed through preprocessing but large amounts will cause emission and operational issues if not removed prior to treatment. The ESMI Companies reserve the right to surcharge or reject loads that are delivered with higher debris content than agreed to contractually.
Do you accept plastic used to cover stockpiles?
ESMI is permitted to accept a reasonable volume of plastic. Excessive volumes of plastic may be subject to a surcharge due to increased labor and disposal costs. If at all possible, please remove plastic from the top of the stockpiles prior to loading the soil into the trucks.
What are your receiving hours?
The New York and New Hampshire facilities accept soils from 7 am to 5 pm Monday through Friday. All shipments to the facility need to be scheduled prior to shipment.
Does ESMI accept concrete?
ESMI will accept incidental amounts of concrete with the soil shipments. The concrete must be less than 8" in all dimensions and be free of reinforcing steel in order to be properly processed at the facility.
Does ESMI provide trucking services?
Yes, ESMI can arrange the logistics for hauling soils to our facilities.
What size trucks will you send?
For most projects we use tractor-trailer dumps (25-30 tons), if you have volume and space constraints we can schedule Tri-Axle dumps (18-22 tons).
What type of shipping documents do I need to use?
In most states such as (NH, NY, CT, VT, ME, RI) all that is required is a straight Bill of Lading. Massachusetts requires a LSP Bill of Lading or Material Shipping Record.
What is a minimum load charge?
Since transportation rates are calculated based on a full legal weight load, when a truck transports less than the legal load as a result of the site running short on soil the invoice will reflect as if the truck had hauled a legal load and not the actual weight on the weigh ticket.
Do you accept soils in drums?
Yes, ESMI Companies can accept soils in drums. Any information pertaining to the drummed soils should be representative of all the material. Please let the facility know if you are planning on shipping material in drums so the proper arrangements can be made.
What other services does ESMI offer?
In addition to your soil treatment and transportation needs ESMI can provide you with:
- Soil Sampling
- Technical Support
- Treatment Certification
What are your compound specific limits for VOC and SVOC?
The specific limits for VOCs and SVOCs are based on several factors including whether or not the media has the potential to be a listed or characteristic waste as well as maximum soil feed rates to the thermal treatment process. We recommend allowing ESMI to review the analytical data and site history for your project in order to make a determination of acceptance.
Do you take material contaminated with Lead?
Yes, but the primary contaminant of concern must be petroleum related and the media can not be a characteristic hazardous waste (TCLP must be less than 5 mg/l). The average total lead concentration should be below 300 mg/kg of lead. However higher concentrations may be accepted based on the facilities ability to manage such material properly as outlined by their solid waste permits. Please consult the facility if you have higher concentrations.
Do you accept soils contaminated with PCB's?
The ESMI Companies' fixed facilities can not accept PCB remediation waste. The New York facility can accept soils with PCB levels <1 mg/kg. The New Hampshire facility can accept soils with PCB’s <50 mg/kg, as long as the materials are not TSCA PCB remediation waste.
What size rock can the facility accept?
ESMI prefers that the largest rock is 8” or less. If there is a large amount of material greater than 8” please consult the facility to discuss other treatment options. The ESMI Companies reserve the right to surcharge or reject loads that have greater oversized content than agreed to contractually.
Do you take material with fly or bottom ash?
No.
Who is responsible for determining if my waste is hazardous or not?
The generator or generator's representative is responsible for completing
the waste determination of the materials generated.
How much time should I plan for scheduling purposes?
Depending on the size and complexity of the project, as well as any critical project paths consult with the ESMI Companies as early as possible. Situations such as backlogged schedules as well as planned down time are all factors that can impact the scheduling of your project. Please keep ESMI up to date on any changes in your projects schedule, so ESMI can help assist you in meeting your goals.
If material is from a previously approved site, do I need to provide a profile and data?
In most cases, No. As long as the new soils are consistent with the initial approval, not part of a different release, process or activity, and as long as there is enough data to support the soil approval then you would be able to schedule the job. If any of these factors are not met, then a new profile, and lab data representative of the soils would be required.
Portable Plant
What volume of contaminated soil is required before an onsite plant is feasible?
This is dependent on the type and concentration of the contaminant, and location of the site, but generally it would be at least 10,000 tons. Consult ESMI regarding this type of project.
What types of material does an onsite plant treat?
An onsite plant can treat the same material as the stationary plants. However, under certain conditions soils regulated under such programs as RCRA and TSCA can be treated on site. When sites contain hazardous waste onsite treatment could be a less expensive option.
What size area do I need to enable a portable plant to set up at my site?
Typically the plant would require a minimum of least 2 acres to be set, more area may be required in order to meet regulatory or processing requirements.
What other utilities may be required?
Area Required to Setup Plant: 100’ X 200’ (plus site specific soil storage)
Fuel: Natural Gas, Propane, Diesel or Spec. Used Oil. (84mmbtu/hr)
Electric: 480 Volt, 3-phase, 600 kw
Water: 90 gpm, 25 psi Residual
Misc Links:
Thermal Desorption Definition – Wikipedia
Waste Determination Process for Unused Chemicals
Waste Determination Process for Spent Chemicals
EPA:
EPA 40 CFR 260 - 266 Subchapter I, Solid Wastes
EPA 40 CFR 267 - 299 Subchapter 1, Solid Wastes cont.
Land Disposal Regulations, Basic Information
Introduction to LDR Guidance Doc.
Guidance on Demonstrating Compliance with LDR-Alt Soil Treatment Stds
40 CFR 761 TSCA PCBs
PCBs Combined Q and A
RCRA FAQ DATABASE
Waste Analysis Plan Guidance Document
Quality Management Tools - QA Project Plans
Preparation of Soil Sampling Protocol
Connecticut:
State of Conn - Waste Regulations
Management of Contaminated Environmental Media
CT Waste Determinations
CT “Contained-In” Determination Policy
Connecticut Regulated Waste
CT-Site Characterization Guidance Document
Massachusetts:
Mass HW Regulations
Mass MCP Regulations
Mass Cleanup Standards: Table 1600
Mass MCP Q and A
Mass MCP Index Page
New Hampshire:
New Hampshire Waste Determinations
New Hampshire Contaminated Site Management
New Hampshire Brownfield Program
New Hampshire Management of ASTs
New Hampshire-Soil Manual for Site Evaluations
New Hampshire-Management of Street Wastes
New Hampshire Solid Waste-Fact Sheets
New York:
New York DEC Waste Regulations
New York DEC Spill Response Guidance Documents
NYS DEC Soil Cleanup Objectives and Cleanup Levels (TAGM 4046)
NYS DEC Guidance-Management of Coal Tar Waste & Coal Tar Contaminated Soils & Sediment
Rhode Island:
Rhode Island Waste Regulations
Rhode Island Oil Pollution Control Guidance
Vermont:
Guidelines for Petroleum Contaminated Soil and Debris
Vermont HW Regulations
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