Experience has shown that in major incidents, most of the elements of the waste management plan will be the same and that the most time intensive elements – identification of regulatory requirements, waste characterization, and identification of waste management facilities and assets – can best be planned well in advance of any given incident. Wide-area chemical waste management plans can be patterned after existing plans for disposal of hazardous waste and extended to cover waste contaminated by chemical substances and their decontamination break-down products, including agricultural and animal wastes as appropriate.
Understanding how a state regulates a specific chemical can have important impacts on and consequences for the activities undertaken during the response to and recovery from an incident. For example, the lack of an appropriate waste management facility to handle the disposal of the specific waste in a state may greatly influence the remediation strategy, timelines, and cost. In some instances, the most prudent course of action may be to leave chemical waste where it is. Knowing the likely options ahead of time allows for the identification and validation of regional solutions for waste disposal. U.S. Department of Agriculture (USDA) coordination with national waste management associations may enable national-level agreements surrounding issues unique to large animal agriculture incidents.
Clearly, predetermining disposal options for managing, transporting, and disposing of large volumes of contaminated materials is essential to mount an effective and efficient response and recovery. However, the process of planning out these options may require significant time and detailed discussions with the facilities and entities involved. Solutions may include establishing staging sites, treatment options, exceptions to regulatory requirements, transportation options, and disposal options. EPA’s CBRN CMAD may be able to help jurisdictions develop a waste management response and recovery plan and provide needed capabilities during a large-scale incident.