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Considerations for Waste Management Decisions

There are many considerations that should be taken into account during the decision-making process regarding how and where to manage the waste. Below are questions that you should consider:

What is the nature of the event?

The nature of the event may influence how the resulting waste is managed. Generally, different types of incidents can generate different kinds of waste. For example, animal disease outbreaks may result in carcasses contaminated with biological agents. Natural disasters may generate large quantities of vegetative debris and construction and demolition materials. The types of waste generated by chemical, biological, radiological, or nuclear incidents are very dependent upon the decontamination and cleanup methods employed during the response as a result of the characteristics of the agent involved. Therefore, depending on the nature of the event, there may be waste management options that are more appropriate, preferable, or available than other options for each type of waste generated. In addition, some options may be required or prohibited for a particular waste stream. There is no one option that is best for all waste streams.

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How much waste was generated by the incident?

The amount of waste generated by an incident affects decisions regarding how to manage the waste, including the storage, treatment, and disposal of the waste. Therefore, determining the amount of waste generated helps facilitate effective waste management decision-making during the response. The amount of waste generated partly depends upon the magnitude of the incident and the resulting contamination. Factors such as delivery method of an agent (i.e., chemical, biological, radiological, or nuclear) and environmental conditions (e.g., wind speed, temperature, humidity, and UV light intensity), which influence the size, shape, intensity, and overall effectiveness of the agent deposition pattern, are important to determining the magnitude of contamination.

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Are staging and storage areas available for the waste prior to its treatment and disposal?

Having the capability to stage and store large amounts of waste can aid in waste management, for example, by providing the space needed for sorting waste into different waste streams, isolating hazardous waste in order to keep it from contaminating non-hazardous waste streams, and storing waste until capacity becomes available at a waste management facility. Local communities should identify and secure staging and storage areas before an incident occurs as part of their pre-incident planning and preparation activities.

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What wastes can be segregated into different waste streams?

Where feasible, the waste should be segregated into different waste streams, such as vegetative debris, hazardous waste, white goods, sediment, construction and demolition materials, and putrescible waste. Different waste streams can be subject to different Federal, state, local, and tribal regulations and requirements. In addition, different recycling, treatment, and disposal options may apply to different waste streams, which affect other considerations including cost and environmental consequences. For example, hazardous waste, which is subject to stringent regulations, should be kept separate from other wastes in order to avoid contaminating other waste, which would cause more waste to be deemed hazardous. Vegetative debris can often be recycled or composted, creating a usable product that may generate revenue. EPA’s Planning for Natural Disaster Debris Guidance (PDF) (94 pp, 1.9MB, about PDF) provides more information on different waste streams. Waste segregation may not be possible during the initial stages of a response to an incident, but as the cleanup and recovery progresses, waste segregation may become easier to accomplish. Communities should plan for waste segregation in advance of an incident in order to increase the efficiency and effectiveness of their waste management activities during and after an incident. This pre-incident planning should include the identification of staging and storage areas that are large enough to accommodate waste segregation activities.

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Can any of the waste be reused or recycled?

There are reuse or recycling opportunities available for many waste streams, even hazardous waste. Reuse and recycling options should be considered before other options. Reuse and recycling have positive environmental and, possibly, economic impacts. There are many reuse and recycling resources.

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Should the items or buildings be decontaminated?

If an item or building has been contaminated by biological organisms, chemical warfare agents, or radiological materials, for example, decontamination may be necessary to remediate the affected item or building. However, not every item can be reused because, in some situations, decontamination is not feasible or even possible. The decision on whether or not to decontaminate an item or building depends upon environmental, economic, public health, and other considerations, which may have to be balanced. For example, decontamination of contaminated materials generates its own waste that requires disposal, including personal protective equipment, vehicles, and contaminated water. The amount of waste generated may be small or very large. Therefore, the decision on whether to decontaminate an item or not should in part balance the cost of replacing and disposing of the item, if feasible, with the time and cost of decontaminating the item and disposing of the associated waste. Other factors to consider include whether a facility will accept contaminated waste, the effectiveness of the decontamination process, and public perception.

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Can the waste be minimized?

The amount and toxicity of waste needing to be managed should be limited and reduced as much as possible. Waste minimization not only has environmental benefits, but can have economic benefits as well. Communities that prepare and plan for incidents can identify opportunities for minimizing the generation of waste in the first place. In addition, entire waste streams (e.g., vegetative debris) can be diverted from disposal through reuse and recycling opportunities along with wastes such as scrap metal and sediment. Waste that can be treated before disposal, to render the waste less contaminated or non-hazardous, may make the waste cheaper to dispose of.

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What are the environmental consequences of each option?

Each management option triggers some environmental concerns, including air emissions, potential groundwater and surface water contamination, disease spread, and soil contamination. The environmental consequences associated with each waste management option with regards to each waste stream vary. When deciding upon a waste management option for a particular waste stream, it is important to minimize the environmental risk as much as possible by choosing an option that is best suited for that waste stream within the context of the particular situation. To help ensure optimal environmental protection, it is important to comply with all applicable Federal, state, local, and tribal laws and regulations. You should contact your state, local, and tribal officials for further information and assistance in selecting the appropriate waste management option(s).

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Do the site conditions allow for on-site waste management options?

On-site waste management options include on-site composting, air-curtain incineration, and burial. These on-site options generally are preferable to off-site options, particularly for incidents involving animal disease outbreaks. For animal disease outbreaks, keeping contaminated animal carcasses on-site minimizes the risk of disease spread and increases biosecurity. In addition, removing the need to transport the waste off-site simplifies logistics and potentially reduces overall waste management costs. However, on-site options must be carefully considered, and their environmental effects (e.g., air emissions, groundwater contamination, and soil contamination) must be carefully reviewed. The appropriateness of on-site waste management for a particular incident may depend upon Federal, state, local, and tribal requirements, deed restrictions, weather, groundwater depth, and soil composition among other considerations.

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What arrangements must be made to transport the waste off-site?

Arrangements must be made if the waste is being transported to an off-site waste management facility. First, an appropriate off-site waste management facility for each waste stream needs to be identified and located. A facility must be properly permitted or licensed for a particular waste stream in order to be able to accept that waste stream. Also, arrangements should be made in advance with the facility to ensure that the waste will be accepted upon arrival at the destination and not turned away due to capacity limitations or unwillingness to accept the waste as a result of liability concerns or lack of public acceptance. Sometimes, the facility needs advance notice before the waste arrives so that it can prepare for receiving the waste. In addition, the size of the waste may need to be reduced (e.g., ground, shredded) to facilitate its transportation or to meet a facility’s requirements. An alternate route to the facility should be planned in case the primary roads were affected by the incident. Next, a sufficient number of transport vehicles should be acquired to transport the waste to the facility. These transport vehicles should have sufficient protection (e.g., liners) against accidental spillage into the environment when necessary. For transporting hazardous waste, a manifest is needed and all US Department of Transportation requirements, including placarding, must be adhered to. Furthermore, hazardous waste transporters need EPA identification numbers, and some states require transporters to have permits or licenses. Note that pre-incident planning and preparation can help facilitate these arrangements and limit the time and resources needed for waste management activities during and after an incident.

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How much will each waste management option cost?

The table below provides the relative costs for different waste management options. Actual costs depend upon many factors, including site conditions, transportation, the waste stream, and the waste management facility. As a result, actual costs can be highly variable.

Waste Management Option Relative Cost
Landfill (Subtitle D)
$$
Landfill (Subtitle C)
$$$
Landfill (Construction & Demolition)
$
Trench Burial
$
Mass Burial
$$
Hazardous Waste Incinerator
$$$$
MSW Combustor
$$$
Air Curtain Destructor
$$
Mobile Incinerator
$$$
Autoclave
$$
Composting
$
Rendering
$$
Lemieux, NHSRC, 2007

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How much waste can each waste management option handle?

Actual capacity for each waste management option depends upon various factors, including the waste stream and the waste management facility, and, thus, can vary widely. As part of pre-incident planning and preparation, a community should determine how much waste different waste management options can handle.

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Does the waste have to be reduced in size before it can be treated, disposed of, and/or transported?

Some waste management facilities may require the waste brought to them to be no larger than a certain size. Therefore, it is important to check with the waste management facility to determine whether it has any size restrictions. If it does, obtaining sufficient space may be necessary for processing the waste on-site before it can be transported to the facility. Reducing the size of the waste and obtaining space to process the waste may add to waste management costs. However, size reduction may facilitate transportation and lower its costs.

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What is the public reaction to the available options?

The public’s opinion of each waste management option varies. A community might not like a certain waste treated or disposed of near them or like certain types of waste transported through their neighborhoods. Therefore, as part of a community’s pre-incident planning, local officials and community leaders should discuss the available options with local residents, including where the storage and staging areas should be located during an incident. This should be part of a larger risk communication plan, which the community should develop before an incident occurs.

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How quickly does the waste need to be managed?

The speed in which the waste needs to be managed (e.g., treated, disposed of) varies with the type of waste and the conditions at the site(s). Some wastes should be managed as quickly as possible, such as putrescible waste (e.g., food waste), disease-contaminated carcasses, and leaking hazardous waste storage tanks, as these may pose an immediate risk to human health and the environment. Other wastes, such as vegetative debris, can be collected and stored over a period of time in accordance with applicable regulations (e.g., permit requirements, time limitations). Local officials and emergency responders make these decisions in accordance with best practices and Federal, state, local, and tribal guidance and policies.

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Has the facility agreed to accept the waste?

Facilities, such as landfills and incinerators, do not have to accept the waste brought to them. Also, a facility may not have the authority to accept certain types of waste. The permit issued to a facility by the regulatory authority defines the types of waste and allowable quantities that the facility can accept. As a result, facilities that can accept problematic waste streams should be identified before an incident even occurs as part of pre-incident planning and preparation. Once a facility is identified, it is necessary to work with the facility and gain its acceptance before transporting waste to that facility during an incident. For example, a contract can be pre-negotiated with a facility for particular waste streams as part of pre-incident planning and preparation. FEMA’s Public Assistance Debris Management Guide (PDF) (260 pp, 15MB, about PDF) provides further information on contracted services.

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Does the state, local, or tribal jurisdiction or private entity involved in the incident have a waste management preference?

It is important to work with the state, local, and tribal jurisdictions because these jurisdictions likely have the authority to make waste management-related decisions. Also, the local or tribal jurisdiction may have a waste management plan that includes information on nearby waste management facilities and the types of waste that can be expected to be generated by the community. If the waste is generated from a private business (e.g., animal carcasses from a poultry farm), the business should have its own waste management plan that can assist in the decision-making process.

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Should the waste be treated prior to its disposal?

Whether treatment is appropriate depends upon the characteristics of the waste and the particular situation at hand. For example, if the waste is particularly voluminous (thus making transportation to a disposal facility very expensive and/or unfeasible), then treatment to reduce its volume is likely to be appropriate. Similarly, if waste is particularly toxic, treatment may be needed before it is transported to a disposal facility in order to further protect human health and the environment. It is important to note, however, that treatment options generally create residues or by-products that would need to be tested and properly handled, transported, and managed as well. Therefore, the decision to treat the waste also should address how and where the waste and any resulting residues or by-products will be disposed of or otherwise managed (e.g., recycled).

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Are multiple options needed or will one suffice?

Choosing multiple waste management options to handle the waste that may be generated during an incident may be most appropriate, considering the nature and severity of the incident. If an incident produces a relatively small volume of waste, then one option may be sufficient. However, a larger incident may generate multiple waste streams, likely requiring a comprehensive approach with many different waste management options. The type and nature of the waste streams, level of contamination, lack of storage space or transport vehicles, limited capacity at accessible facilities, a facility’s refusal to accept certain types of waste, and available reuse or recycling opportunities are just some of the reasons that make choosing multiple waste management options necessary. Also, different waste management options may be better for different waste streams for environmental, public safety, or economic reasons. Before one or more waste management options are chosen, it is important to assess the different options available and the considerations associated with each along with the different waste streams needing to be managed.

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What if no waste management options can be found?

Before selecting a waste management option, consider its availability, feasibility, and cost effectiveness, taking into account the specific incident, site, and waste stream involved. It may be possible that there is no effective option for a waste stream at an incident site within a certain time frame. In this situation, the waste may have to be stored for an indefinite period of time. Contact the applicable state agency for assistance if waste management options cannot be found for the waste.

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Are there any barriers to the selected waste management approach?

Even if the decision-making process for how to manage waste from an incident took into account each waste management consideration (e.g., public health and the environment, the type and quantity of waste streams, transportation, cost, and facility permits), there may be community and facility barriers to implementing the selected approach. With regards to the community, there may be, for example, environmental justice concerns with the transportation of waste to a particular waste management facility. Another possible community barrier may be residents who actively oppose waste being sent into their community. Lack of indemnification for waste management facilities and worker safety concerns at facilities are possible facility barriers. These barriers, in addition to political pressure, may preempt all or part of a selected waste management approach. However, having a comprehensive waste management plan in place prior to the incident may mitigate or remove these barriers. Pre-incident planning and preparation provides stakeholders (e.g., state, local, and tribal governments, owners of private storage, treatment, and disposal facilities, residents) with an opportunity to work together to find acceptable waste management-related solutions.

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