Waste Management Decision-Making Process During a Homeland Security Incident Response

Although each incident response is different, many waste management-related issues and decisions are similar from incident to incident. The waste these incidents generate will require a comparable decision-making process regarding how the waste should be managed during and after the response. Typical waste management-related decisions include how waste can be minimized, collected and treated, as well as where waste can be sent for staging, storage or final disposal. Pre-incident waste management planning can help facilitate this process during and after an incident by providing preliminary information on how waste generated by an incident may be managed, although the needs and details of the incident response should guide the specifics of the decision-making process.
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All-Hazards Waste Management Decision Diagram for Homeland Security Incidents

EPA developed a flow chart that demonstrates the waste management decision‐making process during a response to and recovery from an incident. The flow chart has been divided into three stages - initial activities, on‐site activities and off‐site activities – at which waste management decisions are typically made during an incident, regardless of the specific nature of the incident. Many of these waste management considerations and decisions are part of every response. Having an understanding of the various waste management‐related considerations and decisions involved, and incorporating them into planning, can help expedite the cleanup process and help minimize costs during an incident, enhancing communities’ resiliency.

All Hazards Waste Management Decision Diagram for Homeland Security IncidentsClick image to see larger version.

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Considerations for Managing Waste from Homeland Security Incidents

Throughout an incident response, communities may encounter many issues and considerations during waste management activities. Thinking through these issues when writing a waste management plan can positively affect the efficiency and effectiveness of a response and recovery. For example, the amount of times waste is handled, the number of transporters needed, waste management sites and facilities needed, the cost and environmental impact of the incident and the recovery timeline could all be minimized through thorough and detailed planning prior to the incident. Each step of the decision-making process influences others, requiring a holistic systems approach.

Below are questions that emergency planners, managers and responders should consider during a homeland security incident response:

  • What is the nature of the incident?

    The type of the event may influence what wastes are generated and how these resulting wastes are managed. Different types of incidents generate different wastes; such as:

    • Animal disease outbreaks may generate high numbers of animal carcasses contaminated with biological agents.
    • Natural disasters may produce large quantities of vegetative debris and comingled construction and demolition debris.
    • Chemical, biological or radiological incidents may result in huge volumes of contaminated water, depending upon the decontamination and cleanup technologies and methods used.

    Therefore, depending on the nature of the incident, one or more waste management options may be more appropriate, preferable or available than other options. Some options may be required or prohibited for a particular waste stream. No one option is best for all waste streams for all incidents, which is why pre-incident waste management planning is so important.

    How Pre-incident Waste Management Planning Can Help:
    Pre-incident planning identifies applicable regulations, possible options for managing the anticipated waste and facilities’ waste management acceptance criteria. Pre-incident planning should be documented in a Pre-incident Waste Management Plan. When an incident occurs, the Pre-incident Waste Management Plan can be tailored to the actual incident, facilitating the waste management decision-making process during the incident. Planning for foreseeable waste management needs before an incident occurs can limit the related waste management impacts on the overall response and recovery and frees up time and resources for responders to handle unanticipated waste management issues that may arise during the incident.

  • How much waste did the incident generate?

    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. For example, available capacity at waste management facilities is limited to a predetermined amount. Available capacity is further limited if facilities still accept waste from daily activities during the incident response or choose not to accept incident-generated waste at all. Therefore, estimating the amount of waste generated from the incident as early in the response as possible helps facilitate effective waste management decision-making during the response (e.g., how many facilities might be needed to manage the waste, and whether staging and storage areas are necessary to house the waste temporarily).

    The amount of waste generated partly depends upon the type and magnitude of the incident and the resulting contamination or damage. Important to estimating the total amount of waste that is generated by the incident itself and the resulting response and recovery activities are factors such as the:

    • Size of the area affected by the incident
    • Delivery method of an agent (i.e., chemical, biological or radiological)
    • 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
    • Spread of contamination by people or vectors
    • Waste-related data from similar incidents in the past

    How Pre-incident Waste Management Planning Can Help:
    Pre-incident planning can include forecasting the amounts of each waste stream that may be generated by different types of incidents. These numbers help planners determine how the waste could be managed should an incident occur. Tools such as EPA’s Incident Waste Decision Support Tool (I-WASTE DST) and FEMA's Hazus program for earthquakes, floods and hurricanes can be used prior to an incident to help forecast waste amounts. This planning also can be used to reduce the amount of anticipated waste by drawing attention to where and how the waste is generated. For example, if large amounts of construction and demolition debris likely will be generated, then communities can ensure the adequacy of building codes in how they address qualities of materials, structural design and construction methods. Any missing requirements for durable materials and appropriate construction for buildings to withstand greater wind, rain or snow loads could be inserted into the building codes.

  • Can any items be reused or recycled?

    Reuse and recycling opportunities potentially are available for many different waste streams, including hazardous waste. According to EPA’s waste management hierarchy, reuse and recycling options should be considered before other waste management options (e.g., landfills) to help lessen the environmental and economic impacts of the incident. Separating reusable and recyclable items from other wastes can help decrease the impact of the incident by conserving resources and capacity in disposal facilities. EPA's Planning for Natural Disaster Debris Guidance provides information and resources on recycling various waste streams.

    How Pre-incident Waste Management Planning Can Help:
    Communities should evaluate their reuse and recycling program to ensure it can be scaled up to handle incident-related wastes should an incident occur. To ensure the availability of reuse and recycling opportunities for different waste streams during an incident, a viable reuse and recycling infrastructure, such as recycling facilities and end markets for reused and recycled products, needs to be in place prior to an incident. Green building programs, local waste management ordinances and building code requirements can encourage the creation and maintenance of a functioning reuse and recycling infrastructure. At the same time, pre-incident planning can improve the characteristics of waste to support recycling. For example, pre-incident waste management plans may incorporate activities that ensure adequacy of building codes in how they address the resiliency and recyclability of materials.

    Pre-incident planning also can help facilitate the reuse and recycling of generated wastes during an incident within and across jurisdictional lines. Many of the permitting, compliance, collection, processing and marketing issues can be largely resolved before an incident occurs.

  • Why should wastes be segregated into different waste streams?

    State, local, tribal and territorial governments are under pressure to remove waste quickly from their communities when an incident occurs. Separating waste into different waste streams may slow down the process of waste removal, especially if the waste is mixed together in large piles. However, waste segregation allows:

    • Each waste stream to be more appropriately and efficiently managed in accordance with its applicable federal, state, local, tribal and territorial regulations and requirements.
    • Waste to be reduced in volume more effectively.
    • Waste management to be more cost-effective.
    • Facilities to more easily accept the waste.
    • More facilities to be able to accept some of the generated waste.
    • Non-contaminated and treated wastes to remain separated from contaminated wastes.

    For example, hazardous waste is subject to stringent regulations under the Resource Conservation and Recovery Act (RCRA) and should be kept separate from non-hazardous wastes in order to avoid contaminating those wastes. Mixing hazardous waste with non-hazardous waste could cause more waste to be deemed hazardous and increase the cost of managing the waste. Wastes contaminated by chemical, biological or radiological agents should be separated from non-contaminated and treated wastes to limit the spread of contamination. Also, these wastes may be further segregated relatively easily because chemical, biological and radiological incidents may not result in large piles of comingled debris like natural disasters or explosions.

    Waste segregation also allows for the recycling of different types of waste, including:

    • Electronic waste for recovering their copper, silver, gold, plastics and glass to use in new electronic products.
    • Vegetative debris for composting, landfill cover and boiler fuel.
    • White goods (i.e., household appliances, such as refrigerators and window air conditioner units) for refrigerant recycling.
    • Vehicles and vessels for scrap metal.
    • Soils and sediment for use as fill in reconstruction projects and cover material in landfills, if not returned to their original location.
    • Construction and demolition debris, like crushed masonry materials, such as bricks and blocks, for use in road reconstruction and gypsum drywall for new drywall, cement and agricultural uses.

    Recycling creates a usable product that may generate revenue and saves valuable resources. Communities should refer to EPA’s Planning for Natural Disaster Debris Guidance for information on recycling various waste streams.

    Due to these reasons, waste segregation activities should be started as early in the response as possible (e.g., before the waste is collected) and continue throughout the response and recovery. The waste can be segregated by type, receiving facility, contaminant, required treatment technology, etc.

    How Pre-incident Waste Management Planning Can Help:
    Communities should plan for waste segregation prior to an incident and in coordination with other waste management activities (e.g., waste collection). This planning should include the identification of staging and storage areas large enough to accommodate waste segregation activities. Off-site segregation may be necessary if the waste was not able to be segregated on-site, which is preferred, or if further segregation is needed for the collected waste. Pre-incident planning for these activities helps ensure that the waste would be segregated and, therefore, managed more effectively during an incident without needlessly slowing down waste removal.

  • Should items, buildings or exterior surfaces be decontaminated?

    Areas contaminated by chemical, biological or radiological agents may need decontamination to remediate the affected items, buildings and area. Decontamination aims to save or reuse exposed furnishings and other items, buildings and the exterior environment by reducing or removing harmful substances, such as noxious chemicals (e.g., with methods using bleach or diluted bleach) and harmful bacteria or other organisms (e.g., with antisepsis and disinfection procedures). The decision on whether or not to decontaminate particular materials depends upon public health, environmental, economic, private property issues and other considerations, which may have to be balanced. For example, the decontamination process generates its own waste that requires disposal, including personal protective equipment, contaminated water and items destroyed during the decontamination process.

    The amount of waste generated from the decontamination process depends upon the technology used and its effectiveness. On the other hand, decontamination may minimize the overall amount of waste requiring disposal, which is an important goal of any cleanup. Therefore, the decision to decontaminate an item, building or exterior surface should balance the cost of replacing and managing the item with the time and cost of the decontamination process, which includes managing the associated waste. Other factors to consider are:

    • Whether a transporter or facility could or would accept contaminated waste
    • Effectiveness of the decontamination technology in meeting the established clearance level
    • Time and cost of sampling and analysis
    • Packaging and labeling requirements
    • Public’s and occupants’ perception of decontaminated materials, among others

    The owner of a specific, affected item or structure also should have input in this decision.

    How Pre-incident Waste Management Planning Can Help:
    To increase the effectiveness of the decontamination process, decontamination technologies can be tested and identified for different surfaces and contaminants prior to an incident. Also, to help ensure public acceptance of decontaminated items and buildings in the affected area, pre-incident planning should include the development of a waste management-specific public outreach plan that addresses risk communication.

  • Can the waste be minimized?

    Because waste minimization has important environmental and economic benefits, waste should be minimized early and to the greatest extent possible during an incident response. Reuse and recycling opportunities can limit the amount of waste requiring disposal. Entire waste streams, including vegetative debris, scrap metal, electronic waste and soils and sediments, can be diverted from disposal through reuse and recycling, which preserve valuable landfill space and resources. Decontamination and treatment technologies can reduce the toxicity of items. For example, treating waste to remove or inactivate the contaminating agent will render the waste non-hazardous or less contaminated, which makes transporting and managing the waste (e.g., at RCRA Subtitle D facilities instead of at RCRA Subtitle C facilities) easier and less costly.

    Waste segregation also can help with waste minimization by keeping contaminated waste away from non-contaminated waste and hazardous waste away from non-hazardous waste. Every effort should be taken to limit the spread of contaminants (e.g., chemical, biological or radiological agents after an incident, oil after a spill caused by a natural disaster) during cleanup activities.

    How Pre-incident Waste Management Planning Can Help:
    Even before an incident occurs, communities can act to minimize the waste generated by an incident by identifying potential strategies for minimizing waste during a response. Communities should maximize opportunities for reuse and recycling of incident-generated waste to minimize the need for disposal. Also, testing the efficacy of different decontamination technologies for different agents (i.e., chemical, biological or radiological) on different surfaces in advance of an incident can not only minimize waste but save time and cost during a response. In addition, these communities can begin implementing strategies for decreasing the amount of potential waste generated by an incident through source reduction by mitigating the hazards in their neighborhoods (e.g., retrofit PCB transformers), updating building codes and limiting the possible spread of contamination (e.g., seal access points to the sewer or water system with drain covers).

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

    On-site waste management options include on-site composting, mobile incineration and burial. On-site options may be used to treat (e.g., reduce volume) or dispose of waste streams, such as vegetative debris, construction and demolition debris and animal carcasses. These options generally are preferable to off-site options, particularly for incidents involving animal disease outbreaks. For these incidents, keeping contaminated animal carcasses on-site minimizes the risk of the disease spreading and increases biosecurity. In addition, removing the need to transport bulky waste off-site simplifies logistics and potentially reduces overall costs.

    On-site options must be carefully considered, and their environmental effects (e.g., air emissions, surface and groundwater contamination, soil contamination) must be carefully reviewed and monitored. The appropriateness of on-site waste management for a particular incident may depend upon federal, state, local, tribal and territorial requirements; deed restrictions; weather; groundwater depth; distance to surface water and soil composition; as well as other considerations.

    How Pre-incident Waste Management Planning Can Help:
    Prior to an incident, emergency planners and managers should determine if on-site options are appropriate for their area by becoming familiar with the environmental characteristics of the area and applicable regulations. If on-site options are feasible, they should plan for environmental monitoring and controls at the sites.

  • Should the waste be relocated to a staging or storage area prior to further management?

    Before waste can be recycled, treated or disposed of on-site or at an appropriate off-site waste management facility, the waste may need to be staged or stored on-site or off-site for several reasons. These reasons may include the:

    • Need to gain time and space to segregate the waste into different waste streams
    • Removal of hazards from particular waste streams (e.g., refrigerants and food from refrigerators and freezers)
    • Need to minimize waste volume or toxicity in order to meet waste acceptance criteria or lower transportation costs
    • Lack of immediate available capacity at waste management facilities
    • Lack of sufficient numbers of transporters

    Waste staging or storage activities also can serve to remove waste management from the “critical path” to reoccupancy by not having the waste management decision-making process and its various transportation, treatment and disposal issues impact the timeline for people to return to their homes or jobs. These activities should be efficiently conducted to avoid multiple handlings of the waste, if possible.

    EPA’s Planning for Natural Disaster Debris Guidance and FEMA’s Public Assistance Program and Policy Guide provide guidance on selecting, designing, operating and monitoring these temporary staging or storage areas. Storing or staging waste on-site or off-site can have different legal requirements.

    How Pre-incident Waste Management Planning Can Help:
    If possible, local communities should identify and secure through agreements or contracts staging and storage areas as part of their pre-incident planning and preparation activities. Pre-identifying these waste management sites will save time and effort during a response.

    Also, multiple sites or locations should be pre-selected to provide emergency responders with options during an incident. However, designating specific sites or locations in advance of an incident may not be possible. In this case, communities should develop guidelines that could be used to designate sites during an incident. Whether specifying sites or locations or developing guidelines, consider the following:

    • Benefits of on-site vs. off-site management
    • Speed with which waste needs to be managed
    • Waste management facility requirements and capacity
    • Permitting procedures
    • Cost of various options
    • Environmental justice and other community concerns
    • Site security
    • Resources needed, including private sources of equipment
    • FEMA cost reimbursement requirements
    • Proximity to anticipated waste generation points and to recycling, treatment and disposal facilities
    • Ease of access
    • Ease of containment of wastes
    • Ownership of sites
    • Proximity to sensitive/protected areas
    • Need for short- and long-term surface water, groundwater, air and other environmental monitoring at the waste management sites
  • What is the appropriate waste management option for each waste stream?

    If not planned for prior to an incident, selecting the appropriate waste management option for each waste stream can be a time-consuming search and negotiation. Federal, state, local, tribal and territorial officials can provide information and assistance to help with this process.

    The following factors should be considered and balanced when making this important waste management decision:

    • Legal Requirements
      Generated waste from an incident is likely to be subject to federal, state, local, tribal or territorial legal waste management requirements. Different waste streams may be subject to different requirements, affecting the handling, packaging, transportation, treatment, disposal, etc. of each waste stream. Emergency planners and responders should be familiar with all applicable requirements for each generated waste stream to help ensure that the waste is properly managed during an incident.
    • Environmental Consequences
      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 vary with regard to each waste stream. To help ensure optimal environmental protection, all applicable federal, state, local, tribal and territorial laws and regulations should be followed. Additional environmental monitoring may be necessary.
    • 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 and Demolition) $
      Low-level Radioactive Waste Repository $$$$$
      Trench Burial $
      Mass Burial $$
      Hazardous Waste Incinerator $$$$
      MSW Combustor $$$
      Air Curtain Destructor $$
      Mobile Incinerator $$$
      Autoclave $$
      Composting $
      Rendering $$
      Lemieux, EPA’s National Homeland Security Research Center (NHSRC), 2007
    • Waste Capacity
      A waste management facility’s available capacity (both daily and overall) is limited to a predetermined amount. A facility may continue to accept waste generated by daily activities not associated with the incident, reducing available capacity for incident-related waste. Also, a facility may have limitations on ingress and egress of vehicles that may impact daily capacity even if the facility has sufficient overall capacity. Therefore, a facility should be contacted to determine waste capacity before transporting the waste there. Staging and storage areas may be needed to store the waste until capacity becomes available. Furthermore, multiple waste management options and facilities may be required to handle all the incident-generated waste.
    • Permit Status
      A facility may not have the authority to accept certain types of waste. The permit issued by the regulatory authority to a facility owner/operator defines the types of waste and allowable quantities that the facility can accept. Many facilities legally may not be allowed to accept problematic wastes like chemical-, biological- or radiological-contaminated wastes. For these and other non-typical waste streams, permit modifications or waivers in accordance with applicable law may be necessary.
    • Compliance History
      A facility’s compliance history should be reviewed before incident-related waste is sent there. A facility with a poor compliance history may not be the best choice for incident-related waste, which may already have a stigma associated with it.
    • Facility Acceptance
      Even if an appropriate waste management option is found for a waste stream, privately owned facilities do not have to accept waste. Once an appropriate facility is identified, working with the facility to gain its acceptance is advised before waste is transported to that facility during an incident. In addition, even if a facility agrees to accept incident-related waste, the facility may have waste acceptance criteria that the waste needs to meet before it will be accepted, such as size or other restrictions.
    • Distance from Waste Generation Points
      Transporting waste to an off-site facility may have cost, security, jurisdictional and environmental consequences. Therefore, the further the waste has to travel to a facility, the more complicated the logistics become for managing the waste. In addition, managing the waste at a distant facility may take more time, which could extend the recovery timeline.
    • Preference of the Impacted Jurisdiction(s)
      It is important to work with all affected state, local, tribal and territorial jurisdictions when making waste management-related decisions. These jurisdictions may have a pre-incident waste management plan that can help guide the response. If the waste is generated from a private business (e.g., animal carcasses from a poultry farm), the business may have its own waste management plan that can assist in the decision-making process.
    • Environmental Justice and Other Community Concerns
      Due to environmental justice and other community concerns, some waste management options or facilities may be less preferable than others for different waste streams. Some communities may not want certain wastes treated or disposed of near them or want certain types of waste transported through their neighborhoods, which may impact where and how the waste is transported.

    How Pre-incident Waste Management Planning Can Help:
    As part of a community’s pre-incident planning, local officials, community leaders and other stakeholders should identify and discuss available options for anticipated waste streams. For example, uncontaminated vegetative debris, depending on the jurisdiction, could be openly burned, composted or ground up for mulch or landfill cover or combusted as boiler fuel. While each of these options may vary in cost and environmental impact, each option has benefits and challenges that should be considered before one option is chosen over another. After available waste management options are determined, multiple waste management facilities should be pre-identified and documented in the pre-incident waste management plan. Communities should begin discussions and pre-negotiate agreements with other jurisdictions and facility owners and operators before an incident occurs to help ensure their acceptance of waste generated during an incident. FEMA’s Public Assistance Program and Policy Guide provides further information on contracted services. This preparation will facilitate an incident response.

  • Should the waste be treated prior to recycling or disposing of it?

    Treatment can be used to reduce the volume or toxicity of waste. If the waste is particularly bulky (thus making transportation to a disposal facility very expensive or unfeasible), then on-site or off-site treatment to reduce its volume (e.g., grinding, soil washing, composting, combustion) may be appropriate to consider. Similarly, if waste is toxic, treatment may be needed before it can be transported to a recycling or disposal facility to further protect human health and the environment or meet waste acceptance criteria.

    Treatment options generally create residues or byproducts that need to be tested and properly handled, transported and managed. The decision to treat the waste should address how and where the waste, and any resulting residues or byproducts, will be further managed.

    How Pre-incident Waste Management Planning Can Help:
    By determining the requirements and preferences of transporters and waste management facilities before an incident occurs, emergency planners and managers can begin planning how the waste should be handled and treated before it is sent to a waste management facility. This planning should be documented in the pre-incident waste management plan to facilitate an incident response.

  • Are multiple waste management options needed or will one suffice?

    To determine if multiple waste management options are needed to handle incident-generated waste, consider the nature and severity of the incident. If an incident produces relatively small volumes of routine waste streams (e.g., vegetative debris, construction and demolition debris), then one option may be sufficient. However, another incident may generate great amounts of atypical waste streams over a wide area, which may require a comprehensive approach with many different waste management options and facilities. 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 may make choosing multiple waste management options necessary or preferable. Also, different waste management options may be better for various waste streams for environmental, public safety or economic reasons. In addition, the availability of alternate waste management options during a response provides flexibility in the event that the incident adversely impacts one or more pre-selected facilities.

    How Pre-incident Waste Management Planning Can Help:
    Before an incident occurs, it is important to assess what different options are available for anticipated waste streams. This planning will help ensure that all incident-generated waste is managed as efficiently as possible.

  • What if no permanent waste management options can be found?

    Before selecting a waste management option, consider its availability, feasibility and cost effectiveness. Take into account the specific incident, site and waste stream involved. It may be possible that there is no effective option for a generated waste stream 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 permanent waste management options cannot be found.

    How Pre-incident Waste Management Planning Can Help:
    Research possible options for different waste streams prior to an incident, including out-of-state or international options. If storage space may be needed, storage areas or guidelines for selecting storage locations should be pre-identified. It also is important to know the applicable storage regulations and requirements for each waste stream. This information can facilitate an incident response.

  • Are there any barriers to the selected waste management approach?

    Even if the waste management decision-making process takes into account waste management considerations, there may be community and facility barriers to implementing the selected approach. For example, environmental justice and other community concerns may exist with respect to the transportation of incident-generated waste through communities or the management of that waste in communities. Additionally, worker safety concerns and lack of indemnification for waste management facilities are other possible barriers. These barriers, in addition to political concerns, may preempt all or part of a selected waste management approach.

    How Pre-incident Waste Management Planning Can Help:
    Drafting a comprehensive pre-incident waste management plan prior to the incident may mitigate or remove possible barriers. Pre-incident planning and preparation provide stakeholders with the opportunity to work together to find acceptable waste management-related solutions before an incident occurs.

  • How quickly should the waste be managed?

    The speed in which the waste should be managed varies with the type of waste and the conditions at the site. Some wastes may pose an immediate risk to human health and the environment and should be managed as quickly as possible, such as food waste, disease-contaminated carcasses and leaking hazardous waste storage tanks. Other wastes, such as vegetative debris, can be collected and stored for longer periods in accordance with applicable regulations and best practices, which provides additional time and space for waste segregation, treatment and other waste-related activities.

    How Pre-incident Waste Management Planning Can Help:
    Pre-incident planning and preparation helps ensure the most appropriate waste management options are implemented during the response to protect human health and the environment. For example, previously identifying or developing guidelines for selecting waste management sites and facilities can shorten the timeframe for waste management activities, especially managing time-sensitive waste streams.

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

    Arrangements must be made for waste transported to off-site waste management facilities. First, an appropriate off-site waste management facility for each waste stream should be identified and located. To accept the waste, the facility must be properly permitted or licensed for the particular waste streams. Also, prior arrangements should be made with the facility to ensure that the waste will be accepted upon arrival. Sometimes, the facility needs advance notice before the waste arrives so that it can prepare for its delivery. The size of the waste may need to be reduced (e.g., ground, shredded) to facilitate its transportation or to meet facility requirements. An alternate route to the facility should be planned in case the primary roads are affected by the incident. Next, a sufficient number of transport vehicles should be acquired to transport each waste stream to the selected facility. Waste can be transported in trucks, railcars, ships, etc. that meet the facility’s requirements. When necessary, these transport vehicles should have sufficient protection (e.g., liners) against accidental spillage into the environment. Transporters need a manifest when transporting hazardous waste, and they must adhere to applicable U.S. Department of Transportation, state, local, tribal and territorial requirements, including placarding and possible additional security. Hazardous waste transporters also need EPA identification numbers, and some states require transporters to have permits or licenses. Finally, the waste must be packaged, handled and labeled in accordance with federal, state, local, tribal and territorial requirements.

    How Pre-incident Waste Management Planning Can Help:
    Note that pre-incident planning and preparation, such as pre-negotiated contracts with transporters, can help facilitate these arrangements and limit the time and resources needed for waste management activities during and after an incident. Additionally, planning can help mitigate concern from communities and waste management facilities that might turn away waste.

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