Contained-in policy for contaminated soil and groundwater

• Site address
• Map of the site that shows the locations of the following:
  • Buildings, if applicable
  • Sampling locations with sample identification numbers
  • Groundwater monitoring wells
  • Surface water bodies
  • Location of sources of contamination and planned excavation extents,
    OR
  • If you excavated already, the location and extent of the excavated soil
  • If soil or groundwater comes from drilling, locations with sample identification numbers for the drilled locations
• Name(s), mailing address(es), phone number(s), email address(es) for the:
  • Property owners
  • Environmental staff assisting the property owner with the cleanup, if applicable
  • Ecology site manager overseeing cleanup actions, if assigned
• EPA/State Identification Number, if assigned
  This number is required for certain facilities managing wastes under the Resource Conservation and Recovery Act (RCRA)
• Facility/Site Database Number, if assigned

• Type of cleanup action (i.e., is the cleanup independent, voluntary, or issued under the Model Toxics Control Act (MTCA)?)
• When do you plan to excavate or remove the contaminated soil or groundwater and how long will it take.
  • Already excavated? Give the date and time this occurred.
    Note: DO NOT ship contaminated soil or groundwater until after you have received our approval to do so.
• Proposed procedures to manage and dispose of the soil or groundwater.
• Name, address, and contact information for the proposed permitted disposal facility that will receive your contaminated material.

• Describe the type of contaminated soil or groundwater. Include the:
  • Amount in volume and weight.
  • Listed waste codes.
• Describe the source and level of ALL contaminants at the site (not just listed wastes). Include the:
  • Dates when contaminants may have been released.
• Types of businesses, products, and wastes used or managed.
• Explain if you believe the contaminated soil or groundwater designates as a:
  • Federal characteristic waste,
    OR 
  • Washington state-only criteria waste.
    AND
  • Provide any analytical results, calculations, and analyses that support your explanation.

When you request a contained-in determination, you must provide statistically adequate analytical data that indicates the level of contamination in your soil or groundwater.

• Describe the sampling techniques and type of analytical methods used. Use all reasonable analytical methods to obtain practical quantitation limits below the applicable Model Toxics Control Act (MTCA) cleanup levels and Universal Treatment Standards (UTS). Please include the following:
  • The number, locations, and depths of samples
  • Short description about how your analytical data is representative of the level of contamination in your contaminated soil or groundwater
• Provide a table with analytical results for your contaminated soil or groundwater. For all regulated hazardous constituents and any possible breakdown products in your contaminated soil or groundwater, please include the following:
  • Sample identification numbers
  • Applicable MTCA cleanup levels
  • Applicable UTS
• Provide copies of original:
  • Analytical reports including chain of custody
  • Method detection limits
  • Practical quantitation limits

Are composite samples okay to use?

Please contact the appropriate regional office if you are considering composite samples for analysis:

• We will not accept analytical results from composite samples contaminated with volatile organic compounds.
• If you composite samples for other contaminants, include the justification for why you could not obtain discrete samples.
• We may request additional discrete samples.

To qualify for a contained-in determination, your contaminated soil or groundwater must designate as a listed federal hazardous waste but be below the risk-based cleanup levels allowed under the Model Toxics Control Act (MTCA).

We calculate risk-based cleanup levels according to:

• MTCA Method A cleanup levels for unrestricted land uses (if applicable).
• MTCA Method B, using default exposure scenarios and risk assumptions.

We compare your analytical results against risk-based cleanup levels from MTCA and Universal Treatment Standards (UTS) levels for regulated hazardous constituents in your contaminated soil or groundwater.

When we review your request, we also consider the following:

• Quantity, locations, and age of samples used in your request
• Mobility and toxicity of contaminants in your soil or groundwater
• Potential impacts of these contaminants on landfill operations

We may require additional information from you before making a final decision on your contained-in request.

In most cases, we will require some additional site-specific management of your contaminated soil or groundwater. This can include:

• Covering truckloads of soil
• Spraying excavated soils with water for dust control
• Reporting requirements during and after disposal
• Other requirements necessary to protect human health and the environment

When we review your contained-in determination request, we examine potential risks and pathways of exposure.

Yes. Some debris may qualify under the contained-in policy. We recommend contacting your regional office before submitting your request.