01   /   Site cleanup = environmental remediation

What the EPA refers to as “environmental remediation” might be more familiar to you as “site cleanup.” It’s the removal of pollutants or contaminants from environmental media (i.e., soil, sediment, or water). But call it what you will – there are at least three circumstances in which you need to know about it.

02   /   In what circumstances is environmental remediation necessary?

Too much of anything. Too much of anything can require environmental remediation if it winds up in the wrong place – accidentally or otherwise – no matter how ecologically benign it might seem. Milk is a good example. At first blush, you might think that pouring milk onto a farm field would make for good fertilizer. (Sometimes farmers dump milk, given the peculiarities of agronomics.) What could be bad? After all, we drink it. But milkfat from a milk runoff will block oxygen and sunlight just as effectively as one made of motor oil, harming nearby waterways. So, even a dairy spill can require environmental remediation. We know of a case where a r‑alarm fire at a dairy warehouse “sent a burning river of melted butter into the streets,” per contemporary reports. Ad hoc dams were hastily built to stop the buttery flow from reaching creeks and lakes. Officials worried that the butter could solidify in sewers and, in what had to be an understatement, “create problems.”
The rules change. There’s the case in which you’ve been collecting something onsite that’s off EPA radar, but then learn that your state has deemed it a regulated pollutant and now your property requires environmental remediation. California provides a good example: Back in 2007, that state passed a statewide chemistry policy that exceeds the scope of the federal Toxic Substances Control Act (TSCA). Local governments (e.g., San Francisco) also tightened controls. This is in no way unusual, as state and local environmental regulations are commonly more restrictive than their EPA counterparts.
Change of purpose. A common situation requiring environmental remediation is where a known pollutant has been collecting somewhere, but now needs to be removed, usually because the site owner wants to use or sell the property for some other purpose. Erstwhile gas stations are a prime example, where leaky storage tanks have let gasoline leach into the soil. So are defunct shooting ranges, where spent lead has accumulated into earthen ammo-backstops. Add to that former dry‑cleaning properties, contaminated with tetrachloroethylene, a Group 2A carcinogen.

03   /   The responsibility for environmental remediation is yours – and yours alone

In any of these three cases, whether you’ve concluded by yourself that you own a property in need of environmental remediation – or some local, state, or federal authority has so determined – the burden is on you to complete the site-cleanup within the law.

You can’t just go out with a shovel and wheelbarrow and start digging up pollutants, however. There are issues. Not the least among them: the safe and legal transport, treatment, and/or disposal of hazardous waste materials.

Also bear in mind, environmental remediation is subject to a host of EPA regulations. And, in cases where pertinent laws are either nonexistent or advisory, your situation might instigate ad hoc requirements based on presumed risks, previously unconsidered.

As in all things regarding the EPA, it’s crucial to get expert advice.

04   /   Environmental remediation assessment and methodology

If you own a site needing environmental remediation, it will need to be analyzed to determine the size, type, and extent of contamination; the environmental media affected; and the local environmental and geological characteristics.

This requires soil sampling, chemical analyses, and other scientific methods. Again ­– get expert advice before proceeding.



As to the actual environmental remediation, there are two approaches.

Ex-situ methods involve extracting the contaminated soil and groundwater, and then hauling it offsite to an appropriate treatment facility. As you’re legally responsible for all hazardous waste from cradle to grave, you’ll want to make sure that the company you hire is current on DOT hazmat transportation requirements.

In-situ methods treat the soil and groundwater without removal. They involve such technologies as “soil vapor or steam-enhanced extraction,” “chemical oxidation,” “bioremediation‑phytoremediation,” “thermal desorption,” and other chemical interventions.

A word about brownfield sites

So-called brownfield sites are industrial-sized abandoned, idled, or underused properties in which redevelopment is hampered by environmental contamination.

Think abandoned railroad yards, oil refineries, steel plants, liquid/chemical storage facilities, and heavy manufacturing facilities.

The EPA maintains a Brownfields Program to provide funds and technical assistance to states, communities, and other economic stakeholders to assess, remediate, and reuse brownfields.

Contact us to find out more.

05   /   EPA regulation of environmental remediation efforts

The EPA supervises the scientific examination of a property needing environmental remediation per  RCRA (e.g., soil sampling, chemical analysis, etc.). The environmental remediation itself might be performed by the EPA, other federal agencies, states, or local municipalities

In many cases, however, the party responsible for the contamination is required to conduct the environmental remediation. Thus, the company you engage to assist you will have to be properly “licensed and permitted” per the EPA, as well as by any number of state and local authorities.

06   /   Get expert consultation

Given the close scrutiny the EPA affords site cleanup, it’s important that you hire a hazardous waste management company that’s an expert in – and specifically licensed for ­– environmental remediation.

By doing so, you’ll know that your environmental remediation efforts comply with all EPA regulations and mandates – as well as any unforeseen requirements based on presumed risks. More specifically:


For ex-situ remediation, look for documented, fully compliant experience in the hauling and/or disposing of contaminated soil and groundwater.


For in-situ remediation, look for a documented history of sound scientific practice.

Remember, RCRA dictates that you’re responsible for any hazardous waste from “cradle to grave.” This includes its generation, transportation, treatment, storage, and disposal.

You’re not only accountable for a hazardous waste from the moment it’s generated. You’re also legally responsible for its safe transportation to wherever it will be ultimately processed or disposed of.

A noncompliant environmental remediation project can cause you more legal, regulatory, and environmental headaches than it solves.

Don’t take chances. Contact us today. Or call 866.315.8116

And thank you for reading our blog!

Robert Losurdo

President, COO