Compliance Assistance and Waste Management Consulting
Transportation Technology Center, Inc. (TTCI) • Pueblo, CO
Solution Overview
Client:
TTCI
Business Challenge:
- The need to dispose of 500 tons of mined lead ore used as ballast in rail cars
- Ballast was found to be characteristic of a hazardous waste
- Lead was present in both the ore, and soils beneath the ore
- Beneficial recovery of the ore was considered but was not economically viable
Solution:
- Develop an on-site treatment plan in cooperation with the Colorado Department of Public Health and Environment (CDPHE)
- Treatment of ore and soil by MT2 using ECOBOND®, a lead restabilization agent
Results:
- Reclassification of the previously hazardous ore and soil as a non-hazardous waste following treatment
- Significant disposal cost savings for the client
- Reduction of worker exposure for the facility
Challenge
The Transportation Technology Center (TTC) is a federal facility owned by the US Department of Transportation (DOT), Federal Railroad Administration (FRA), and operated by the TTCI, dba MXV Rail. TTCI is a research and test facility dedicated to investigating and improving the safe transportation of commodities, primarily via rail. Other testing and training are also provided at the facility to various international, government, industrial, municipal, and corporate customers. Environmental management program challenges have included generation and management of hazardous and solid waste, air pollution emissions, asbestos, non-transient non‑community drinking water system monitoring, ozone depleting substances (refrigeration equipment), Superfund Amendments and Reauthorization Act (SARA) Title III Tier II reporting, industrial wastewater treatment, water pollution, polychlorinated biphenyls (PCBs), industrial wastewater, mercury containing articles, and petroleum contaminated soils.
In 2010, TTCI discovered 500 tons of lead ore previously used as ballast in rail cars during testing activities. The ballast was found to be characteristic of hazardous waste due to elevated lead content both in the ore and soils beneath the lead ore, at leachable levels exceeding regulations. The provenance of the lead ore was not known, and no documentation could be produced to afford an exemption from a hazardous waste classification under the Bevill Amendment.
Solution
Beneficial use recovery of the lead ore for iron, lead, silver, and other mineral constituents was considered as an option for disposal but was not economically viable.
Onsite treatment of the lead ore and impacted soils with off-site disposal was the only viable option. Apex Companies initiated discussions with the CDPHE to evaluate acceptable treatment options. The CDPHE concurred that the lead ore could be treated onsite in tanks/containers, in accordance with regulations, to remove the lead hazard without a permit, followed by off-site disposal at an approved solid waste landfill.
The lead ore and soil were treated by MT2 Firing Range Services using ECOBOND®, a lead restabilization agent. The lead ore and soil were then reclassified as non‑hazardous solid waste, following verification sampling.
Results
TTCI was able to avoid incurring the costs disposing of 500 tons of hazardous waste. Thankfully, lead contaminated materials are one of the easiest things to treat. Once stabilized, the lead ore and soil could be safely handled and transported to a solid waste landfill for disposal.