ASTM E3274-24

This document is not an ASTM standard and is intended only to provide the user of an ASTM standard an indication of what changes have been made to the previous version. Because
it may not be technically possible to adequately depict all changes accurately, ASTM recommends that users consult prior editions as appropriate. In all cases only the current version
of the standard as published by ASTM is to be considered the official document.
Designation: E3274 − 21 E3274 − 24
Standard Guide for
Management of Investigation-Derived Waste Associated with
PFAS
This standard is issued under the fixed designation E3274; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. A
superscript epsilon (´) indicates an editorial change since the last revision or reapproval.
1. Scope
1.1 Existing guidance on the management of investigation-derived waste is focused upon cuttings, purge water, personal protective
equipment, and other miscellaneous solid waste generated at property that may be impacted by the release of hazardous materials
and hazardous substances. These hazardous substances include, but are not limited to, heavy metals, petroleum, petroleum
byproducts, solvents, polycyclic aromatic hydrocarbons, organic and inorganic corrosives, radioactive material, and explosives.
Guidance on the management of investigation derived waste generated at sites that may be impacted by releases of perfluoroalkyl
and polyfluoroalkyl substances (PFAS) is limited. This standard guide addresses this deficiency
1.2 This guide describes best practices for managing investigation-derived waste associated with PFAS that are consistent with
federal and state policies and regulations at the date of issuance. The user is advised to determine if new regulations or rules have
been promulgated by the state, federal, or tribal regulatory agency having jurisdiction over the property.
1.3 This guide describes considerations to prevent the unintended and unauthorized disposal of liquid investigation-derived waste
that may contain PFAS into wastewater treatment plants or systems that are not permitted to receive these waste streams.
1.4 This guide describes considerations to prevent the unintended and unauthorized disposal of solid investigation-derived waste
that may contain PFAS into landfills or other solid waste disposal facilities that are not permitted to receive these waste streams.
1.5 This guide describes several stormwater pollution prevention best management practices applicable to investigation-derived
waste.
1.6 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility
of the user of this standard to establish appropriate safety, health, and environmental practices and determine the applicability of
regulatory limitations prior to use.
1.7 This international standard was developed in accordance with internationally recognized principles on standardization
established in the Decision on Principles for the Development of International Standards, Guides and Recommendations issued
by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
2. Referenced Documents
2.1 ASTM Standards:
This test method is under the jurisdiction of ASTM Committee E50 on Environmental Assessment, Risk Management and Corrective Action and is the direct
responsibility of Subcommittee E50.04 on Corrective Action.
Current edition approved June 1, 2021Feb. 1, 2024. Published August 2021March 2024. Originally approved in 2021. Last previous edition approved in 2021 as E3274–21.
DOI: 10.1520/E3274–2110.1520/E3274–24
For referenced ASTM standards, visit the ASTM website, www.astm.org, or contact ASTM Customer Service at service@astm.org. For Annual Book of ASTM Standards
volume information, refer to the standard’s Document Summary page on the ASTM website.
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
E3274 − 24
D5088 Practice for Decontamination of Field Equipment Used at Waste Sites
E3302 Guide for PFAS Analytical Methods Selection
2.2 Other Standards:
49 CFR 172 Hazardous Materials Table, Special Provisions, Hazardous Materials Communications, Emergency Response
Information, Training Requirements, and Security Plans
49 CFR 262 Standards Applicable to Generators of Hazardous Waste
Method 537 : Determination of Selected Perfluorinated Alkyl Acids in Drinking Water
3. Terminology
3.1 Definitions:
3.1.1 investigation-derived wastes, n—discarded materials resulting from field activities such as sampling, surveying, drilling,
excavation, and decontamination processes that, in present form, possess no inherent value or additional usefulness without
treatment.
3.1.1.1 Discussion—
Well development and well purge waters are considered investigation-derived waste. Soil cuttings, excess sample spoils, and
excavated soil that are returned to the borehole or excavation are not considered investigation-derived waste. The user must
determine if the regulatory authority having jurisdiction over the site, the responsible party, and property owner, permit the return
of soil cuttings and spoils to the borehole or excavation. Soil cuttings, excess sample spoils, and excavated soil that cannot be
returned to the borehole or excavation are considered investigation-derived wastes.
3.1.2 other regulated wastes, n—personal protective equipment, (for example, nitrile gloves, paper towels, polyethylene sheeting)
and decontamination fluids that may be classified as hazardous or nonhazardous wastes.
3.1.3 PFAS, n—perfluoroalkyl and polyfluoroalkyl substances are a group of man-made chemicals consisting of polymeric chains
of carbon bonded to fluorine atoms, usually with a polar functional group at the head.
3.1.4 PFAS-impacted waste, n—discarded material that contains perfluoroalkyl and polyfluoroalkyl substances and their
breakdown constituents.
3.2 Acronyms:
3.2.1 CFR—Code of Federal Regulations
3.2.2 DOT—U.S. Department of Transportation
3.2.3 EPA—U.S. Environmental Protection Agency
3.2.4 IDW—Investigation-derived waste
3.2.5 OSHA—U.S. Occupational Safety and Health Administration
3.2.6 PFAS—perfluoroalkyl and polyfluoroalkyl substances and their breakdown constituents.
3.2.7 PFOS/PFOA—Perfluorooctane Sulfonate (PFOS) / Perfluorooctanoic Acid (PFOA)
4. Significance and Use
4.1 Perfluoroalkyl and polyfluoroalkyl substances (PFAS) are a family of more than 4700 synthetic organic chemicals. PFAS can
withstand high temperatures and survive highly corrosive environments. They are used in the manufacture of coatings, surface
treatments, and specialty chemicals in cookware, carpets, food packaging, clothing, cosmetics, and other common consumer
products. PFAS also have many industrial applications and are an active ingredient in certain types of fire-fighting foams (aqueous
Available from United States Environmental Protection Agency (EPA), William Jefferson Clinton Bldg., 1200 Pennsylvania Ave., NW, Washington, DC 20460,
http://www.epa.gov.
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film-forming foams, or AFFF). PFAS coatings resist oil, grease, and water. PFAS are persistent compounds. Therefore, PFAS should
be considered for purposes of managing investigation-derived waste where PFAS is known or suspected to be present in
environmental media.
4.1.1 PFAS are emerging contaminants for which environmental regulations and guidance are dynamic and are being developed
simultaneously at federal, state, local, and international levels as more is learned about their characteristics, environmental fate,
and management/treatment. Therefore, site-specific rules, regulations, and guidance should be evaluated for options and
restrictions on management of PFASinvestigation-derived waste. For example, the Massachusetts Department of Environmental
Protection has determined that PFAS wastes are “hazardous materials” subject to the Massachusetts Oil and Hazardous Material
Release Prevention and Response Act (M.G.L. Chapter 21E) and the Massachusetts Contingency Plan. Other states and
jurisdictions may have or will develop and implement similar determinations that affect the on-site management, storage, and
labeling and off-site transportation requirements for PFASinvestigation-derived waste.
4.1.2 Given the characteristics and persistence of PFAS compounds, PFASinvestigation-derived waste presents special handling
and treatment/disposal considerations. EPA recently issued Interim Guidance on the Destruction and Disposal of Perfluoralkyl and
Polyfluoralkyl Substances and Materials Containing Perfluoralkyl and Polyfluoralkyl Substances (2020) (1) . This interim
guidance focuses on technologies for treatment and disposal that have the potential to destroy PFAS by breaking the carbon-fluorine
bonds or controlling migration of PFAS in the environment (for example, secure landfilling). Although the interim guidance focuses
on the destruction and disposal of residuals and wastes/waste byproducts from manufacturing activities, the guidance should be
considered when evaluating treatment or disposal options for PFASinvestigation-derived waste.
NOTE 1—The Department of Defense issued a new policy in July 2023 addressing the management of PFAS-contaminated material, including IDW (2).
4.1.3 PFASinvestigation-derived waste may also contain other nonhazardous or hazardous substances or materials that may impact
the options and requirements for management. The associated substances should be considered for proper characterization of the
investigation-derived waste and in selecting containerization, labeling, handling, transportation, and disposal options. (23)
4.2 Field investigation activities result in the generation of waste materials that may include PFAS.Investigation-derived waste
may include monitoring well development water, purge water, soil cuttings from boreholes, sediments, soil or fill from excavation
activities, solutions from decontaminating sampling equipment, personal protective equipment, and other sampling wastes (for
example, paper towels, plastic sheeting).
4.2.1 Soil cuttings, excess sample spoils, and excavated soil that are returned to the borehole/excavation may not be considered
investigation-derived waste on sites in jurisdictions where regulations and guidance allow for this management option.
4.2.1.1 The user must determine the disposal options for these materials in conjunction with the property owner, responsible party,
and the regulatory agency.
4.3 The primary objectives for managing investigation-derived waste during field activities include:
4.3.1 Leaving the site in no worse condition than existed before field activities,
4.3.2 Removing wastes that pose an immediate threat to human health or the environment,
4.3.3 Segregating wastes above background or threshold concentrations,
4.3.4 Complying with federal, state, local, regulations,
4.3.5 Minimizing the quantity of investigation-derived waste, and
4.3.6 Properly containerizing, managing, and disposing of investigation-derived waste.
4.4 Container Labeling:
4.4.1 In accordance with the OSHA Hazard Communication Standard (34) or other applicable jurisdictional requirements, an
The boldface numbers in parentheses refer to a list of references at the end of this standard.
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“investigation-derived waste container” or “Waste Awaiting Designation” label shall be applied to each drum, intermediate bulk
container, portable tank, or other container using indelible marking. Labeling or marking requirements for investigation derived
waste are as detailed below and should be referenced in the site’s Health and Safety Plan and Sampling and Analysis Plan.
4.4.1.1 Include the following information on labels and markings: project name, generation date, location of waste origin,
container identification number, sample number (if applicable), and contents (that is, decontamination water).
4.4.1.2 Apply each label or marking to the upper one-third of the container at least twice, on opposite sides.
4.4.1.3 Position labels or markings on a smooth part of the container. The label must not be affixed across container bungs, seams,
ridges, or dents.
4.4.1.4 Use weather-resistive material for labels and markings and permanent markers or paint pens capable of enduring the
expected weather conditions. If markings are used, the color must be easily distinguishable from the container color.
4.4.1.5 Secure labels in a manner to ensure that they remain affixed to the container.
4.4.2 Labeling or marking requirements for containers of investigation-derived waste that is determined to be hazardous material
and is expected to be transported offsite must be in accordance with the requirements of U.S. Department of Transportation (DOT)
hazardous material regulations (see 49 CFR 172). Wastes determined to be hazardous waste or subject to state, provincial, or tribal
regulation will be staged onsite in accordance with the requirements of U.S. EPA hazardous waste regulations (40 CFR 262) or
other applicable jurisdictional requirements regarding labeling and marking until disposal options are determined by the property
owner, responsible party, or the site operator.
4.5 Investigation-derived waste Container Movement Predetermine staging areas for investigation-derived waste containers in
accordance with the site’s Health and Safety Plan and Sampling and Analysis Plan. Determine the methods and personnel required
to safely transport investigation-derived waste containers to the staging area before field mobilization. Handling and transport
equipment will be consistent with the associated weight for both lifting and transporting. Transportation of investigation-derived
waste that is considered to be DOT hazardous material offsite via a public roadway is prohibited unless the requirements of 49 CFR
172 or applicable national regulations are met.
4.6 Investigation-derived waste Container Storage
4.6.1 Stage containerized investigation-derived waste awaiting results of chemical analysis at a pre-determined location on the
site.
4.6.2 Store containers such that the labels can be easily read.
4.6.3 Provide a secondary/spill container for liquid investigation-derived waste storage (for example, drums and intermediate bulk
containers shall not be stored in direct contact with the ground). In addition, liquid IDW should be staged in secondary containment
that conforms to the applicable, federal, provincial, state, or tribal regulations for hazardous waste accumulation areas.
4.6.4 The user must determine if federal, state, local, provincial, or tribal regulations impose additional requirements for the
temporary storage of investigation-derived waste, including those pertaining to storage requirements and limitations for hazardous
materials or hazardous wastes. These requirements may include periodic inspections of the containers and implementation of
stormwater pollution prevention Best Management Practices (see 5.6).
5. Additional Considerations
5.1 The characterization, containerization, labeling, ma
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