MANAGING ENVIRONMENTAL RISK FOR ROAD AND BRIDGE PROJECTS

Thomas E. Ballard Taber Consultants West Sacramento, CA

WHAT IS A HAZARDOUS WASTE?

Ò Hazardous waste possesses at least one of four characteristics: É  Ignitability É Corrosivity É Reactivity É Toxicity

Ò Or, appears on special United States Environmental Protection Agency (US EPA) lists (listed waste)

CALTRANS POLICY

Ò  Caltrans’ policy is to avoid contaminated properties, have responsible parties accept responsibility for remediation, and seek reimbursement from responsible parties when remediation and/or monitoring must be conducted.

Ò  All properties shall be investigated for contamination before being considered for incorporation into the state right-of-way.

Ò  Full policy is found in Contaminated Property Directive, PD-02.

EXCEPTIONS TO POLICY

Ò  Benefits of acquiring contaminated property can outweigh the risks or the property must be acquired in order for a project to proceed.

Ò  Exception needs approval by the Caltrans District Director or the Headquarters Chief Engineer.

Ò  Approval requires: É  An adequate site investigation É  Consideration of the cost of remediation É  Potential impacts to the project and to the state must be

understood. Ò  In these cases, every effort must be made to avoid

acceptance of legal liability and responsibility for the cost of cleanup.

INITIAL SITE ASSESSMENT (ISA) PROCESS

WHAT IS AN INITIAL SITE ASSESSMENT?

Ò The ISA identifies potential or known hazardous materials, hazardous waste, and contamination in the project area as well as the party(ies) responsible, or potentially responsible, for hazardous waste and contamination.

Ò Part of the Preliminary Environmental Study (PES) process.

STANDARDS

Ò  Caltrans Standard Environmental Reference (SER) Manual É Volume 1, Chapter 10: Hazardous Materials, Hazardous

Waste and Contamination

Ò  ASTM Standard E1527-13 É Standard Practice for Environmental Site Assessments:

Phase I Environmental Site Assessment Process

Ò  USEPA All Appropriate Inquiries (AAI) Rule É 40 CFR Part 312

WHAT TRIGGERS AN ISA?

An ISA is necessary if a project: Ò Requires acquisition of new right of way; Ò Structure modification or demolition; Ò  Includes excavation.

ELEMENTS OF AN ISA

Ò  Interviews with past and present owners, operators, and occupants

Ò  Review of historical sources of information É  environmental databases É  aerial photographs É  topographic maps É  fire insurance maps É  building department

records É  chain of title documents É  land use records

Ò  Review of government records for both the subject properties and nearby or adjoining properties

Ò  Review geology and groundwater information

Ò  Visual inspection of the subject properties and of adjoining properties

Ò  Documentation of results of the environmental inquiry in a written report

QUALIFICATIONS FOR ISA WORK

The ISA preparer must generally meet the qualifications for an “Environmental Professional” per ASTM E1527-13: Ò  PG or PE with 3 yrs experience Ò  A license or certification to perform environmental

inquiries with 3 yrs experience Ò  A college degree in engineering, environmental

science, or earth science with 5 yrs experience Ò  A college degree with 10 yrs experience

COMMON HAZARDOUS MATERIALS ISSUES

AERIALLY DEPOSITED LEAD

Ò  ADL accumulated from vehicle exhaust emissions during the period of leaded gasoline usage

Ò  Highest accumulations in area of highest traffic

Ò  Idling and acceleration also contribute to high levels of ADL

LEAD-BASED PAINT

Ò  Paint in poor condition must be sampled to determine if hazardous levels of lead are present.

Ò  Multiple generations of paint may be present

LEAD IN SOIL BELOW PAINTED SURFACES

Ò  Hazardous levels of lead can accumulate in soil below surfaces coated with lead-based paint though a leaching process over time.

Ò  Sand-blasting residue can be widely distributed

ASBESTOS-CONTAINING MATERIALS

Ò  Many building materials used in bridges have been known to contain asbestos: É  Bearing pads É  Guard rail shims É  Concrete binder É  Expansion joints

YELLOW ROAD STRIPING

Ò  Yellow paint striping can contain hazardous levels of lead.

Ò  Some white paint can also contain lead and chromium.

TREATED WOOD WASTE

Ò  Treated wood is usually chemically treated to prevent rotting over time.

Ò  Treatments can range from creosote to heavy metals such as arsenic.

NATURALLY OCCURING ASBESTOS

Asbestiform minerals occur naturally in certain geologic settings in California, most commonly in association with ultramafic rocks and along associated faults. Asbestos is a known carcinogen and inhalation of asbestos may result in the development of lung cancer or mesothelioma. Health hazards can result from activities that disturb rocks and soil containing asbestos that can generate asbestos laden dust.

OTHER HAZARDOUS MATERIALS ISSUES

CA 29 SOUTH OF MIDDLETOWN, CA - TODAY

CA 29 SOUTH OF MIDDLETOWN, CA - 2005

PAST AND PRESENT RETAIL PETROLEUM OPERATIONS

Ò  Underground Storages Tanks at gasoline stations have often leaked in the past

Ò  Chemical spills Ò  Automotive repairs can

be a source of contamination

CHEMICAL SPILLS AND STORAGE

WELLS

WELLS

AGRICULTURE – PESTICIDES

Ò  Pesticides can span a wide range of chemical types, most of which can be toxic to humans: É  Organophosphorus É  Organochlorine É  Heavy Metals

Ð  Lead Ð  Arsenic Ð  Copper

PIPELINES

Ò  Can carry a variety of petroleum products or chemicals

Ò  Often under pressure Ò  Mostly underground so

difficult to identify releases

RAILROADS

Ò  Many types of hazardous materials are transported by rail.

Ò  Derailment or spill risks Ò  Trains also leak

petroleum products Ò  Historical record review

for spills is important

RISK CATEGORIES

RISK CATEGORIES

Ò Potential to produce or cause site contamination and materials that require special handling.

Ò  Impacts to Project: É Cost É Scope É Schedule

Ò Risk of future liability to the state

HIGH RISK LAND USES/CONDITIONS

Ò  Airports Ò  Automotive Maintenance Ò  Bulk Fuel Facilities Ò  Chemical Plants Ò  Chemical Storage Ò  Computer Manufacturing Ò  Defense Dept Sites Ò  Dry Cleaners Ò  Electrical Generation Ò  Geothermal Plants

Ò  Industrial Properties +20 yrs Ò  Junk Yards Ò  Landfills Ò  Metal Plating Shops Ò  Paint Manufacturers Ò  Railroad Yards Ò  Recycling Centers Ò  Refineries Ò  Sandblasting/Leaded Glass Ò  Ship Yards Ò  Underground Storage Tanks

MEDIUM RISK LAND USES/CONDITIONS

Ò  Above Ground Storage Tanks

Ò  Aerially Deposited Lead Ò  Agricultural Fields Ò  Asbestos in Buildings Ò  Crop Dusting Operations Ò  Debris Laden Fill Ò  Gas Stations Ò  Industrial Property <20

yrs

Ò  Lead-Based Paint on Buildings

Ò  Lumber Mills Ò  Mines and Quarries Ò  Naturally Occurring

Asbestos Ò  Non-Chapter 15 Surface

Impoundments Ò  Railroad Lines

LOWER RISK LAND USES/CONDITIONS

Ò  Asbestos É  Bridges É  Retaining Walls É  Guard Rails É  Bearing Pads É  Other Structures

Ò  Lead-Based Paint É  Bridges É  Retaining Walls É  Other Structures

EXAMPLE: LUMBER MILL

Ò  Bridge replacement project

Ò  ISA identified wood waste from a former lumber mill

Ò  Required additional soil/waste pile sampling to characterize material

EXAMPLE: LUMBER MILL

Ò  Sampling program indicated low levels of dioxins in material on land proposed for right-of-way acquisition

Ò  Lesser concentrations of metals also present

EXAMPLE: MINE TAILINGS

EXAMPLE: MINE TAILINGS

Ò  ISA identified mine tailings along road and within the Area of Potential Effects

Ò  Testing conducted for arsenic, lead and mercury indicated hazardous levels of arsenic in some locations

CALTRANS STANDARD SPECIAL PROVISIONS

Ò Guidance for handling common hazardous materials during the construction phase: É Aerially deposited lead (+DTSC variance) É Naturally occurring asbestos É Lead-Based paint É Yellow traffic striping É Treated wood waste É Earth materials containing lead

PRELIMINARY SITE INVESTIGATION (PSI)

WHAT IS A PSI?

Ò  The PSI typically consists of a confirmatory investigation to determine whether suspected contamination is actually present on the property.

Ò  Usually involves physical sampling of suspected hazardous materials

PRELIMINARY SITE INVESTIGATION ELEMENTS

Ò  Site specific scope based on hazardous materials issues identified in the ISA

Ò  Materials sampling, surface sampling, subsurface sampling

Ò  Laboratory analytical data

Ò  Recommendations

PSI REPORT

Ò  Site Investigation Project Description

Ò  Site Background Ò  Investigation Methodology Ò  Data Evaluation and Discussion

É  Maps illustrating the site, physical features, boring locations, well locations, and contaminant distribution

É  Cross sections of subsurface geology and hydrologic conditions, including chemical results exceeding detection limits

É  Tabulated chemical data for all media sampled

É  Summary of laboratory results É  Boring Logs

Ò  Conclusions and Recommendations É  Documentation of the findings of the

investigation É  Potential impacts of the

contamination to the planned transportation project

É  Any further steps necessary to adequately assess the contamination

É  Mitigation issues to be considered if the contaminated property or site is included in the transportation project

Ò  Supporting Documents É  Laboratory reports É  Historical data É  Copies of permits É  Waste disposal records

DETAILED SITE INVESTIGATION (DSI)

WHAT IS A DSI?

Ò  If the PSI indicates the presence of contamination that may impact the project, but does not adequately delineate it, then a DSI is necessary.

Ò  Determines the full nature and extent of contamination so remediation costs, impacts to project scope and schedule, and future liability to the state can be realistically estimated.

DETAILED SITE INVESTIGATION PROCESS

Ò  Site specific and based on results of PSI

Ò  Usually a more extensive sampling program than a PSI

Ò  Seeks to define the limits of identified hazardous materials

Ò  May evaluate potential for remedial options, if warranted

DSI REPORT

Ò  Site Investigation Project Description Ò  Site Background Ò  Investigation Methodology Ò  Data Evaluation and Discussion

É  Maps illustrating the site, physical features, boring locations, well locations, and contaminant distribution

É  Cross sections of subsurface geology and hydrologic conditions, including chemical results exceeding detection limits

É  Tabulated chemical data for all media sampled

É  Summary of laboratory results É  Boring Logs É  Treatability testing results É  Analysis of remedial options, if

applicable

Ò  Conclusions and Recommendations É  Documentation of the findings of the

investigation É  Potential impacts of the contamination to

the planned transportation project É  Any further steps necessary to adequately

assess the contamination É  Recommended remedial options

Ò  Supporting Documents É  Laboratory reports É  Historical data É  Copies of permits É  Waste disposal records É  Pilot testing results, if applicable

QUALIFICATIONS FOR PSI AND DSI WORK

Ò Must be conducted by: É California Professional Geologist (PG) É California Professional Civil Engineer (PE)

Ò Lead-based paint requires Certified Lead Assessor

Ò Asbestos requires a Certified Asbestos Consultant

Ò Some situations may require specialized certifications

“SHELF LIFE”

CHANGING PROPERTY CONDITIONS

Ò  Hazardous materials conditions at a project site can change quickly, unlike many other aspects of the project. É New spills can occur É Tanks can begin leaking É Unauthorized dumping can occur

Ò  Any ISA over 1-year old is considered out of date and must be re-evaluated and updated as needed.

Ò  This can be an issue as the design phase can last a number of years.

KEEPING PROJECTS ON TRACK

KEYS TO KEEPING PROJECTS ON TRACK

Ò Complete hazardous materials studies early in the project before it becomes the critical path.

Ò Pre-screening can help identify issues even before the formal ISA process commences.

Ò Don’t assume rural bridges do not have hazardous materials issues.

Ò Combining the ISA/PSI process can save time and money.

THIS IS WHAT WE WANT TO

AVOID!

TTHHAANNKK YYOOUU!! Thomas E. Ballard Taber Consultants, West Sacramento, CA (916) 371-1690 tballard@taberconsultants.com