Chapter 61

SOIL AND GROUNDWATER MANAGEMENT PROGRAM

Contents

Approved by David Baskin
Revised 11/12

61.1 Policy
61.2 Scope
61.3 Applicability
61.4 Exceptions
61.5 Roles and Responsibilities
61.6 Definitions
61.7 Required Work Processes

Work Process A. General Requirements and Flowchart
Work Process B. Preparing a Soil Management Plan

61.8 Source Requirements
61.9 Reference Documents

 

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61.1 Policy

The Soil and Groundwater Management Program provides monitoring requirements and management controls to help ensure that groundwater or soil contaminants at Berkeley Lab do not adversely impact human health or the environment and that soil and groundwater is handled, stored, disposed of, or reused on site following applicable laws, regulations, and Berkeley Lab policies.

61.2 Scope

From 1992 to 2006, the Berkeley Lab Environmental Restoration Program investigated the magnitude and extent of soil and groundwater contamination that resulted from historical releases of hazardous chemicals into the environment at Berkeley Lab. The investigations were conducted under the regulatory oversight of the California Environmental Protection Agency Department of Toxic Substances Control (DTSC) in accordance with Resource Conservation and Recovery Act (RCRA) Corrective Action Plan (CAP) requirements. The results of the investigation are documented in the RCRA Facility Investigation (RFI) Report at http://www.lbl.gov/ehs/erp/html/documents.shtml. The investigations showed that volatile organic compounds (VOCs) (e.g., trichloroethylene) that had been used as cleaning solvents, and their degradation products, were present in soil or groundwater in some Berkeley Lab areas at concentrations that posed a potential risk to human health and/or the environment. Berkeley Lab implemented DTSC-approved measures to restore soil and groundwater quality to levels protective of human health and the environment.
In addition to VOCs, the following contaminants were detected in the soil or groundwater at Berkeley Lab:

• Polychlorinated biphenyls (PCBs)
• Petroleum hydrocarbons
• Polynuclear aromatic hydrocarbons (PAHs)
• Semivolatile organic compounds (SVOCs)
• Metals
• Pesticides
• Tritium and curium-244

Of these contaminants, only PCBs and metals were detected at concentrations that posed a potential risk to Berkeley Lab workers. Where the concentrations posed an unacceptable risk, the contamination was cleaned up to DTSC-approved levels for unrestricted use.
The DTSC also required Berkeley Lab to complete a Soil Management Plan and a Groundwater Monitoring and Management Plan. The Soil and Groundwater Management Program helps ensure that the institutional requirements specified in these plans are implemented.

61.3 Applicability

The Soil and Groundwater Management Program applies to the following areas:

• Activities that disturb soil and require a Permit to Penetrate Ground or Existing Surfaces of LBNL Property
• New building construction in areas where contaminated groundwater or soil is present (i.e., where there is a potential risk of exposure to contaminated soil vapor migrating into indoor air)

61.4 Exceptions

 None

61.5 Roles and Responsibilities

61.6 Definitions

61.7 Required Work Processes

Work Process A. General Requirements and Flowchart

Work Process B. Preparing a Soil Management Plan

Soil and Groundwater Management

The Soil Management Plan and the Groundwater Monitoring and Management Plan  describe required procedures for managing and disposing of contaminated waste soils (e.g., from construction excavations) and the required institutional controls to reduce potential risk to site workers from exposure to contaminants in soil and groundwater. The Groundwater Monitoring and Management Plan also provides requirements for ongoing groundwater and surface water monitoring performed by the Environment, Health, Safety, and Security’s (EHSS's) Environmental Services Group (ESG). The plans specify the following controls to reduce potential human health risks from exposure to contaminated soil and groundwater and the risk of impact to the environment:

1. Groundwater Use. Where groundwater contaminants are present, the groundwater may not be discharged to the storm drain or sanitary sewer unless in compliance with a discharge permit issued by the responsible regulatory agency.
2. Land Use. New buildings intended for human occupancy cannot be constructed in areas where indoor workers could potentially be exposed to contaminants in migrating soil vapor unless measures are implemented (e.g., building vapor barriers or completing additional cleanup) to mitigate potential risks, or additional data are collected to show that the risks are within acceptable levels.
3. Soil Penetrations. Prior to surface penetrations, a Permit to Penetrate Ground or Existing Surfaces of LBNL Property must be obtained in accordance with the requirement of Facilities' Administrative Procedure (ADMN-053). This permit requires that the responsible individual/project manager notify the ESG to initiate a preconstruction site evaluation. The ESG determines the nature and extent of any known or suspected soil contamination. Soil cleanups are completed, eliminating most known hazards to construction workers. However, if contaminated soil is unexpectedly encountered, excavation must be stopped, and the ESG must be contacted. 
4. Soil Management. Project-specific soil management plans (SMPs) are required for major Facilities Division projects. The SMPs provide roles and responsibilities; the location and extent of the area to be excavated; any known or suspected contamination; soil analytical testing requirements; requirements for managing, handling, transporting, and disposing of excavated soil; and conditions requiring stopping work and notification.
   1. Clean excavated soil will be reused on site to the extent practicable; otherwise, clean soil must be disposed of at a California-permitted landfill. Contaminated soil that is below hazardous levels must be disposed of in a California landfill that is permitted to accept the soil. Should excavated soil contain contaminants at hazardous levels or radionuclides above background, the Waste Management Group must be contacted for waste handling and disposal assistance.
5. Groundwater Extraction. Activities that may encounter contaminated groundwater must have written procedures for site monitoring, spill contingency and treatment, and discharge for any extracted groundwater. If contaminated groundwater is extracted, it must be captured and treated prior to being routed to a permitted discharge point. Discharges to the sanitary sewer must comply with provisions of the EBMUD wastewater discharge permit. Where the ESG determines a potential groundwater risk to construction workers, plans must be prepared to document worker protection and training requirements.
6. Radionuclides. A Summary of Radionuclide Investigations report was submitted to the Department of Energy (DOE) in September 2003. Based on the report, DOE determined that no corrective actions were required; however, DOE specified the following use restrictions:
   1. For two abandoned radioactive waste storage tanks under Building 74, a prohibition was placed on the release of the structure, equipment, or area from any existing controls.
   2. Release of the Building 5 former Decontamination Area, the Building 5 former Outdoor Radioactive Waste Storage Area, and the Building 4 former Radioactive Waste Storage and Staging Area to the general public was prohibited.
   3. The Building 75A Radioactive Waste Storage Area was specifically designated for reuse by the Berkeley Lab Radiation Protection Group.

61.8 Source Requirements

• 40 CFR, Parts 260-272, Resource Conservation and Recovery Act (Hazardous Waste Regulations)
• Resource Conservation and Recovery Act (42 U.S.C. Section 6901 et seq.)
• Toxic Substance Control Act (15 U.S.C. Section 2601 et seq.)
• 22 CCR, Division 4.5, Environmental Health Standards for the Management of Hazardous Waste, Sections 66001-67800.5
• California Water Code Section 13000 et seq.
• California Health and Safety Code Section 25249.5 et seq.
• Bay Area Air Quality Management District Rules and Regulations

Other Driving Requirements

• 40 CFR, Part 141, Safe Drinking Water Act
• San Francisco Bay Basin Plan and Amendments, Regional Water Quality Control Board

61.9 Reference Documents

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