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

 
NOTE:
. . . . . Denotes a new section.
. . . . . . . . Denotes the beginning of changed text within a section.
. . . . . . . . Denotes the end of changed text within a section.

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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:

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:

61.4 Exceptions

 None

61.5 Roles and Responsibilities

Role

Responsibilities

Project Managers and Supervisors

  • Ensure that environmental laws, regulations, and policies are followed
  • Request assistance from the Environmental Services Group (ESG) for technical advice on environmental requirements and potential environmental risks that apply to their projects
  • Notify the ESG before disturbing soil or groundwater
  • Request information from the ESG on soil/groundwater management requirements and/or the preparation of soil management plans (SMPs) if soil is to be disturbed
  • Provide training for employees in operational requirements for contaminated soil and groundwater, and maintain records of such training

Employees

  • Follow applicable environmental laws, regulations, and policies
  • Observe excavated soil during field operations for evidence of potential chemical contamination and immediately stop work and notify the ESG if evidence of contamination is observed
  • Complete all training required by the Job Hazards Analysis (JHA)

Environmental Services Group (ESG)

  • Develops Laboratory policies and procedures to assure that operations are conducted in an environmentally safe manner and fully comply with all applicable laws and regulations and DOE orders
  • Evaluates proposed project locations to assess the nature and extent of any known or suspected contamination
  • Assists projects in developing SMPs
  • Curtails or suspends any operations that pose an immediatedanger to members of the public or the environment
  • Determines on-site reuse criteria and disposal options for contaminated soil and groundwater

61.6 Definitions

Term

Definition

Clean soil or groundwater

Soil or groundwater containing metals at concentrations within Berkeley Lab background levels and not contaminated with hazardous organic compounds or radioactive substances

Department of Toxic Substances Control (DTSC)

The Department within the California Environmental Protection Agency that regulates hazardous waste management and remedial actions

East Bay Municipal Utility District (EBMUD)

The local municipal wastewater treatment facility that accepts and regulates sanitary sewer discharges from Berkeley Lab

Hazardous soil

Soil with detectable levels of hazardous substances that are above applicable federal and California hazardous waste standards

Nonhazardous soil

Soil with detectable levels of hazardous substances below applicable federal and California hazardous waste standards

Radioactive soil

Soil with detectable concentrations of radionuclides above background levels

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

Other Driving Requirements

61.9 Reference Documents

Document Number

Title

Type

07.10.002.001

Waste Management

Program

 

Soil Management Plan

Plan

 

Groundwater Monitoring and Management Plan

Plan

 

 

 

 

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