Site Source & Uncontaminated Soil Certifications: Assessment Strategies to Minimize Costs ENVIRONMENT : INFRASTRUCTURE : DEVELOPMENT

Transcription

1 Site Source & Uncontaminated Soil Certifications: Assessment Strategies to Minimize Costs ENVIRONMENT : INFRASTRUCTURE : DEVELOPMENT

2 CCDD & Uncontaminated Soil CCDD: UNCONTAMINATED broken concrete without protruding metal bars, bricks, rock, stone, reclaimed or other asphalt pavement, or soil generated from construction/demolition activities. NOT CCDD NOT CCDD NOT CCDD

3 CCDD & Uncontaminated Soil CCDD Fill or Uncontaminated Soil Fill Operations: Permitted or registered operation that can accept fill material in a current or former quarry, mine or other excavation.

4 Soil Management Options in Illinois Private or Public Property Permitted Subtitle D Landfill Reuse Onsite Permitted CCDD or Registered Clean Fill Sites

5 Soil Management Options in Illinois Reuse Onsite Applies to site of origin No testing requirements Least expensive option Ensure property owner/contract specifications allow for this approach If test results available: Although not required, consider potential exposure pathways

6 Private or Public Property No certification requirements Less expensive option CCDD is not waste when used as fill below grade when: Fill is placed no higher than the highest point of elevation existing prior to the fill and if covered by sufficient uncontaminated soil to support vegetation within 30 days. Fill not placed in Setback Zone. Used as required fill as part of a project. Soil Management Options in Illinois

7 Permitted CCDD or Registered Clean Fill Sites Disposal costs $35 to $105/truckload Lower hauling costs Requires certification Source Site Certification by Owner or Operators (LPC-662) Uncontaminated Soil Certification by Licensed PEs & PGs (LPC-663) Painted CCDD Certifications (LPC-667) Soil Management Options in Illinois

8 Owner & Operators LPC-662 Form Owner or Operator Certify: Soil is not from a site that is potentially impacted property (PIP) Soils within a soil ph range of 6.25 to 9.0 Owner or Operator required to sign the certification form certifying soil is PRESUMED to be uncontaminated

9 Potentially Impacted Properties LPC-662 Form Properties on which a historical or current use, or contaminant from a proximate site, increases the presence or potential presence of contamination at the source site ASTM Methods (E & E ) IDOT & Toll Highway Authority Environmental Procedures (Environmental Surveys, PESAs & PSIs) Six documents incorporated by reference at 35 IAC

10 Potentially Impacted Properties LPC-662 Form Environmental Regulatory Database Reports Sanborn Fire Insurance Maps Historic City Directories Historic Aerial Photographs

11 Soil ph LPC-662 Form Measure of soil acidity or alkalinity Certify soil ph is within range of 6.25 to 9.0 units Laboratory (Method 9045C) versus field methods (reproducible)

12 PE/PG Certification LPC-663 Form Required for all sites that are potentially impacted properties (PIPs) Professional Engineer or Professional Geologist certifying soil is uncontaminated and within a ph range of Supporting documentation required to be submitted with LPC-663 Form PE or PG required to sign and seal the certification form

13 Site Investigation LPC-663 Form Historical review of area Review of regulatory environmental databases Soil screening and sampling Laboratory results Certification evaluation

14 Screening Process LPC-663 Form Process of identifying and defining areas, contaminants, and conditions at the property that warrant further attention Visual/Olfactory PID Screening

15 Sampling Process LPC-663 Form Composite: A sample comprised of soils from an entire depth profile or several locations within prescribed area Discrete: A sample from a distinct or prescribed soil depth interval or location

16 Constituents of Concern LPC-663 Form Based on subject and surrounding property historical and current uses (or requirements of CCDD Facility) Typical analyte groups: Volatile Organic Compounds (Fuel & solvents) Semi-Volatile Organic Compounds (Combustion/fuel components) Polynuclear Aromatic Hydrocarbons (Combustion By-products) RCRA Metals (Naturally Occurring & Everywhere) Pesticides/Herbicides (Agricultural/food applications) Polychlorinated Biphenyls (Cooling/hydraulic oils)

17 MACs are the lowest Tier 1 chemical-specific soil value of the exposure routes for residential and construction worker receptors set forth in 35 Ill. Adm. Code 742.Appendix B, Tables A and B Soil ingestion, outdoor inhalation, soil component of the groundwater ingestion and construction worker exposure routes Maximum Allowable Concentrations (MACs) LPC-663 Form

18 Different types of analytical methods Maximum Allowable Concentrations (MACs) LPC-663 Form Total Concentrations (e.g. total chromium) Toxic Characteristic Leaching Procedure (TCLP) or Synthetic Precipitate Leaching Procedure (SPLP) Uncontaminated Soil = Below MACs

19 Load Rejections Load rejection form Discuss option with CCDD facility contact, PE/PG and owner PID rejection possible air out Retest or delineate bad area Landfill waste characterization necessary? Load may be taken back to site until further handling requirements are determined

20 Soil Management Options in Illinois Permitted Subtitle D Landfills Most expensive disposal costs $350 to $500/truckload Limited disposal options results in higher hauling costs Different type of analytical testing (waste characterization) Soil managed as landfill cover, non-hazardous, special or nonspecial waste

21 Uncontaminated Soil vs. Landfill Analysis Landfill waste characterization NOT the same as uncontaminated soil characterization Landfill Waste Characterization used to verify wastes do not exhibit hazardous waste characteristics (ignitability, corrosivity, reactivity and toxicity) Uncontaminated Soil Characterization used to verify soils do not contain constituents of concern above MACs

22 Application Utility Improvement Project: PIP Evaluation LPC #662 versus LPC #663 Former Drycleaner Contaminants of Concern Soil Analytical Results Polk 1 Polk 2 Polk 6 Soil Management (Re-use, CCDD or landfill) Polk 3 Polk 4 Polk Non CCDD Dirt Former Gas Station Approx. 30 Truckloads of Non- Haz, Non-Spec Waste Soil Approx. $24,000 Additional Disposal Cost

23 Application Utility Improvement Project: Delineate Impacted Soils 20 Non CCDD Dirt Former Drycleaner Approx. 2 Truckloads of Non-Haz, Non-Spec Waste Soil Approx. $1600 Additional Disposal Cost Polk 1 Polk 2 Polk 2a Polk 2b Polk 3 Polk 4 Polk 5 Polk 6 Delineation Sampling Cost Approx. $2,000 Former Gas Station Project Savings $20,400

24 Application Ravenswood Station Redevelopment: A 240,000-square-foot retail center also anchored by Mariano s with a LA Fitness and Sears Auto Center Former Site Occupants: Sears Auto, Gas Station and Coal Yard Previous Phase II ESAs Identified Soil Impacts Soil from Column Pads, Footings, Utility Trenches, Stormwater Detention Budgeted for Non-Haz, Non-Spec Waste Disposal Est. 1,200 $800/load

25 Application Ravenswood Station Redevelopment: Developed Soil Management Plan to Delineate Impacts Prepared LPC #663 Defining Areas/Established Waste Profile Performed On-Site Soil PID screening During All Soil Excavation Activities Act. 240 $800/load and 960 $200/load Additional Sampling/Oversight Costs Approx. $60,000 Project Savings $566,000

26 Some Good Advice Internal screening process for project PIPs Work with an environmental professional Select potential CCDD facilities & landfills and confirm sampling requirements prior to initiating project Owner control of LPC-662 & LPC-663 evaluation process Perform sampling for landfill and uncontaminated soils at same time Delineate contaminated soils on projects

27 Brian Mihelich, CHMM Iroquois Avenue, Ste. 206 Naperville, Illinois p f ENVIRONMENT : INFRASTRUCTURE : DEVELOPMENT