Chapter 61 – Soil and Groundwater Management

DRAFT

Approved by David Baskin
Revised 9/21

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. Program Requirements
Work Process B. General Soil Management Plan – General Requirements Flowchart

61.8 Source Requirements
61.9 Reference Document

Note:
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61.1 Policy

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

61.2 Scope

From 1992 to 2006, the LBNL 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 Program (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)and their degradation products, were present in soil and/or groundwater in some Berkeley Lab areas at concentrations that posed a potential risk to human health and/or the environment. In addition to VOCs, the following contaminants were detected in the soil and/or groundwater at Berkeley Lab:

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

Of these contaminants, only PCBs and metals in the soil were detected at concentrations that posed a potential risk to Berkeley Lab workers. Where the contamination in the soil posed an unacceptable risk, the contamination was cleaned up to levels determined to be protective of site workers. Measures were also implemented to clean up VOC-contaminated groundwater that are ongoing.

As part of the RCRA CAP process, the DTSC required Berkeley Lab to complete a Soil Management Plan https://drive.google.com/file/d/1Wu99s4X45aaV2WXOPMPNx290dJ6TQ_kZ/view and a Groundwater Monitoring and Management Plan https://drive.google.com/file/d/1F5hxlLrdh_oky_nMis7NUJtoBPqZuE-F/view. The Soil and Groundwater Management Program helps ensure that the requirements specified in these plans are implemented.

Since the RCRA activities were completed in 2006, additional areas of soil, soil vapor, and groundwater contamination have been discovered as part of investigations conducted for site redevelopment. From 2010 to 2015, Berkeley Lab investigated potential subsurface contamination in and around the former Bevatron area. VOCs were detected in soil and soil vapor at concentrations exceeding regulatory screening levels protective of the health of site workers. VOCs were also detected in groundwater at concentrations exceeding maximum contaminant levels (MCLs) for drinking water. The DTSC has not yet required that Berkeley Lab implement corrective actions (e.g. cleanup) for these areas.

From 2014 through early 2017, Berkeley Lab investigated potential subsurface contamination in and around former Buildings 5, 16, 16A, 52, and 52A (the area known as “Old Town”) as part of the Old Town Demolition Project. During the investigations, PCBs and localized areas of metals and petroleum hydrocarbons were detected in the soil at concentrations that posed a potential risk to site workers. Most of the PCB-contaminated soil that posed an unacceptable risk was removed (excavated and disposed of offsite at a permitted landfill) under United States Environmental Protection Agency (EPA) oversight. In addition to the chemical contaminants, radionuclides were detected in the soil at levels that posed a potential risk to site workers. This soil was excavated and disposed of off-site. The radionuclide cleanup was overseen by the U.S. Department of Energy (DOE).

Additional areas of soil, soil vapor, and/or groundwater contamination will likely be discovered during investigations associated with future site redevelopment activities.

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 there is a potential risk from exposure to contaminated soil vapor migrating into indoor air

61.4 Exceptions

None

61.5 Roles and Responsibilities

Role	Responsibilities
Project Managers and Supervisors	Ensure that requirements of the Soil Management Plan and applicable environmental laws, regulations, and LBNL policies are followed Notify the Environmental Services Group (ESG) before disturbing soil or groundwater and request assistance in determining environmental requirements and potential human health and environmental risks that may apply to their projects Request assistance from the ESG on analytical requirements for excavated soil Request assistance from the ESG on determining acceptable soil/groundwater management, disposal, or reuse options Ensure that employees who may contact potentially contaminated soil or groundwater have the applicable training Stop work and notify ESG if contaminated soil is unexpectedly encountered
Employees	Follow requirements of the Soil Management Plan and applicable environmental laws, regulations, and LBNL policies Observe excavated soil for evidence of potential 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)	Evaluate proposed project locations to assess the nature and extent of any known or suspected contamination Oversee project compliance with requirements of the Soil Management Plan and Groundwater Monitoring and Management Plan Assist projects in determining appropriate analytical requirements for excavated soil Assist projects in assessing acceptable on-site reuse criteria and offsite 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
De minimis excavation	Excavation where the volume is 20 cubic yards (CY) or less and there is no evidence of contamination
Department of Toxic Substances Control (DTSC)	The Department within the California Environmental Protection Agency that regulates hazardous waste management and remedial actions at Berkeley Lab
East Bay Municipal Utility District (EBMUD)	The municipal wastewater treatment agency that accepts and regulates sanitary sewer discharges from Berkeley Lab
Hazardous soil or groundwater	Soil or groundwater with concentrations of hazardous substances that are above applicable federal or California hazardous waste standards
Industrial use level soil	Non hazardous soil with chemical concentrations below regulatory screening levels for LBNL workers, construction workers, and leaching to groundwater or for metals, if above, below the LBNL background level
Non-hazardous soil or groundwater	Clean soil or groundwater or soil or groundwater with concentrations of hazardous substances below applicable federal or California hazardous waste standards
Radioactive soil	Soil with concentrations of radionuclides above background levels
Residential use level soil	Non hazardous soil with chemical concentrations below regulatory screening levels for residents, construction workers, and leaching to groundwater or for metals , if above, below LBNL background levels

61.7 Required Work Processes

Work Process A. Program Requirements

The Soil Management Plan provides the requirements for managing and reusing or disposing of excavated soil and the required controls to reduce potential risk to site workers and the environment. The Groundwater Monitoring and Management Plan provides the requirements to reduce or eliminate both potential risks to human health from exposure to contaminated groundwater and potential releases of contaminated groundwater to the environment. It also provides the requirements for monitoring the areas of known groundwater contamination. The monitoring is performed by the ESG.

The plans specify the following required management controls:

Groundwater. Groundwater may not be discharged to the storm drain or sanitary sewer unless in compliance with a discharge permit issued by the East Bay Municipal Utility District for the sanitary sewer or the Regional Water Quality Control Board for the storm drain. 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.
Land Use. New buildings cannot be constructed in areas where soil vapor concentrations pose a potential risk to future building occupants unless measures approved by the DTSC are implemented (e.g.,vapor mitigation system or cleanup of contaminants) to mitigate potential risks, or additional data are collected that shows that the risks are within acceptable levels.
Soil Penetrations. Prior to surface penetrations, a Permit to Penetrate Ground or Existing Surfaces of LBNL Property must be obtained. The Permit requires that the responsible individual/project manager notify the ESG to initiate a pre-construction site evaluation of any known or suspected soil or groundwater contamination.
Soil Management. The SMP establishes policies and procedures to ensure that soil excavated at LBNL does not adversely impact human health or the environment and is handled, stored, reused or replaced on site, or disposed of off site in accordance with applicable laws, regulations, and LBNL policies. The disposition of excavated soil at Berkeley Lab falls into one or more of the following five categories based on the volume and/or concentrations of contaminants. Note that these categories do not apply to radiologically contaminated soil, which is subject to additional requirements. The general process for determining the analytical requirements required to determine acceptable soil disposition options is shown in the flowchart (Work Process B).
1. De Minimis – De minimis excavation soil can be replaced in the original excavation area without sampling.
2. Unrestricted Soil Reuse – Clean soil may be reused without restriction anywhere at Berkeley Lab.
3. Restricted Soil Reuse – Residential use level soil can be reused within the central developed area of Berkeley Lab, including at a location other than the one from which it was excavated.
4. Soil Replacement –Industrial use level soil can be replaced in the same general excavation area (e.g., the same utility trench or the same building foundation excavation) from which it was removed.
5. Soil Disposal – Soil that is not reused or replaced, including clean soil, must be transported off site for disposal at a facility that possesses a permit to accept the specific type of waste soil generated. 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.

Work Process B. General Soil Management Plan

General Requirements Flowchart

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

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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