B09_Att_23_Exhibit_D_NPS_Clean_Fill_Protocol_0002.pdf

EXHIBIT D

NPS CLEAN FILL PROTOCOL

Revision Date: March 22,2020 Page 1 of 3

CLEAN FILL PROTOCOL

Clean fill shall be uncontaminated, non-water soluble, non-decomposable, inert solid material. The term includes soil, rock, stone, dredged material, and brick, block, or concrete from construction and demolition activities that is separate from other waste and recognizable as such. Clean fill must be physically similar to the native material of the destination area.

All clean fill shall be evaluated for evidence of potential contamination at the source area through due diligence. If the clean fill source is determined to be potentially suitable following due diligence, samples of clean fill shall be collected at a frequency detailed in Table 1, below, and analyzed for the following analytes at a NELAP-certified laboratory:

1. Volatile organic compounds (VOCs; EPA CLP Target Compound List) by

EPA Method 8260B or the most current version;

2. Semi-volatile organic compounds (SVOCs; EPA CLP Target Compound List) by EPA Method 8270 with SIM for polycyclic aromatic hydrocarbons or the most current version;

3. Pesticides (EPA CLP Target Compound List) by EPA Method 8081A or the most current version;

4. Polychlorinated biphenyls (PCBs; EPA CLP Target Compound List) by EPA Method 8082 or the most current version;

5. Metals (EPA 13 Priority Pollutant list) by EPA Method 6020 or the most current version;

6. Total cyanide by EPA Methods 9010/9012/9014 or the most current version;

and

7. Phenols by EPA Method 8041A or the most current version.

Analysis for cyanide and phenols is required only if identified as a likely contaminant in prospective fill material.

If additional potential contaminants of concern are identified by due diligence (e.g., land near an asbestos mine may contain elevated asbestos concentrations) or are likely to be present based on the analytical results (e.g., 1,4-dioxane could be present if 1,1,1-trichloroethane is detected), additional analysis shall be performed for the potential contaminants.

Samples shall be collected based on the specific source and required volume, as detailed in Table 1, below.

Revision Date: March 22,2020 Page 2 of 3

Table 1 Fill Material Sampling Requirements

Area of Individual Borrow Area Sampling Requirements Incremental Sampling Methodology (ISM) is preferred. 1 ISM sample shall be collected from each 1 acre area using a minimum of 40 increments. If ISM sampling is not performed, sampling shall be in accordance with the following areal requirements.

2 acres or less Minimum of 4 samples 2 to 4 acres Minimum of 1 sample every ½ acre 4 to 10 acres Minimum of 8 samples Greater than 10 acres Minimum of 8 locations with 4 subsamples per location (composites from one depth in homogenous areas is acceptable except for VOC and SVOC samples)

Volume of Borrow Area Stockpile Samples per Volume ISM is preferred. 1 ISM sample shall be collected from each 1,000 cubic yards using a minimum of 40 increments. If ISM sampling is not performed, sampling shall be in accordance with the following volumetric requirements.

Up to 1,000 cubic yards 1 sample per 250 cubic yards 1,000 to 5,000 cubic yards 4 samples for first 1,000 cubic yards + 1 sample per each additional 500 cubic yards Greater than 5,000 cubic yards 12 samples for first 5,000 cubic yards + 1 sample per each additional 1,000 cubic yards

Imported fill material may not exceed appropriately derived site-specific cleanup goals (removal or remedial goals [RGs]). In the absence of site-specific RGs, concentrations of analytes in backfill material shall not exceed the concentration limits provided in Table 2.

However, NPS, in its sole discretion exercising its professional judgment, may allow exceedances of these concentration limits under certain circumstances. In exercising this discretion, NPS will consider the following factors (and others that may be relevant):

1. The availability of backfill material that meets the Table 2 concentration limits.

2. No likely or known historical sources of contamination in the fill source area.

3. A limited number of Table 2 exceedances (1-3 analytes), all of which are circum-background for the source area soil type.

For analytes not listed in Table 2, follow current NPS Ecological Screening Value (ESV) Protocols available on CSPortal, using professional judgment with respect to source area and destination area background concentrations for naturally occurring analytes.

Acceptance of clean fill shall be documented in a report that includes the following information:

1) Clean fill source origin address and owner contact information

2) Description of clean fill source area use and host vicinity description

3) Clean fill supplier and transporter contact information

4) A description of sampling methodology and frequency, which must comply with Table 1, above

5) A list of analytes and methods, including all additional analytes

6) All laboratory results

Revision Date: March 22,2020 Page 3 of 3

7) A comparison of laboratory analytical results to the concentration limits in Table 2, the source area background concentrations, and the destination area background concentrations

8) The basis of background determinations (i.e., what informs the establishment of background concentrations for the source area or destination area)

Topsoil

Topsoil shall be fertile, natural soil, typical of the locality, substantially free of stones, roots, sticks greater than 2 inches in diameter or length, clay, peat, weeds and sod, and obtained from upland areas or be treated to be free of exotic plant seeds. It shall contain between 2 % and 10% organic matter as determined in accordance with AASHTO-194.

In addition, topsoil must meet all of the requirements of clean fill. A topsoil mixture, enriched or blended with organic compost, may be acceptable provided it meets the above defined specifications and it can be certified not to contain any waste materials (e.g., non-clean fill, sewage, or other sludge).

Adapted from: EPA Region 3 Ecologically Protective Backfill Values

Analyte* EPA EPA (mg/kg) Region 3 ReferencE Compound' (mg/kg) Region 3 Reference backfill Al nH<5.5 a Sb 2.7 b As 18.0 C

Ba 330.0 d

ACENAPHTHENE

ANTHRACENE

BENZOIAlPYRENE

BIPHENYL, 1,1-

backfill 20 e

0.1 e

0.1 e 60 e

Be 40.0 d B 0.5 e Cd 3.6 b Cr (316) 260/1300 fib Co 13.0 C

CHLOROANILINE, P-

CHLOROBENZENE

CHLOROPHENOL, 2-

DDT and metabolites

DICHLOROBENZENE, P-

20 e

0.05 e

7 e

0.21 b

20 e Cu 70.0 C

Fe 2000.0 a Pb 110.0 f Mn 220.0 C

Ho1lnor(l 0.00051 h

NI 38.0 C

Se 0.5 C

Ac 42.0 f Ti 1.0 e Sn 51.5 e V 78.0 f Zn 120.0 d CN 5.0 e

OICHLOROPHENOL, 2,4-

DICHOLOR-2-BUTENE, 1,4-

DIELDRIN

DIETHYL PHTHALATE

DIMETHYLPHTHALATE

DI-N-BUTYLPHTHALATE

DINITROPHENOL, 2,4-

ETHYL BENZENE

ETHYLENE GLYCOL

FLUORANTHENE

FLUORENE

HEXACHLOROCYCLOPENTADIENE

NAPHTHALENE

NITROBENZENE

NITROPHENOL, 2-

20 e 1000 e

0.049 b

100 e 200 e 200 e 20 e

0.05 e 97 e

0.1 e 30 e 10 e

0.1 e 40 e 7 e

NITROPHENOL, 4- 7 e References:

a - EPA Eco-SSI - Al is only considered at pH 5.5 or less b - EPA Eco-SSL Mammalian NOEC with 10 conversion factor to LOEC c- EPA Eco-SSL Plant geometric mean of NOEC and LOEC d - EPA Eco-SSL Invertebrate geometric mean of NOEC and LOEC e - EPA Region 2, Region 4, or the lower of the R2/R4 values f - EPA Eco-SSL Avian NOEC with 10 conversion factor to LOEC g - Oak Ridge National Lab NOEC with 10 conversion factor to LOEC Soil Invertebrates and Microbial Processes h - Oak Ridge National Lab PRG Wildlife

NITROSOOIPHENYLAMINE, N-

PAHs, LMW PAHs, HMW PCBs, TOTAL

PENTACHLOROBENZENE

PENTACHLOROPHENOL

PHENANTHRENE

PHENOL

PYRENE

PYRIDINE

STYRENE

TETRACHLORODIBENZOFURAN, 2,3,7,8- (TCDF1

TETRACHLORODI BENZO-P-DIOXIN, 2,3,7,8- (TCDD )

TETRACHLOROPHENOL, 2,3,4,6-

TOLUENE

TRICHLOROBENZENE, 1,2,4-

TRICHLOROPHENOL, 2,4,5-

TRICHLOROPHENOL, 2,4,6-

20 e 29 d 11 b

0.371 h 20 e 5 C

0.1 e 30 e

0.1 e

0.1 e

0.1 e

0.00084 e

0.00000315 e

20 e

0.05 e 20 e

4 e 9 e

XYLENES (TOTAL) 0.05 e

Original date of Table 1216/2011