Att 14- Quality Control Clean Imported Fill Material.pdf

Executive Summary

This fact sheet has been prepared to ensure that inappropriate fill material is not introduced onto sensitive land use properties under the oversight of the DTSC or applicable regulatory authorities. Sensitive land use properties include those that contain facilities such as hospitals, homes, day care centers, and schools. This docu-ment only focuses on human health concerns and ecological issues are not addressed.

It identifies those types of land use activities that may be appropriate when deter-mining whether a site may be used as a fill material source area. It also provides guidelines for the appropriate types of analyses that should be performed relative to the former land use, and for the number of samples that should be collected and analyzed based on the estimated volume of fill material that will need to be used.

The information provided in this fact sheet is not regulatory in nature, rather is to be used as a guide, and in most situations the final decision as to the acceptability of fill material for a sensitive land use property is made on a case-by-case basis by the appropriate regulatory agency.

Introduction

The use of imported fill material has recently come under scrutiny because of the instances where contaminated soil has been brought onto an otherwise clean site. However, there are currently no established standards in the statutes or regulations that address environmental requirements for imported fill material.

Therefore, the California Environmental Protection Agency, Department of Toxic Substances Control (DTSC) has prepared this fact sheet to identify pro-cedures that can be used to minimize the possibility of introducing contami-nated soil onto a site that requires imported fill material. Such sites include those that are undergoing site remediation, corrective action, and closure ac-tivities overseen by DTSC or the appropriate regulatory agency. These proce-dures may also apply to construction projects that will result in sensitive land uses. The intent of this fact sheet is to protect people who live on or otherwise use a sensitive land use property. By using this fact sheet as a guide, the reader will minimize the chance of introducing fill material that may result in poten-tial risk to human health or the environment at some future time.

California Environmental

Protection Agency

It is DTSC’s mission to restore, protect and enhance the environment, to ensure public health, environmental quality and economic vitality, by regulating hazardous waste, conducting and overseeing cleanups, and developing and promoting pollution prevention.

State of California

DEPARTMENT OF TOXIC SUBSTANCES CONTROL

Information Advisory Clean Imported Fill Material

The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs, see our website at www.dtsc.ca.gov.

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October 2001

Overview

Both natural and manmade fill materials are used for a variety of purposes. Fill material properties are commonly controlled to meet the necessary site spe-cific engineering specifications. Because most sites requiring fill material are located in or near urban areas, the fill materials are often obtained from con-struction projects that generate an excess of soil, and from demolition debris (asphalt, broken concrete, etc.). However, materials from those types of sites may or may not be appropriate, depending on the proposed use of the fill, and the quality of the as-sessment and/or mitigation measures, if necessary.

Therefore, unless material from construction projects can be demonstrated to be free of contami-

Potential Contaminants Based on the Fill Source Area

Fill Source:

Land near to an existing freeway

Land near a mining area or rock quarry

Agricultural land

Residential/acceptable commercial land

Target Compounds

Lead (EPA methods 6010B or 7471A), PAHs (EPA method 8310)

Heavy Metals (EPA methods 6010B and 7471A), asbestos (polarized light microscopy), pH

Pesticides (Organochlorine Pesticides: EPA method 8081A or 8080A; Organophospho-rus Pesticides: EPA method 8141A; Chlori-nated Herbicides: EPA method 8151A), heavy metals (EPA methods 6010B and 7471A)

VOCs (EPA method 8021 or 8260B, as appropriate and combined with collection by EPA Method 5035), semi-VOCs (EPA method 8270C), TPH (modified EPA method 8015), PCBs (EPA method 8082 or 8080A), heavy metals including lead (EPA methods 6010B and 7471A), asbestos (OSHA Method

ID-191)

nation and/or appropriate for the proposed use, the use of that material as fill should be avoided.

Selecting Fill Material

In general, the fill source area should be located in nonindustrial areas, and not from sites undergoing an environmental cleanup. Nonindustrial sites in-clude those that were previously undeveloped, or used solely for residential or agricultural purposes.

If the source is from an agricultural area, care should be taken to insure that the fill does not include former agricultural waste process byproducts such as manure or other decomposed organic material.

Undesirable sources of fill material include indus-trial and/or commercial sites where hazardous ma-

*The recommended analyses should be performed in accordance with USEPA SW-846 methods (1996).

Other possible analyses include Hexavalent Chromium: EPA method 7199

Area of Individual Borrow Area

2 acres or less

2 to 4 acres

4 to 10 acres

Greater than 10 acres

Volume of Borrow Area Stockpile

Up to 1,000 cubic yards

1,000 to 5,000 cubic yards

Greater than 5,000 cubic yards

Sampling Requirements

Minimum of 4 samples

Minimum of 1 sample every 1/2 acre

Minimum of 8 samples

Minimum of 8 locations with 4 subsamples per location

Samples per Volume

1 sample per 250 cubic yards

4 samples for first 1000 cubic yards +1 sample per each additional 500 cubic yards

12 samples for first 5,000 cubic yards + 1 sample per each additional 1,000 cubic yards

Recommended Fill Material Sampling Schedule terials were used, handled or stored as part of the business operations, or unpaved parking areas where petroleum hydrocarbons could have been spilled or leaked into the soil. Undesirable commercial sites include former gasoline service stations, retail strip malls that contained dry cleaners or photographic processing facilities, paint stores, auto repair and/or painting facilities. Undesirable industrial facilities include metal processing shops, manufacturing fa-cilities, aerospace facilities, oil refineries, waste treat-ment plants, etc. Alternatives to using fill from con-struction sites include the use of fill material ob-tained from a commercial supplier of fill material or from soil pits in rural or suburban areas. How-ever, care should be taken to ensure that those ma-terials are also uncontaminated.

Documentation and Analysis

In order to minimize the potential of introducing contaminated fill material onto a site, it is necessary to verify through documentation that the fill source is appropriate and/or to have the fill material ana-lyzed for potential contaminants based on the loca-tion and history of the source area. Fill documenta-tion should include detailed information on the pre-vious use of the land from where the fill is taken, whether an environmental site assessment was per-formed and its findings, and the results of any test-ing performed. It is recommended that any such documentation should be signed by an appropri-ately licensed (CA-registered) individual. If such documentation is not available or is inadequate, samples of the fill material should be chemically ana-lyzed. Analysis of the fill material should be based on the source of the fill and knowledge of the prior land use.

Detectable amounts of compounds of concern within the fill material should be evaluated for risk in accordance with the DTSC Preliminary Endan-germent Assessment (PEA) Guidance Manual. If metal analyses are performed, only those metals (CAM 17 / Title 22) to which risk levels have been assigned need to be evaluated. At present, the DTSC is working to establish California Screen-ing Levels (CSL) to determine whether some com-pounds of concern pose a risk. Until such time as these CSL values are established, DTSC recom-mends that the DTSC PEA Guidance Manual or an equivalent process be referenced. This guid-ance may include the Regional Water Quality Control Board’s (RWQCB) guidelines for reuse of non-hazardous petroleum hydrocarbon con-taminated soil as applied to Total Petroleum Hy-drocarbons (TPH) only. The RWQCB guidelines should not be used for volatile organic compounds (VOCs) or semi-volatile organic compounds (SVOCS). In addition, a standard laboratory data package, including a summary of the QA/QC (Quality Assurance/Quality Control) sample re-sults should also accompany all analytical reports.

When possible, representative samples should be col-lected at the borrow area while the potential fill ma-terial is still in place, and analyzed prior to removal from the borrow area. In addition to performing the appropriate analyses of the fill material, an ap-propriate number of samples should also be deter-mined based on the approximate volume or area of soil to be used as fill material. The table above can be used as a guide to determine the number of samples needed to adequately characterize the fill material when sampled at the borrow site.

Alternative Sampling

A Phase I or PEA may be conducted prior to sam-pling to determine whether the borrow area may have been impacted by previous activities on the property. After the property has been evaluated, any sampling that may be required can be determined during a meeting with DTSC or appropriate regu-latory agency. However, if it is not possible to ana-lyze the fill material at the borrow area or deter-mine that it is appropriate for use via a Phase I or PEA, it is recommended that one (1) sample per truckload be collected and analyzed for all com-pounds of concern to ensure that the imported soil is uncontaminated and acceptable. (See chart on Potential Contaminants Based on the Fill Source Area for appropriate analyses). This sampling fre-quency may be modified upon consultation with the DTSC or appropriate regulatory agency if all of the fill material is derived from a common borrow area. However, fill material that is not characterized at the borrow area will need to be stockpiled either on or off-site until the analyses have been completed.

In addition, should contaminants exceeding accep-tance criteria be identified in the stockpiled fill material, that material will be deemed unacceptable and new fill material will need to be obtained, sampled and analyzed. Therefore, the DTSC rec-ommends that all sampling and analyses should be completed prior to delivery to the site to ensure the soil is free of contamination, and to eliminate un-necessary transportation charges for unacceptable fill material.

Composite sampling for fill material characteriza-tion may or may not be appropriate, depending on quality and homogeneity of source/borrow area, and compounds of concern. Compositing samples for volatile and semivolatile constituents is not accept-able. Composite sampling for heavy metals, pesti-cides, herbicides or PAH’s from unanalyzed stock-piled soil is also unacceptable, unless it is stockpiled at the borrow area and originates from the same source area. In addition, if samples are composited, they should be from the same soil layer, and not from different soil layers.

When very large volumes of fill material are antici-pated, or when larger areas are being considered as borrow areas, the DTSC recommends that a Phase I or PEA be conducted on the area to ensure that the borrow area has not been impacted by previous activities on the property. After the property has been evaluated, any sampling that may be required can be determined during a meeting with the

DTSC.

For further information, call Shahir Haddad, P.E. at

(714) 484-5368.

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