(G) Soil Mgmt SOP.pdf

NAVAL SUBMARINE BASE NEW LONDON

OPERATING

PROCEDURE

DOCUMENT OWNER: PWD Environmental Division

AUTHORIZED BY:

Environmental Division Director

Doc ID SOIL-001

PROCEDURE: Soil Management Standard Operating Procedures (SOP)

Origin Date:

8 January 2020 Page 1 of 10

Revision Date:

24 June 2025 Revision #7

PURPOSE: To define the proper procedures for managing soil on Naval Submarine Base New London (SUBASE) for all parties performing excavation and/or importing fill to ensure compliance with applicable Federal and State laws and regulations.

ACTION: Management of excess soil should be considered at the earliest stages of planning for any project involving excavation, and soil management should be included when developing the cost estimate. In accordance with the procedures established herein, excavated soil shall be managed through reuse at the immediate project site (preferred), reuse at an industrial or commercial area within the SUBASE fence line, or disposal at a permitted, off-base disposal facility. Any soil imported for use on the base shall meet State requirements for “clean fill”.

PROCEDURES:

A. Excavated Soil Procedures

1. A “Request for Permit to Excavate” form, also known as a dig permit, shall be submitted to and approved by the Public Works Department (PWD) prior to initiating any ground-disturbing activities.

Excavation work shall be performed in accordance with the site excavation procedures identified in the dig permit and shall be recorded on the soil tracking form (Attachment 1).

2. The completed soil tracking form shall be submitted to the PWD Environmental Division (EV) Installation Restoration (IR) Program Manager within 5 days of completing excavation operations.

3. If any signs of contamination, including visible staining or chemical/petroleum odors, are noted during excavation, excavation operations shall immediately cease, and EV shall be notified.

Notification shall be made to the IR Program Manager.

4. In the event of an inadvertent discovery of archaeological deposits including human remains, monuments, artifacts, tools, or other similar archeological, Native American, or historic objects, excavation operations shall immediately cease, the site shall be secured, and EV shall be notified. Notification shall be made to the Cultural Resources (CR) Program Manager. Work activities in the area of the resource(s) shall not resume without approval from EV.

5. All excavated soil that can be reused at the immediate project site shall be placed back in the same location, i.e., excavated hole, from which it was removed. Soils reused at the immediate project site shall not require analytical testing.

6. For projects with excess soil that cannot be reused at the project site, the following procedures shall apply:

Soil Management Standard Operating Procedures

Storage and Sampling

a. Excess soil shall be placed on polyethylene sheeting and covered with polyethylene sheeting, a tarp, or an equivalent impervious material that prevents erosion and provides adequate dust control. Soils shall be labeled “Awaiting Analytical Results”, and the label shall include the excavation date. All soils awaiting analytical results shall be managed/stored as Hazardous Waste.

b. A representative sample(s) of the excess soil shall be tested for Resource Conservation and Recovery Act (RCRA) 8 metals using Toxicity Characteristic Leaching Procedure (TCLP) analyses, extractable total petroleum hydrocarbons (ETPH), and volatile organic compounds (VOCs) by a Connecticut accredited laboratory.

All analysis, methods, sample collection and frequency, etc.

shall be conducted in accordance with validated EPA methods and in accordance with the most recent version of the Department of Defense Quality Systems Manual (DoD QSM). Contact the EV Hazardous Waste Program Office for detailed requirements. Costs associated with soil testing shall be included as a project cost and will not be funded by EV.

c. If the excess soil is from a site with known Per- and polyfluoroalkyl substances (PFAS) in the soil, excess soil shall also either be tested for PFAS or managed as PFAS-impacted soil.

i. The analytical sampling must be collected by an experienced professional with a minimum of 3 years of experience dealing with PFAS sampling methods and treatment. All PFAS data must be collected per EPA standard operating procedures, analyzed by an Environmental Laboratory Accreditation Program (ELAP) certified lab, in accordance with the latest version of the DoD QSM, and using EPA method 1633. Costs associated with soil testing shall be included as a project cost and will not be funded by EV. Contact SUBASE Hazardous Waste Program Office for management and testing of PFAS-impacted soil.

Management/Disposition of Soil

a. If results show PFAS is identified in the soil, appropriate management and disposal methods shall follow the Assistant Secretary of Defense for Energy, Installations, and Environment policy, “Interim Guidance on Destruction or Disposal of Materials Containing PFAS in the U.S.”, July 11, 2023 (see https://www.acq.osd.mil/eie/eer/ecc/pfas/tf/policies.html), and applicable state-specific waste disposal regulations.

Regardless of analytical results, excess soil from a site with known PFAS substances shall not be reused on base.

b. If the results of all analytes exceed the criteria designated in Connecticut’s RCRA Contained-in Policy, the soil shall be managed as Hazardous Waste and disposed of off base in accordance with https://www.acq.osd.mil/eie/eer/ecc/pfas/tf/policies.html the SUBASE Hazardous Waste Management Plan. CT’s RCRA Contained-in Policy, updated February 2020, is posted at the end of this document.

c. If the results of all analytes are below the criteria designated in CT’s RCRA Contained-in Policy but exceed current Connecticut Remediation Standard Regulations (RSRs) direct exposure criteria for residential soil and GA pollutant mobility criteria, the soil shall be managed as non-RCRA hazardous contaminated soil and shall not be reused on base. The RSRs in effect in December 2019 are summarized in Table 1. Soil shall be transported off-base to an appropriate, permitted disposal facility.

d. If results for all analytes are below current Connecticut Remediation Standard Regulations (RSRs) direct exposure criteria for residential soil and GA pollutant mobility criteria, the excess soil meets the State requirements for reuse. Soil eligible for reuse may be placed at a location within the SUBASE main installation, pending submission to the EV IR Program Manager of the analytical results, a map denoting the project location and the proposed location for reuse, and an estimate of the volume of soil to be relocated. Excess soil shall be reused within 60 days of the excavation date. Any soil not relocated for reuse on base shall be disposed of off-base as non-regulated soil.

e. Additional IR Site Excavation Procedures may apply to project sites located within an IR site/zone, per the SUBASE Instruction 5090.25A and Section 3 of the Request for Permit to Excavate.

f. Manifests for soil transported off-base shall be coordinated through the EV Hazardous Waste Program Office. The only authorized individual who may sign the waste manifest is a representative from the SUBASE Hazardous Waste Program authorized by the ICO in writing. The receiving facility may require additional analyses not included in this SOP to meet their facility permitted acceptance criteria..

B. Imported Soil Procedures

1. All imported soil to be used on-base shall meet the requirements for “clean fill”, as defined in the Regulations of Connecticut State Agencies (RCSA) §§ 22a-209-1.

2. Documentation of the clean fill source, an estimate of the volume of soil imported, and a map depicting the location where the fill will be placed shall be provided to the EV IR Program Manager prior to soil importation or use on SUBASE.

3. If clean fill to be used on SUBASE is “treated, polluted soil,” as defined in RCSA §§ 22a-209-1, then analytical results documenting that pollutant concentrations do not exceed the GA pollutant mobility criteria and direct exposure criteria for residential soil established in the RSRs shall be provided to the EV IR Program Manager prior to soil importation or use on SUBASE.

EQUIPMENT AND MATERIALS: Sampling equipment and containers, if applicable

SAFETY EQUIPMENT: Appropriate PPE for sampling, as needed

TRAINING: Sampling for Hazardous Materials or equivalent training

POINT(S) OF CONTACT:

Name Title Email Phone

Christopher Koproski

Environmental Division Director christopher.r.koproski.civ@us.navy.mil 860- 694-

Brian Hendrickson

Hazardous Waste Program

Manager brian.g.hendrickson.civ@us.navy.mil

860- 694-

Lindsey Bidder

CR and IR Program Manager lindsey.a.bidder.civ@us.navy.mil 860- 694-

SIGNIFICANT ENVIRONMENTAL ASPECT(s): None

AUTHOR(S): Lindsey Bidder and Brian Hendrickson

APPROVED: ____________________________________

Christopher Koproski, EV Division Director

DOCUMENT REVISION HISTORY:

Original Document Issue Date: 8 January 2020

REVISION

NUMBER

REVISION

DATE

REVISION SUMMARY

1 7-Feb-20 Updated procedure A.3 (now A.4) to indicate that soil shall be reused in the same location from which it was excavated

2 17-Nov-20 Added information regarding unanticipated discoveries; updated Table 1 to correct units for GA Pollutant Mobility Criteria for metals and define acronyms

3 4-May-22 Updated analyte list in Section 5b. to reflect current standards and removed duty phone number

4 12-Dec-22 Added a soil tracking form as part of the excavation procedures

5 2-Nov-23 Updated personnel and contacts 6 18-Oct-24 Update procedure A.6.e to include PFAS language 7 24-Jun-25 Update procedure A.6 to include CT’s RCRA

Contained-in Policy and to address off-base disposal.

Update to the entire document to clarify PFAS requirements per current guidance.

Attachment 1. Soil Tracking Form

SOIL TRACKING FORM

Project Location

Estimated Quantity of Excavated Soil

Estimated Quantity

Reused at Site

Estimated Quantity of Excess Soil

Disposal Plan (check one)

Short-term Storage Location

Proposed Location for Reuse

All soil reused at project site not applicable not applicable Off-site disposal with manifest from HazWaste not applicable Sampling and analysis to support planned reuse*

Comments:

Completed by:

Submit to lindsey.a.bidder.civ@us.navy.mil within 5 days of conducting excavation operations

*Refer to requirements detailed in the SUBASE Soil Management Standard Operating Procedures

Table 1. Connecticut Remediation Standard Regulations (RSRs)

Substance

Direct Exposure Criteria for

Residential Soil (mg/kg)

GA Pollutant Mobility Criteria for Soil

(mg/kg)

Volatile Organic Substances

Acetone 500 14

Acrylonitrile 1.1 0.01

Benzene 21 0.02

Bromoform 78 0.08

2-Butanone(MEK) 500 8

Carbon tetrachloride 4.7 0.1

Chlorobenzene 500 2

Chloroform 100 0.12

Dibromochloromethane 7.3 0.01

1,2-Dichlorobenzene 500 3.1

1,3-Dichlorobenzene 500 12

1,4-Dichlorobenzene 26 1.5

1,1-Dichloroethane 500 1.4

1,2-Dichloroethane 6.7 0.02

1,1-Dichloroethylene 1 0.14 cis-1,2-Dichloroethylene 500 1.4 trans-1,2-Dichloroethylene 500 2

1,2-Dichloropropane 9 0.1

1,3-Dichloropropene 3.4 0.01

Ethylbenzene 500 10.1

Ethylene dibromide (EDB) 0.007 0.01

Methyl-tert-butyl-ether 500 2

Methyl isobutyl ketone 500 7

Methylene chloride 82 0.1

Styrene 500 2

1,1,1,2-Tetrachloroethane 24 0.02

1,1,2,2-Tetrachloroethane 3.1 0.01

Tetrachloroethylene 12 0.1

Table 1. Connecticut Remediation Standard Regulations (RSRs)

Substance

Direct Exposure Criteria for

Residential Soil (mg/kg)

GA Pollutant Mobility Criteria for Soil

(mg/kg)

Volatile Organic Substances (continued)

Toluene 500 20

1,1,1-Trichloroethane 500 4

1,1,2-Trichloroethane 11 0.1

Trichloroethylene 56 0.1

Vinyl chloride 0.32 0.04

Xylenes 500 19.5

Total Petroleum Hydrocarbons

Extractable Total Petroleum Hydrocarbons 500 500

Substance

Direct Exposure Criteria for

Residential Soil (mg/kg)

GA Pollutant Mobility Criteria by TCLP(mg/L)

RCRA-8 Metals

Arsenic 10 0.05

Barium 4,700 1

Cadmium 34 0.005

Chromium 3,900 0.05

Lead 400 0.015

Mercury 20 0.002

Selenium 340 0.05

Silver 340 0.036

Source: RCSA §§22a-133k-1—22a-133k-3 mg/kg – milligrams per kilogram mg/L – milligrams per liter RCRA – Resource Conservation & Recovery Act TCLP – Toxicity Characteristic Leaching Procedure

Connecticut’s RCRA "Contained-In" Policy

For the Characterization of Contaminated Soil, Sediment, and Groundwater

Policy

RCRA hazardous waste determinations for contaminated soil, sediment or groundwater may compare contaminant concentrations with the characterization criteria below. If the concentrations are below these criteria then the soil, sediment or groundwater do not need to be managed in Connecticut as RCRA hazardous waste. If the concentrations are above these levels then the soil/water must be treated, stored, transported, and disposed in the same manner as hazardous waste.

Purpose

To simplify the management of non-hazardous contaminated soil, sediment, and groundwater and to encourage remediation of contaminated sites.

Applicability

This policy applies to contaminated soil, sediment, and groundwater managed in Connecticut. It does not establish cleanup criteria. When contaminant concentrations are below the levels described in this policy, but are greater than applicable Connecticut Remediation Standard Regulations ("RSR") criteria, then the soil, sediment or groundwater must be handled as non-hazardous contaminated soil, sediment, or groundwater subject to applicable RSR polluted soil reuse requirements and to Connecticut solid waste requirements.

Contaminant Soil and Sediment Characterization Criteria

Groundwater Characterization Criteria

Characteristically hazardous waste " D codes"

Non-hazardous if below levels in Toxicity Characteristic Table in 40 CFR

261.24 ("TC Table")1

Non-hazardous if below levels in Toxicity Characteristic Table in 40 CFR 261.24 ("TC Table")

Listed hazardous waste "F,K,P,U codes"

See 40 CFR 261.33 for "P" & "U"

See 40 CFR 261 Appendix VII to identify constituents for which " F" & "K" wastes are listed.

Non-hazardous if below the lower of A and B:

(A) Industrial/Commercial Direct Exposure Criteria in RSR2 and

[choose one method from B]:

(B) either TC Table1 or 100 x GA Pollutant Mobility Criteria in

RSR3

or

Non-hazardous if below 100 x GA Groundwater Protection Criteria in RSR

100 x Groundwater Protection Criteria in RSR4

1. via Toxicity Characteristic Leachate Procedure ("TCLP")

2. via mass analysis

3. via mass analysis or leachate analysis

4. via leachate procedure (e.g., TCLP or Synthetic Precipitation Leachate Procedure

["SPLP"])

For more information about the application of the Contained in Policy in Connecticut, see the following:

• Characterization of Remediation Waste - Overview of Key Concepts: A PowerPoint presentation providing guidance on how to properly characterize remediation-derived waste under RCRA. See in particular slides 6 - 8.

• "Contained-In" Policy References: A list of EPA documents that elaborate on the Contained-In Policy and its application in certain particular situations.

Content Last Updated on February 14, 2020 https://portal.ct.gov/-/media/deep/waste_management_and_disposal/hazardous_waste/characterizationofremediationwastepdf.pdf?rev=f5e69d4274b240fa8848d774d49be444&hash=C2DE548FFF026D496AB103DC952531FE https://portal.ct.gov/-/media/deep/waste_management_and_disposal/remediation_waste/containedinpolicyreferencespdf.pdf?rev=62076038ca3245ffb55bbbae92053b1b&hash=6D68480F621A2E198AD20A6BFAC9519F