N40085-22-R-2691_NAVALS_1.PDF

Naval Station Great Lakes

Soils Management Plan

Naval Facilities Engineering Command Mid‐Atlantic

Public Works Department – Environmental Division

January 2020 – Revised February 2021

DOCUMENTS/RECORDS REVIEW/REVISION FORM

Naval Station Great Lakes Excavated Soils Management Plan

Date of Change

Document / Record

Version No.

# of Page

Summary of Changes

Changes By:

(Initial/Date)

Reviewed / Approved By:

28 Jan 2020 Initial 4 Original Document MTW/28 Jan 2020 PWD EV: MW

09 Mar 2020 01 4 Formatting & Text MTW/09 Mar 2020

PWD EV: MW

25 Feb 2021 02 3,4 o Added reference to

35 IAC

1100.205 o Approval clarification o Addition of analytical parameters

MTW/25 Feb 2021

PWD EV: MW

Public Works Environmental Department Points of Contact:

Heather Richtfort - Haz/NonHaz Waste - Building 221 - (847) 688-6915

Tara Lester – Storm Water – Building 1H - (847) 688-5395 X 272

Matthew Wollert – EV Operations – Building 1H – (847) 688-5395 x270

NAVSTA‐GL Excavated Soils Management Plan February 2021 (Original, Rev. 2)

1.0 Introduction & Background

The purpose of this Soil Management Plan (SMP) is to develop and establish a framework for the management of soil materials excavated within the Naval Station Great Lakes (NAVSTA‐GL) fence‐line. Other Areas of Responsibility (AORs), such as Reserve Centers, should be addressed individually in that there may be different requirements. Given the Installations long history of development, construction, demolition and various historic training activities along with limited records makes it necessary to characterize excavated soil materials prior to being removed “off‐

Station” for disposal.

This SMP provides information on and direction for managing excavated soils and various soil materials throughout NAVSTA‐GL that are not located in known “Environmental Restoration – Navy” (ER‐N) and

“Land Use Control” (LUC) sites (former known or active environmentally impacted/remediation sites). ER‐

N and LUC sites are managed separately and have specific requirements, notifications, and permitting.

Excavation or disturbance of ER‐N & LUC sites is not permitted without written authorization from the

Naval Facilities Engineering Command (NAVFAC) MIDLANT ER‐N Coordinator. MIDLANT EV maintains ER‐

N & LUC site locations on the GRX/GIS system, which is accessible by NAVFAC Public Works Department

– Environmental Division (“PWD‐EV”).

Justification for the SMP process is to limit and minimize environmental liability to the U.S. Navy and reduce financial impact to projects specific to unexpected costs associated with soil transportation and disposal. This is in addition to compliance and conformance with the United States Environmental

Protection Agency (USEPA) Resource Conservation & Recovery Act (RCRA) and Clean Water Act (CWA) in accordance with the OPNAV 5090.1 Series and the NAVSTA‐GL CO’s Environmental Policy. Note that deviation(s) from any one of these requirements can result in a Notice of Violation (NOV), Criminal

Charges, and Financial Impact to applicable parties and the Navy.

2.0 Process Instruction

2.1 Excavated Soils

Day‐to‐day, project specific construction & demolition activities at NAVSTA‐GL have the potential to require soils excavation and disposal. These activities are mission critical and must be performed to support Installation Mission Readiness and Effectiveness. Listed below are the basic procedures to follow addressing excavated soil management:

1. Determine work area where soils are to be excavated. Consult with PWD‐EV. If the proposed work area is identified within an ER‐N or LUC, the project is put on hold and must not proceed without MIDLANT ER‐N Program consultation and approval.

2. Estimate the volume of soil to be excavated and develop a project plan for temporary spoils storage/stabilization and associated costs for disposal. Note that EV does NOT receive funding for impacted and non‐impacted soil characterization (aka laboratory analysis), transportation and disposal. All associated soil characterization, stabilization/transportation and applicable disposal is considered part of the project, and is the responsibility of the Command/Tenant requiring the work to be performed.

3. Comply with the Storm Water Best Management Practices (BMPs) for each project. If the excavation area (including areas of construction that are part of the project where soils are disturbed) equals or exceeds one acre, then develop a Storm Water Pollution Prevention Plan

(SWPPP) and a Notice of Intent (NOI). Both submittals are to be reviewed by PWD‐EV (Storm Water

Program Manager) prior to submittal to the Illinois Environmental Protection Agency (IEPA) Bureau of Water (BOW). Applicable records must be maintained for Regulatory and NAVFAC‐PWD‐EV inspections/audits.

4. If soils are to be replaced in the excavation of origin, no laboratory analysis is required.

However, all storage and stabilization requirements are applicable and must be maintained.

5. In NO circumstance should excavated soil materials be mixed with soil materials from different excavations. This is to prevent mixing or co‐mingling of soil materials, which may or may not be environmentally impacted, likely causing all of the material to be handled as contaminated. Materials considered as “Construction Debris” specific to road type materials and other known demolition type activities can be exempted from this requirement. Consult with PWD‐EV on exemption determination.

6. Excavated soils selected for disposal must not be dumped/abandoned/staged at any location other that the project site or approved soil storage area within the NAVSTA‐GL fence line. All soil stabilization requirements must be met.

7. Where excavated soils are to be disposed of, a representative sample is to be collected and must undergo laboratory analysis for two (2) different determinations listed below. Allow 3‐4 weeks turnaround time for the collection and laboratory analysis.

Estimated a cost of $2,500 each for both determinations.

a. Tier Approach Clean‐up Objectives (TACO) Screen: In accordance with 35 Illinois

Administrative Code (IAC) Part 742, TACO Screen analytical parameters of regulated compounds is to be compared with the Illinois Environmental Protection Agency (IEPA)

TACO default exposure threshold limits. The Environmental Department will apply the most stringent TACO default exposure threshold limits for Residential Exposure

Pathway for comparison in supporting specific disposal options.

b. Profile/Waste Characterization Analysis: A Profile/Waste Characterization, aka

RCRA Analysis, is performed if the soil material is characterized as a regulated waste, i.e., if regulated parameters are identified in the soil materials at concentrations greater than the Illinois EPA TACO default exposure thresholds. A Profile/Waste

Characterization determines how the soil performs in a landfill environment (Hazardous versus non‐Hazardous determination). Based on this data, a ‘Waste Profile’ is considered complete to support the disposal and manifest requirements.

The analytical Profile/Waste Characterization parameters are determined on a case‐by‐ case basis, dependent on the selected disposal location. All disposal locations must be evaluated by PWD‐EV and approved prior to any disposal activities.

2.2 Imported Fill Materials

Various construction and demolition projects often require the import of engineered‐fill materials or organic tops soils. This can include common back fill for excavations, in addition to design specific materials supporting specific loads. The Navy historically has had environmental challenges with these materials due to less scrupulous material providers delivering imported materials that have environmental impacts (aka contaminated fill). Thus, the Navy and NAVSTA‐

GL set the following requirements for imported fill materials:

1. Provide “Clean Fill” Certification from source location/provider (35 IAC

1100.205(a)(1)(B), Form IL532‐2922LPC 663 Rev. 1/2019). This certification must include the specific address, drawings of the source location with sample(s) points and an engineering description of the imported soil materials.

2. Provide the certification with an analytical report of “ACTUAL MATERIAL” analysis documenting the concentration of regulated compounds to default TACO for Residential

Exposure Pathway (35 IAC Part 742). Note the reference to “ACTUAL MATERIAL” is defined as sample(s) collected from the material to be imported to NAVSTA‐GL, not from the general source area of the fill soils.

3. A laboratory sample and a report is required for every 500 cubic yards, or every 150 tons (1 ton = 2,000 lbs.).

Analytical services must be provided by a laboratory with a current IEPA/NELAC

Certification for all applicable parameters to be considered. All material laboratory analysis is to be performed with the most current United States Environmental

Protection Agency (USEPA) SW‐846 Methods. If any of the listed parameters exceed the IEPA TACO default threshold limits, the imported materials MAY NOT be brought onto or utilized at NAVSTA‐GL. The analytical TACO Screen parameters include a complete list of the following:

1) Semi‐Volatile Organic Compounds (SVOCs)

2) Volatile Organic Compounds (VOCs)

3) RCRA (23) Metals + Mercury

4) Polychlorinated Biphenyl’s

5) Pesticides/Herbicides

6) Open Cup Flashpoint

7) Paint‐Filter Test

8) pH – Reactivity

9) PFOA & PFOS

4. Note that even though analytical parameters may be reported below the default regulatory thresholds, PWD‐EV may still reject the materials based on data limitations, source location and interpretations of other constituents contained in the soils material.

EV’s decision on approval or disapproval is final.