HR-SOP.pdf

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File: HR-SOP-HW-03_REV_A Page 2 of 7 Revision Date: 8/23/2017

From: NAVFAC MIDLANT Director, HW Compliance & P2

To: NAVFAC MIDLANT FEADS, Commands and Tenants at CNIC Hampton Roads Naval

Installations

Subj.: Standard Operating Procedure (SOP) – Management of Excavated and Imported Soils

1. Purpose:

NAVFAC Mid-Atlantic’s Environmental Office manages soils at Hampton Roads installations by ensuring compliance with applicable federal, state, laws, regulations, and policies.

This SOP contains guidance for the management of excavated and imported soils in the

Commonwealth of Virginia through reuse at the site of excavation, off-site disposal or off-site re-use. It is preferred that excess soil be used at the project site.

Adherence to the following soil management procedures is imperative to maintain compliance. A failure to maintain compliance can result in violations and fines.

2. References:

-Virginia Waste Management Act

-Virginia Solid Waste Management Regulations 9 VAC 20-81 et. seq.

-Virginia Hazardous Waste Management Regulations 9 VAC 20-60 et. seq.

-Virginia Department of Environmental Quality Guidance Document #LPR-SW-02-012

Titled “Solid Waste Special Waste Disposal Request” as revised

- Virginia Department of Environmental Quality Guidance Document #LPR-SW-04-2012

Titled “Management of and Reuse of Contaminated Media Guidance and Variance” as revised

-Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)

3. Applicability:

It is the responsibility of the activity to notify the Installation Hazardous Waste Media

Manager (HWMM) of soils requiring removal from or imported to project sites. The

Installation HWMM should be notified before any soils are removed or imported.

4. Action:

Due diligence is required to be conducted when any excavation is planned. It is imperative that the management of excess soil be considered at the earliest stages of project planning.

Excess soil can be managed a number of ways: it can be used within the area of the excavation, taken for disposal to an offsite appropriately permitted facility, or re-used offsite in accordance with Virginia Department of Environmental Quality Guidance Document

#LPR-SW-04-2012 Titled “Management of and Reuse of Contaminated Media Guidance and

Variance” as revised.

Every reasonable precaution shall be taken, including temporary and permanent soil stabilization measures, throughout the duration of the project to control erosion and prevent siltation of adjacent lands, rivers, stream, wetlands, lakes, and storm water conveyance

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File: HR-SOP-HW-03_REV_A Page 3 of 7 Revision Date: 8/23/2017 systems. Soil stabilization and/or erosion control measures shall be applied to erodible materials, soil stockpiles, or denuded ground surfaces exposed by any land disturbing activity.

A. Excavated Soil To Be Re-Used On-Site Only

Soils that have been excavated as part of a construction project and that are used as backfill for the same excavation or excavations containing similar contaminants at the same project site, at concentrations of the same level or higher are excluded from the definition of solid waste per the Virginia Solid Waste Management Regulations 9 VAC

20-81 et. seq.

Therefore, soils re-used on site (project site area only) are not regulated and will not require any analytical testing provided there is no free petroleum product. If during excavation of soils any visible and/or odor/smell of contamination is encountered, excavation operations should stop and the Installation Environmental Department be contacted immediately.

B. Requirements for Excavated Soil Planned For Disposal At Permitted Landfill

The Resource Conservation and Recovery Act (RCRA) requires waste generators to determine if materials intended to be discarded (disposed of) meet the definition of a solid waste, and if so, whether the solid waste is a characteristic or listed hazardous waste. The Commonwealth of Virginia has adopted all the requirements set forth under

RCRA for waste determinations. Therefore, to be in compliance with Federal and State regulations, all soils destined for disposal require a waste determination (includes generator knowledge and analytical testing) to be completed. The waste determination shall be made by the installation’s HWMM or authorized EV Services staff.

Generator knowledge (includes but is not limited to: industrial operations, releases/spills, former contamination clean-up, etc. at the project site) should be utilized whenever possible in the waste determination process, along with analytical testing. Use of generator knowledge will be the responsibility of the Navy representatives (FEADs, PMs, CMs, OICCs, etc.) who will provide the Installation HWMM and NAVFAC MIDLANT

EV Services with any historical information of the project site where soil excavation is required.

I. Excavated Soil Analytical Testing Requirements:

1) Analysis of excavated soil is required to be completed in accordance with the

Virginia Department of Environmental Quality (DEQ) guidance document #LPR-

SW-02-012 (Solid Waste Special Waste Disposal Request) which can be found at the link below:

http://deq.state.va.us/Portals/0/DEQ/Land/Guidance/LPR-SW-02-

2012.SpecialWasteDisposalRequestGuidance.pdf.

http://deq.state.va.us/Portals/0/DEQ/Land/Guidance/LPR-SW-02-2012.SpecialWasteDisposalRequestGuidance.pdf http://deq.state.va.us/Portals/0/DEQ/Land/Guidance/LPR-SW-02-2012.SpecialWasteDisposalRequestGuidance.pdf

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File: HR-SOP-HW-03_REV_A Page 4 of 7 Revision Date: 8/23/2017

Guidance document #LPR-SW-02-012 requires the following characteristics and constituents to be analyzed: ignitability, corrosivity, reactivity, TCLP (metals, VOCs, SVOCs, pesticides, and herbicides), PCBs, BTEX, TPH, TOX and Paint

Filter.

2) All analysis, methods, sample collection and frequency, etc. shall be conducted in accordance with EPA SW-846 Test Methods for Evaluating Solid Waste, Physical/ Chemical Methods.

If soil is known to be contaminated with a petroleum product, sampling frequency will be one (1) sample for every 250 cubic yards (CY) of soil. For quantities greater than 2,500 CY, the sampling rates may be adjusted with approval from

Virginia DEQ.

3) The receiving permitted disposal facility may require additional analytical requirements not covered by the Virginia DEQ guidance for their operational solid waste management facility permit requirements. Typically, the analytical parameters provided by the Virginia DEQ regulations will meet the requirements for the landfill’s permit; however, this must be verified prior to sampling.

4) Analytical laboratories are required to be Virginia Environmental Laboratory

Accreditation Program (VELAP) certified/accredited. Facilities providing

Virginia DEQ with environmental laboratory data to satisfy permit and/or regulatory requirements must ensure their environmental laboratories

(commercial or noncommercial) have been accredited or certified by Virginia

Division of Consolidated Laboratory services DCLS.

5) All analytical results must be submitted to the Installation HWMM and NAVFAC

MIDLANT EV Services for review and disposal requirements (non-hazardous vs hazardous).

II. Excavated Soil Disposal Requirements:

1) After analytical results have been reviewed and disposal requirements are determined, a waste profile (usually obtained from the permitted landfill, treatment facility, or disposal contractor) must be submitted to NAVFAC

MIDLANT EV Services for review, approval, and signature. NAVFAC

MIDLANT EV Services is the only authorized division/department with the authority to review, approve, and sign waste profile documentation for soil/waste disposal (non-hazardous or hazardous waste disposal) on behalf of the Navy; no other personnel (to include contractors) are authorized to sign waste profiles.

Please allow up to 15 business days for analytical review and approval, and signature for waste profile.

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File: HR-SOP-HW-03_REV_A Page 5 of 7 Revision Date: 8/23/2017

2) Each disposal shipment (haul truck, bulk container, etc.) from the installation to the permitted landfill or treatment facility must be accompanied with the proper shipping documents (non-hazardous or hazardous waste manifests, etc.).

NAVFAC MIDLANT EV Services is the only authorized division/department to sign any and all shipping documents on behalf of the Navy; no other personnel (to include contractors) are authorized to sign. Coordination must be made with

NAVFAC MIDLANT EV Services at 757-341-0412 or 0460 to obtain proper generator information and signature for shipping documents.

III. Management Requirements for Excavated Soil to Be Disposed Of:

1) Soils that are determined to be non-hazardous or hazardous waste may only be accumulated for up to 90 days at the generating project site in an appropriate container without obtaining a solid waste or hazardous waste management storage permit.

a. At a minimum, the “container” may be constructed on-site using poly sheeting plastic liner and cover that utilizes hay bales or other sediment control measures to minimize sediment discharge by storm water run-off.

b. The soil may also be containerized in drums or roll-offs that are covered.

2) All accumulation areas (including containers) must be properly labeled. Prior to making a waste determination the container must prominently display a sign or label stating “Waste Pending Analysis” and include an accumulation start date.

3) If project site soils are determined to be hazardous, the contractor and Navy representatives are required to contact the Installation HWMM immediately for additional soil storage and handling requirements.

IV. Imported Fire Ant Quarantine:

The counties of James City and York, and the cities of Chesapeake, Hampton, Newport News, Norfolk, Poquoson, Portsmouth, Suffolk, Virginia Beach, and

Williamsburg are currently located within an Imported Fire Ant quarantine area.

Regulated articles (including soil) can be moved freely within the quarantine area;

however, regulated articles may not be moved outside of the quarantine area unless they have been certified free of Imported Fire Ants by the Virginia Department of

Agriculture and Consumer Affairs. More information is available at:

http://www.vdacs.virginia.gov/plant-industry-services-fire-ant-suppressioneand-eradication.shtml http://www.vdacs.virginia.gov/plant-industry-services-fire-ant-suppressioneand-eradication.shtml http://www.vdacs.virginia.gov/plant-industry-services-fire-ant-suppressioneand-eradication.shtml

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File: HR-SOP-HW-03_REV_A Page 6 of 7 Revision Date: 8/23/2017

C. Requirements for Excavated Soil To Be Used As “Clean” Fill Outside The Original

Project Site

All soils excavated from a Navy installation/facility are considered to be potentially contaminated, and proper due-diligence (to include generator knowledge and analytical testing) will be required for any excavated soil to be considered for re-use outside of a project site.

Excavated soils from a project site to be re-used at a different project site location will be required to meet the Virginia DEQ's Management and Reuse of Contaminated Media

Guidance and Statewide Variance (contained under Virginia Variance #LPR-SW-04-

2012). Coordination with the Installation HWMM is required for proper guidance. LPR-

SW-04-2012 is enclosed as Attachment 1.

All contract requirements associated with the management of excavated soils on a project site must be reviewed and any changes/modifications to contract requirements must be approved by the contracting officer or his/her designee.

D. Requirements for Soils Imported From Off-Site Location For Use As “Clean” Fill

Material

It is recommended that if a project site requires the importation of soils from off-site locations (e.g. borrow pits) for backfilling excavations, grading, restoration, etc., the imported soils be verified “clean” via analytical testing.

Analytical testing requirements for imported soil provided below do not apply to

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) remedial sites. Remediation activities at CERCLA remedial sites are overseen by EPA and

Virginia DEQ; therefore, analytical requirements are pre-determined, reviewed, and approved by EPA and Virginia DEQ.

I. Imported Soil Analytical Recommendations:

1) Analytical sampling requirements should be in accordance with the Virginia DEQ's

Management of and Reuse of Contaminated Media Guidance (contained under Virginia

Variance #LPR-SW-04-2012) which are included as attachment 1.

a. All constituents/parameters displayed on Table 2 (Soil: Residential and Other

High Frequency Receptors) provided in Variance #LPR-SW-04-2012 are recommended for analysis.

b. Soils should not contain concentrations of analytes above the appropriate criteria displayed in Table 2 (Soil: Residential and Other High Frequency Receptors).

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File: HR-SOP-HW-03_REV_A Page 7 of 7 Revision Date: 8/23/2017

2) In addition to Table 2 constituents listed above, the soil should also be analyzed for TPH, BTEX, and TOX to ensure the imported soils are not contaminated with petroleum products per Virginia regulation 9VAC20-81-660.

Soils should not contain concentrations of analytes above the appropriate criteria set forth in Virginia regulation 9VAC20-81-660.

3) All analysis, methods, sample collection and frequency, etc. should be conducted in accordance with EPA SW-846 Test Methods for Evaluating Solid Waste, Physical/

Chemical Methods.

4) Analytical laboratories are required to be VELAP certified/accredited. Laboratories must provide documentation (e.g. certification number) upon request.

5) All analytical results should be submitted to the Installation HWMM for review and approval prior to importing soil to the project site.

Attachment 1

HR-SOP-HW-03