G Environmental Specification - Soils.pdf

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ENVIRONMENTAL SPECIFICATION - SOILS

PART 1 – GENERAL

1.1 SUMMARY

A. This specification section describes Subcontractor requirements that apply to those portions of projects at

Lawrence Berkeley National Laboratory (LBNL) that include environmental protection and environmental restoration activities involving the excavation, grading, sampling, management, reuse, and/or disposal of soils, and to sampling soil vapor.

B. All activities must be planned and conducted with full regard to protecting site workers, the public, and the environment, as well as complying with all applicable environmental laws and regulations.

C. The Environmental Services Group (ESG) must review proposed documented work products, including but not limited to work packages, instructions, sampling and quality assurance plans, permit applications, and associated reports to determine if they are consistent with LBNL policies and comply with regulatory requirements.

D. The Subcontractor must provide, in the performance of LBNL environmental activities, labor, materials, equipment, services, and supervision required to conduct work in accordance with all applicable federal, state, and local environmental laws and regulations, and LBNL policies protective of public health and the environment as specified in this section.

PART 2 – PRODUCTS – Not Used

PART 3 – EXECUTION

3.1 OVERVIEW OF RELEVANT ENVIRONMENTAL REGULATIONS, LBNL DOCUMENTS, AND

SPECIFICATIONS

A. This section provides a list of potentially relevant environmental regulations, LBNL documents and procedures, and specifications pertaining to excavation, sampling, management, and/or disposal of soils and soil vapor sampling. LBNL documents can be downloaded from the LBNL website and can also be provided in electronic format upon request.

B. The Soil Management Plan for Lawrence Berkeley National Laboratory (SMP) constituents establishes the policies and procedures for non-radiological constituents to ensure that soil excavated at LBNL does not adversely impact human health or the environment and is handled, stored, reused or replaced on site, or disposed of offsite in accordance with applicable laws and regulations.

C. The LBNL Soil Management Plan – Radiological Assessment establishes requirements for soil management activities if there is the potential for radiological contamination..

3.2 ENVIRONMENTAL REGULATIONS

Potentially relevant laws and regulations that must be met during the course of a project commonly include, but are not limited to, the following.

A. Bay Area Air Quality Management District (BAAQMD) Rules and Regulations – the regulation listed below covers the requirements associated with permits related to the removal of underground storage tanks and associated contaminated soil must be met during the course of a project.

1. Regulation 8, Rule 40 – Aeration of Contaminated Soil and Removal of Underground Storage Tanks

(USTs).

B. California Code of Regulations (CCR).

1. Title 17, Division 3, Chapter 1, California Air Resources Board (ARB), Subchapter 7.5, Airborne Toxic

Control Measures (ATCM).

a. Section 93105 – ATCM for Construction, Grading, Quarrying and Surface Mining Operations.

b. Section 93106 – ATCM for Surfacing Applications.

2. Title 22, Division 4.5, Environmental Health Standards for the Management of Hazardous Waste, Chapter 11, Article 3, Characteristics of Hazardous Waste.

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a. Section 66261.24 – Characteristic of toxicity defines characteristics of solids and liquids for hazardous waste classification purposes according to California law.

3. Title 23, Division 3, State Water Resources Control Board (SWRCB) and Regional Water Quality

Control Boards (RWQCB) Porter-Cologne Water Quality Control Act and its implementing regulations.

4. Title 27, Division 2, Regulations for Treatment, Storage, Processing or Disposal of Solid Waste.

C. Code of Federal Regulations (CFR).

1. Title 29, Part 1910 – Occupational Safety and Health Standards – Hazardous Waste Operations and

Emergency Response (HAZWOPER).

2. Title 40, Chapter 1 – Solid Wastes, Subchapter I, Parts 260 to 265 - Hazardous Waste Management

3. Title 40, Chapter 1, Subchapter R –Toxic Substances Control Act (TSCA):

a. Provides authority to require reporting, record-keeping, and testing requirements and restrictions related to chemical substances and/or mixtures.

b. Part 761 – Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce and Use Prohibitions - includes PCB contamination investigation, reporting and cleanup requirements

D. California Environmental Agency Department of Toxic Substances Control (DTSC) enforcement of the

Resource Conservation and Recovery Act (RCRA).

1. Corrective Action Program (CAP) at LBNL and its implementing regulations in 40 CFR:

a. Sections of 40 CFR that pertain to RCRA and the regulatory requirements pertaining to non-hazardous waste, hazardous waste, and other RCRA regulations found in parts 239 through 282.

2. LBNL operates under a RCRA Part B Hazardous Waste Facility Permit issued by the DTSC.

E. Department of Energy (DOE) Requirements.

1. Order 231.1b – Environment, Safety, and Health Reporting

2. Order 243.1 – Records Management Program:

a. Includes a Contractor Requirements Document (CRD) that applies to "contractors that create, receive, use, maintain, disseminate, and/or dispose of DOE records in connection with the performance of DOE-funded tasks or activities.”

3. Order 414.1D – Quality Assurance and the Environmental Restoration Quality Assurance Program Plan

(QAPrP).

4. Order 436.1 – Departmental Sustainability and ISO 14001:2015 – Environmental Management

Systems.

5. Order 458.1 – Radiation Protection of the Public and the Environment.

3.3 LBNL ENVIRONMENTAL DOCUMENTS

A. The most current version of the following documents will be provided to the Subcontractor upon request to

LBNL:

1. LBNL Environmental, Health and Safety Manual, PUB-3000 – last updated on March 16, 2017.

2. RCRA Corrective Measures Study Report (CMS) and Corrective Measures Implementation Report

(CMI) at LBNL, 2005 and 2007; approved by the DTSC.

3. Annual Site Environmental Report – each September.

4. Environmental Management System Plan – March 2009.

5. Environmental Restoration Program Annual Progress Report – each February.

6. Quality Assurance Program Plan (QAPrP) for the Environmental Restoration Program – March 2016.

7. Closure Plan for hazardous waste treatment units or underground storage tanks – as needed.

8. Soil Management Plan (SMP) – December 2017; approved by DTSC.

a. References DTSC-approved screening levels for evaluating reuse, replacement and disposal of excavated soil at LBNL.

9. Soil Management Plan – Radiological Assessment – November 2017.

10. Agreement between LBNL and DOE Berkeley Site Office LBNL Implementation of DOE Metal Release

Suspension, Rev. 03 (6/30/2011).

11. Survey Levels for Volumetrically Contaminated Soil and Sediment – Document TP5030 - for radiological contamination.

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3.4 ENVIRONMENTAL SERVICES GROUP (ESG) REFERENCE PROCEDURES

A. Environmental Document Preparation – Procedure 200.

B. Drilling, Logging, Sampling, and Destroying Groundwater Wells – Procedure 231.

C. Soil Vapor Sampling and Sample Probe Installation – Procedure 238.

D. Sample Processing, Packaging, and Transport – Procedure 254.

E. Soil, Sediment, and Vegetation Sampling – Procedure 266.

F. Environmental Sample Tracking and Data Management – Procedure 268.

3.5 POTENTIALLY RELEVANT SPECIFICATIONS

A. This section provides a list of potentially relevant specifications pertaining to activities that require excavation, grading, sampling, management, reuse, and/or disposal of soils and soil vapor sampling. These include, but are not limited to:

1. DIVISION 01 – GENERAL REQUIREMENTS:

a. Section - 010000 – General Requirements

b. Section - 013500 – Special Procedures

c. Section - 013529 – Environmental Safety and Health Procedures

d. Section - 015111 – Temporary Utilities for Trailers

e. Section - 015723 – Storm Water Pollution Prevention

f. Section - 017419 – Construction Waste Management

g. Section - 019113.1 – Represented Construction Checklist

2. DIVISION 02 – EXISTING CONDITIONS:

a. Section - 024116 – Structure Demo

b. Section - 024119 – Selective Structure Demo

c. Section - 026113 – Excavation and Handling Contaminated Material

d. Section - 028200 – Asbestos Abatement

e. Section - 028300 – Lead Abatement

3. DIVISION 31 – EARTHWORK:

a. Section - 311000 – Site Clearing

b. Section - 312213 – Rough Grading

c. Section - 312316.13 – Trenching

d. Section - 312316 – Excavation

e. Section - 312323 – Backfilling

f. Section - 313500 – Slope Protection

g. Section - 314119 – Hydraugers

h. Section - 315000 – Excavation Support and Protection

4. DIVISION 32 – EXTERIOR IMPROVEMENTS:

a. Section - 329216 – Hydraulic Seeding

5. DIVISION 33 – UTILITIES:

a. Section - 333100 – Sanitary Sewer Utilities

b. Section - 334000 – Storm Drainage Utilities

6. RADIOLOGICAL PROTECTION SPECIFICATION (rev 4/26/2018)

7. HAZARDOUS, MIXED, AND RADIOACTIVE WASTE MANAGEMENT SPECIFICATION (rev

4/26/2018)

3.6 REQUIRED SUBCONTRACTOR SUBMITTALS

A. The following is a list of documents that may be required to be submitted by the Subcontractor, depending on the specific project’s needs. The documents must be consistent with the LBNL policies listed above and comply with all applicable regulatory requirements.

B. The documents will be reviewed by ESG and revised by the Subcontractor in accordance with LBNL comments.

C. If regulatory agency review is required, the Subcontractor will prepare responses to regulatory agency comments and revise the document in accordance with regulatory agency-approved responses and as directed by LBNL. All responses to regulatory agency comments and revised versions of the documents will be submitted to ESG for review and approval prior to submission to the regulatory agency by LBNL.

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D. Any deviations from the LBNL-approved documents must be justified in writing and approved by ESG prior to implementation.

E. The LBNL PM and EHS Environmental Project Coordinator must approve any written communication with regulatory agencies and an LBNL representative must be present for any verbal communication.

F. The minimum requirements for each document, if required, are specified below. Each required document must be comprehensive to comply with the most recent environmental regulations and LBNL policies listed above.

G. Potential document submittals and minimum requirements.

1. Regulatory Agency Compliance Plan

a. If requested by ESG, the Subcontractor will be required to prepare the Regulatory Agency

Compliance Plan. The Regulatory Agency Compliance Plan will describe interactions, including notification and reporting requirements, with regulatory agencies with oversight authority for the project. All environmental-related communications between the project and the regulatory agency and all documents and other correspondence must be provided to an LBNL Environmental Project

Coordinator unless otherwise specified by LBNL.

b. The Plan must include, but will not be limited to, the following information:

1. All project-specific regulatory agency compliance requirements;

2. Applicable state and federal laws, their implementing regulations and applicable regulatory agency guidance documents;

3. Permits and approvals;

4. Names, positions, and contact information for all regulatory agencies;

5. Release notification requirements and actions;

6. Required plans and reports and other deliverables, as applicable;

7. Contingency plans for non-compliance conditions;

8. Certification requirements;

9. Site access;

10. Dispute resolution as it pertains to a remedial action, Record of Decision, or other regulatory-approved project plan; and

11. Subcontractor personnel responsible for regulatory agency compliance.

2. Regulatory Agency Compliance Agreement

a. If requested by a regulatory agency, the Subcontractor will be required to prepare the Regulatory

Agency Compliance Agreement.

b. A compliance agreement with a regulatory agency such as the EPA Region 9, California DTSC, and/or the San Francisco Area Regional Water Quality Control Board and LBNL may be necessary for environmental investigation and cleanup activities that will specify the regulatory process that must be followed, including how environmental activities will be conducted and the regulatory agency interactions that will be required.

c. In coordination with LBNL and DOE, the content of the agreement will be based on lead agency requirements and the requirements specified in the LBNL radiological and/or non-radiological

SMPs.

3. Records/Data Management Plan

a. The Records/Data Management Plan provides the requirements, responsibilities, and procedures for managing records/data, including storage and transfer to LBNL, and archiving and retention time. The Plan specifies the requirements for documentation be in accordance with:

1. DOE Order 243.1, Records Management Program, which includes a Contractor Requirements

Document (CRD) that applies to "contractors that create, receive, use, maintain, disseminate, and/or dispose of DOE records in connection with the performance of DOE-funded tasks or activities."

2. DOE Order 458.1 requires that environmental radiation protection records be retained until final disposition is authorized by the DOE.

b. LBNL’s Requirements and Policies Manual, which describes LBNL’s institutional records management program, and which is consistent with all applicable laws and DOE requirements.

Records/data to be managed under this Plan include but are not limited to:

1. Work plans and reports.

2. Technical studies.

3. Risk evaluations.

4. Results of soil and sediment sampling and chain-of-custody forms.

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5. Project documents such as Quality Assurance Plans, Health and Safety Plans, and Sampling and Analysis Plans.

6. Community relations/public participation documents.

7. Comments and responses.

8. Regulatory agency approvals and decision documents.

9. Files, photographs, sampling and monitoring data, and laboratory analytical reports, including hard copies and Electronic Data Deliverables (EDDs).

c. Laboratory analysis EDDs must be in the format required by Specifications for Transmitting

Analytical and QA/QC Data from a Subcontract Analytical Laboratory to Environment, Health and

Safety Division, LBNL, April 26, 2012 (with updates).

4. Environmental Release Report

a. During the course of conducting work under this specification, should an unexpected environmental condition be encountered or an unexpected environmental release occur, an Environmental

Release Report must be prepared by the Subcontractor.

b. Reports submitted to regulatory agencies must be signed by a qualified professional approved by

ESG.

c. If an unexpected release occurs, the report must include the following, as applicable:

1. A summary of the environmental release, including the location, the material released, and the quantity of material released;

2. A description of potential or known impacts to human and environmental receptors;

3. Corrective actions taken to contain the release and media that were impacted by the release;

4. If additional investigation is required to evaluate the extent of the release; and

5. Documentation of required regulatory notifications; and

6. All sampling and analytical data.

d. If the unexpected release or condition encountered results in additional investigation, the report must also include the following, as applicable:

1. A summary of investigation results (include tables and figures that summarize sample locations and analytical results);

2. A description of the investigation, including methods and procedures and all data necessary to understand the investigation in its entirety;

3. A discussion of key decisions resolved during the investigation; and

4. A discussion of any field or laboratory condition(s) that occurred that may influence the results with summary tables documenting the condition(s) and identifying the sample(s) that may be impacted.

5. Annual Environmental Report Attachments

a. The Subcontractor must provide LBNL an annual report prepared by a qualified professional approved by ESG to be included as an attachment to LBNL’s Site Environmental Report and/or

Environmental Restoration Program Annual Progress Report, if applicable. The report must include, at a minimum:

1. All actions taken to achieve compliance with regulatory agency requirements;

2. A summary of all findings;

3. All problems or potential problems encountered and solutions;

4. All projected work for the next fiscal year;

5. A discussion of any changes in personnel that occurred during the reporting period;

6. Summaries of all contacts with representatives of regulatory agencies, the press, local community, or public interest groups;

7. The results of any sampling tests and/or other data generated, including maps showing sample locations and tables of analytical results; and

8. A discussion of any deviation from approved plan requirements, with reasons for the deviation.

6. Quality Assurance Project Plan

a. The Quality Assurance Project Plan (QAPP) provides the project quality assurance requirements for collecting and analyzing project specific environmental data involving the investigation and cleanup, if required, of soil and soil vapor contamination. The QAPP may be a component of the

Sampling and Analysis Plan.

b. The QAPP must comply with EPA Region 9 Guidance for Quality Assurance Project Plans and meet the requirements of DOE Order 414.1D Quality Assurance and the ESG Environmental

Restoration Program QAPrP.

c. The QAPP must contain, but not be limited to, the following four main elements:

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1. Program Management: Addresses program objectives, roles, and responsibilities.

2. Data Generation and Acquisition: Addresses all aspects of program data generation and describes procedures to ensure that appropriate methods for data collection or sampling;

measurement, analysis, and data generation; data handling; and quality control (QC) activities are employed and properly documented. This includes development of Data Quality Objectives

(DQOs).

3. Assessment and Oversight: Addresses the activities to assess the effectiveness of the implementation of the program and associated quality assurance (QA) and QC activities.

4. Data Review and Usability: Addresses the QA activities that occur after the data collection or generation phase.

7. Sampling and Analysis Plan

a. The Sampling and Analysis Plan (SAP) establishes the requirements for collecting environmental data for investigation and cleanup of soil and soil vapor contamination, if required.

b. Guidance for preparing a SAP is provided in EPA Region 9 Sampling and Analysis Plan Guidance and Template Version 4, General Projects R9QA/009, 1 May 2014 and the DTSC Guidance for the

Evaluation and Mitigation of Subsurface Vapor Intrusion to Indoor Air (Vapor Intrusion Guidance).

c. The SAPs must be prepared by a qualified professional approved by ESG and approved by the

Subcontractor PM, and submitted to and approved by ESG before any samples are collected.

d. As required by the SMP, a project-specific SAP must be prepared when excavating more than 100 cubic yards of soil or when soil characterization is conducted in situ. Information gathered during the historical environmental review will be used to develop a project-specific SAP.

e. Sample analysis must comply with LBNL’s policies and procedures. Contracted laboratories must provide EDDs that are compatible with LBNL’s ESM database.

f. Subcontractors must use analytical laboratories with existing contracts with LBNL. Potential exceptions require pre-approval by ESG. .

g. At a minimum, the SAP must establish DQOs and include, but not be limited to, the following for all sampling, monitoring, and analytical activities:

1. A description of the activities that require sampling and analysis;

2. Identification of the contaminants of potential concern (COPCs);

3. Sampling design, including specification of the number, locations, and depths where samples will be collected. The sampling design should in most cases include a conceptual site model that incorporates existing data and provides a basis for the sampling design;

4. Sampling and analysis approach, including description of the sampling equipment and requirements for collecting, labeling, storing, and transporting samples to the laboratory;

5. Sample analysis requirements, the analytical methods to be used, holding times, and the required reporting limits; and

6. The names, addresses, and telephone numbers of the analytical laboratories.

7. The SAP must be submitted as a stand-alone document and as such will contain relevant elements contained in the QAPP.

8. Polychlorinated Biphenyl Cleanup Plan (PCB) Cleanup Plan

a. The PCB Cleanup Plan must meet the requirements of EPA Region 9 regulations implemented by

TSCA (40 CFR, Part 761).

b. Various notification and report requirements apply to each of the options including, but not limited to:

1. Nature of the contamination;

2. Summary of sampling procedures, analytical results, dates of collection, and analyses;

3. Location and extent of contamination;

4. Cleanup plan with schedule, disposal approaches, and contingency plans; and

5. Written certification that all plans, procedures, and related documents and data are on file at the remediation location.

c. The following information is required in a PCB Cleanup Plan, at a minimum:

1. Introduction;

2. Site Characterization;

3. Risk Screening;

4. Cleanup Plan;

5. Waste Management;

6. Decontamination Procedures;

7. Location of Waste Accumulation Areas;

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8. Cleanup Verification Sampling;

9. Field Sampling Methods;

10. Health, Safety, and Environmental Protection;

11. Laboratory Analysis;

12. Data Management;

13. Data Analysis and Review;

14. Cleanup Completion Report;

15. Controls and Monitoring;

16. Recordkeeping; and

17. Schedule.

d. Written notification must be provided to the EPA 30 days prior to the date that the self-implementing or required cleanup begins. Once cleanup is underway, the EPA must be notified in writing of any changes to the proposed cleanup no less than 14 days prior to the proposed change.

e. If conducting a self-implementing PCB cleanup, Subcontractor, once authorized by LBNL, may proceed if EPA has not responded within 30 days.

f. For risk-based PCB cleanups, the work may not proceed without formal approval by EPA.

9. Plan for the Excavation and Removal of Potentially Contaminated Underground Piping

a. Underground piping must be excavated in a manner that prevents the release of potentially contaminated liquids or sediments to the environment.

b. Subcontractors involved in excavation projects that may encounter potentially contaminated underground piping must prepare a Plan for the Excavation and Removal of Potentially

Contaminated Underground Piping.

c. At a minimum, the Plan must include details describing the safe performance of the following activities:

1. Exposing the Pipe for Visual Observation;

2. Inspecting and Testing of Exposed Pipe;

3. Extracting Pipe Segments and methodology for containing leaking pipe contents;

4. Pipe and Soil Sampling, characterization, profiling, and Disposal in accordance with the SMP;

and

5. Decontamination.

10. Soil Management Report

a. The Soil Management Report documents the status of soil management activities.

b. It must be signed and stamped by a California PG in good standing with the Board of Professional

Engineers, Land Surveyors, and Geologists, or other licensed professional approved by ESG and include the following information related to soil management, at a minimum:

1. Documentation with maps, tables, and text of the locations, depths, and volumes where soil was excavated.

2. Documentation with maps, tables, and text of the locations and depths where samples were collected.

3. Documentation with maps, tables, and text of the locations and depths of any contaminated soil that was reused onsite.

4. Copies of all laboratory analytical reports, including chain-of-custody (COC) records.

5. Tables with analytical results, including detection limits.

6. Final disposition (e.g., specific disposal facility or onsite reuse location) of all excavated soil, referenced to the location where the corresponding soil was excavated.

7. Sources of and test results for any imported backfill and locations where placed.

8. Copies of all applicable soil profiling, waste acceptance applications and approvals, and waste manifests, along with transport and disposal documentation.

9. Photographic documentation (photograph and date) of soil management activities, including potential release locations from underground utilities and observations.

10. Tables listing: analytical results, soil screening levels, criteria for the acceptability of the onsite reuse of soil (less than or equal to residential screening levels), criteria for acceptability of the replacement of soil in the original excavation area (less than or equal to Industrial screening levels), and recommendations as to the acceptable disposition of soil.

c. The locations of excavations, soil sampling, and soil reuse must be accurately located and determined by either survey or other appropriate method approved by the ESG.

11. Project Specific Memoranda

a. Site Environmental Report for Project Activities:

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1. The annual report is prepared by ESG and is due to the DOE at the end of each September. It is the Subcontractor’s responsibility to provide details pertaining to project-related tasks involving soils for the previous calendar year by August 1st so that they can be included in the report.

2. The information must meet the reporting requirements of DOE Order 231.1b, Environment, Safety, and Health Reporting.

b. Environmental Restoration Program Annual Progress Report for Project Activities:

1. The Annual Progress Report is prepared by ESG and is due to the DTSC annually by the end of February and covers activities conducted during the previous fiscal year ending September

30. It is the Subcontractor’s responsibility to provide a project-specific memorandum including details pertaining to activities involving soil by December 31st for the preceding fiscal year ending September 30 so that they can be included in the report. The memorandum shall include but is not limited to, tables and figures summarizing sampling and analysis results and regulatory agency actions.

2. If work conducted is a corrective action, the information must meet the reporting requirements of LBNL’s approved RCRA Corrective Action Program.

3.7 SUBCONTRACTOR QUALIFICATION, TRAINING AND CERTIFICATION REQUIREMENTS

A. Qualifications of the assigned Subcontractor and personnel include, but are not limited to:

1. Knowledge of federal, State of California, and local environmental regulations and their applicability

(Part 3.2 above);

2. Professional California registration or applicable certification in good standing (i.e., PG or PE-Civil) as required by the regulations;

3. The Subcontractor must be properly licensed as required by the State of California. Specialty licenses may be required (e.g. C-57 drilling license).

B. Training requirements of the assigned Subcontractor and personnel include, but are not limited to:

1. If the project involves hazardous substance removal or other activities that expose or potentially expose personnel to hazardous substances and health hazards, those personnel must possess a current 40-hour HAZWOPER training certificate and have received a minimum of three days field experience under the direct supervision of a trained experienced supervisor as required under 40 CFR 1910.120.

2. Workers that are onsite only occasionally for a specific limited task (such as, but not limited to land surveying or geophysical surveying) and who are unlikely to be exposed over permissible exposure limits (PELs) must possess a current 24-hour occasional site worker HAZWOPER certificate and one day of field experience under the direct supervision of a trained, experienced supervisor.

3. The Supervisor of HAZWOPER personnel must have 8-hour HAZWOPER Supervisor training in addition to the 40-hour training.

4. All 40 and 24-hour HAZWOPER-certified personnel must also possess a current (within the last year) 8-hour HAZWOPER refresher training certification.

C. Certifications required of the assigned Subcontractor and personnel include, but are not limited to:

1. Environmental investigation and sampling work associated with the excavation, sampling, management, reuse, and/or disposal of soils and soil vapor sampling must be performed under the supervision of a

California licensed PG or a licensed California PE-Civil in good standing with the Board of Professional

Engineers, Land Surveyors, and Geologists, or licensed professional approved by ESG with requisite training and experience in conducting environmental investigations.

2. Sample locations must be surveyed either by a licensed surveyor or LBNL-approved personnel with the appropriate training in surveying and mapping.

Chemical and radiological analyses must be performed by a laboratory that is certified by both the

California State Water Resources Control Board and the Environmental Laboratory Accreditation

Program and is accredited by a third party overseen by the Department of Energy

3.8 SUBCONTRACTOR ROLES AND RESPONSIBILITIES

A. The Subcontractor is responsible for project oversight and execution of the work; verifying that work is conducted in a safe manner and meets all regulatory requirements; submitting to ESG required documents for review and approval; and preparing permit applications and/or draft notices to regulatory agencies (Part

3.10). Subcontractor must provide qualified personnel to fulfill the following roles. Depending on the size of the project, one or more of the roles may be assigned to one on-site person:

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1. Subcontractor Project Manager (PM) – The PM has responsibility for project oversight of the work plan development and implementation processes for environmental protection and restoration activities associated with excavation, management, sampling, or handling of soils and sampling of soil vapor.

2. Environmental Professional (EP) – The EP will oversee field activities, verify that all documentation is maintained, and provide input regarding field conditions that may require changes to the work plan or notification to agencies.

3.9 DOCUMENT APPROVAL PROCESS

A. All documents, whether new or adopted, must be approved by LBNL.

B. Subcontractor-prepared documents will be submitted to the LBNL Technical Representative identified by the

Contract, who will distribute documents to their selected review team.

C. Internal draft, draft, and final versions of documents are required. A response to comments table may be required for large deliverables as stipulated by LBNL.

D. Subcontractor should assume complete high-quality documents will require 10 working days for review by

LBNL; inadequate or incomplete documents will require longer review, multiple review cycles, or result in document rejection.

3.10 REQUIRED PERMITTING

Unless otherwise specified, permits will be prepared by the Subcontractor and submitted to the applicable agency by the LBNL Project Manager or ESG representative. Required permits may include, but are not limited to, the following:

A. California State Water Resources Control Board General Stormwater Permit for Construction Activities: Any construction or demolition activity, including, but not limited to, clearing, grading, grubbing, or excavation, or any other activity that results in a land disturbance of equal to or greater than 1 acre must be covered by the state’s general construction permit. The Subcontractor will prepare a Notice of Intent for permit coverage and must meet all permit requirements.

B. East Bay Municipal Utility District (EBMUD) Special Discharge Permit: Subcontractor will prepare an application to EBMUD before any discharges of water are made to the sanitary sewer. The Permit is typically needed for dewatering excavations and discharging treated water to the sanitary sewer. The legally responsible person is the Facilities Project Manager.

C. City of Berkeley Applications for Well Construction, Installation, Destruction, or Modification Permit:

Subcontractor will submit a permit application to the City of Berkeley only for the installation or decommissioning of any permanent or temporary wells or borings installed with the primary purpose of collecting hydrologic information or assessing groundwater or soil contamination.

D. A City of Berkeley Underground Storage Tank (UST) Permit: Subcontractor will prepare an application required for any work on a UST that is not just a like-for-like change-out. The City must approve the UST permit application.

E. BAAQMD:

1. UST removal and aeration of contaminated soil – BAAQMD regulates pollutant emissions from soil contaminated by organic or petroleum chemical leaks or spills and from USTs when they are removed or replaced. Prior to beginning UST removals or associated soil excavation, Tank Removal Excavation of Contaminated Soil Notification must be completed and submitted to BAAQMD.

2. Soil Vapor Extraction Operations – annual permit to operate SVE systems.