I Soil Management Plan for Lawrence Berkeley National Laboratory Rev. 1 12_2017.pdf

Soil Management Plan for Lawrence Berkeley National Laboratory

Prepared by:

Environment/Health/Safety Division

Environmental Services Group

Revision: 01

December 2017

Abbreviations

AOC Area of Concern

Berkeley Lab Lawrence Berkeley National Laboratory

BMP best management practice

CAP Corrective Action Program

CCR Code of California Regulations

CMI Corrective Measures Implementation

CMS Corrective Measures Study

COC contaminant of concern

COPC chemical of potential concern

CY cubic yard(s)

DCA dichloroethane

DCE dichloroethene

DOE U.S. Department of Energy

DQO data quality objective

DTSC Department of Toxic Substances Control

DTSC-SL DTSC-Modified Screening Level

EHS Environment, Health and Safety (Division)

EIR Environmental Impact Report

EPA U.S. Environmental Protection Agency

ESL Environmental Screening Level

HHRA Human Health Risk Assessment

IFB indistinguishable from background

LBNL Lawrence Berkeley National Laboratory

LRDP Long Range Development Plan

MCL maximum contaminant level

PAH polynuclear aromatic hydrocarbon

PCB polychlorinated biphenyl

PCE tetrachloroethene

PDF portable document format (Adobe Acrobat)

PRG Preliminary Remediation Goal

QAPP Quality Assurance Program Plan

RCRA Resource Conservation and Recovery Act

RFA RCRA Facility Assessment

RFI RCRA Facility Investigation

RSL Regional Screening Level

RWQCB Regional Water Quality Control Board

SAP Sampling and Analysis Plan

SMP Soil Management Plan

SVOC semivolatile organic compound

SWMU Solid Waste Management Unit

SWPPP Stormwater Pollution Prevention Plan

TCA trichloroethane

TCE trichloroethene

TCLP Toxicity Characteristic Leaching Procedure

TPH total petroleum hydrocarbons

TSCA Toxic Substances Control Act

UC University of California

UCL upper confidence limit

VOC volatile organic compound

WET Waste Extraction Test

Contents

1 Introduction

1.1 Purpose

1.2 Scope

2 Background

2.1 Site Description

2.2 RCRA Corrective Action Program

2.2.1 RCRA Facility Assessment

2.2.2 RCRA Facility Investigation

2.2.3 Corrective Measures Study and Implementation

2.2.4 Activities Conducted Since Corrective Measures Implementation

2.2.5 Release Reporting Requirements

3 Discussion of Key Terms

3.1 General Definitions

3.2 Soil Classification Definitions

4 Land Use and Land Use Restrictions

4.1 Land Use

4.2 Land Use Restrictions

5 Classifying Soil for Replacement, Reuse, and Disposal

5.1 Soil Disposition

5.2 Data Quality Objectives Process

5.2.1 Problem Statement

5.2.2 Soil Management Plan Goals

5.2.3 Required Information

5.2.4 Study Boundaries

5.2.5 Analytical Approach

5.2.6 Performance Criteria

5.3 Method for Selecting Soil Classification Levels

5.4 Soil Screening Process

5.4.1 Step 1 – Historical Environmental Review

5.4.2 Step 2 – De Minimis Project Determination

5.4.3 Step 3 – Characterize Soil

5.4.4 Step 4 – Compare to Reuse/Replacement Levels

6 Soil Management Requirements

6.1 Excavation and Construction Activities

6.2 Preconstruction Evaluation of Soils

6.3 Management of Excavated Soil

6.4 Management of Soil Reuse and Soil Replacement Areas

6.5 Record Keeping

7 References

List of Tables

Table 1 Summary of Soil Units

Table 2 Screening Levels for Common Contaminants for Classification of Soil as Clean, for Soil Reuse, for Soil Replacement, or as Hazardous Waste

Table 3 Clean Soil, Soil Reuse, and Soil Replacement Levels for Common Contaminants Table 4 Minimum Number of Soil Samples Required for Soil Classification

List of Figures

Figure 1 Site Map and Topography, Lawrence Berkeley National Laboratory Figure 2 Locations of Chemical Soil Units, Lawrence Berkeley National Laboratory Figure 3 Location of Central Developed Area, Lawrence Berkeley National Laboratory Figure 4 Locations of Units Restricted to Institutional Land Use Figure 5 Landscape Framework Plan Figure 6 Bedrock Geologic Map, Lawrence Berkeley National Laboratory Figure 7 Flowchart for Characterizing Soil for Reuse, Replacement, or Disposal Figure 8 Flowchart for Classifying Soil Based on Sampling Data Figure 9 Locations of Volatile Organic Compounds in the Soil Figure 10 Locations of Polychlorinated Biphenyls (PCBs) in the Soil Figure 11 Locations of Petroleum Hydrocarbons (TPH) in the Soil Figure 12 Locations of Other Contaminants in the Soil

List of Appendices

Appendix A Method for Estimating Soil Concentrations Based on Partitioning from Soil Vapor

1 Introduction

1.1 Purpose

The Soil Management Plan (SMP) establishes policies and procedures to ensure that soil excavated at Lawrence Berkeley National Laboratory (LBNL, Berkeley Lab) does not adversely impact human health or the environment and is handled, stored, reused or replaced on site, or disposed of off site in accordance with applicable laws and regulations. The plan provides clear and consistent criteria for determining the requirements for the soil management process.

This document is a revision of the SMP that was approved by the California Environmental Protection Agency’s Department of Toxic Substances Control (DTSC) in 2006 (LBNL, 2006a). The 2006 SMP was prepared to comply with requirements of the Corrective Measures Implementation (CMI) phase of the Resource Conservation and Recovery Act (RCRA) Corrective Action Program (CAP) at Berkeley Lab.

1.2 Scope

This document discusses soil management activities for potentially contaminated soil that may fall under the regulatory oversight of DTSC, the U.S. Environmental Protection Agency (EPA), and/or the Regional Water Quality Control Board (RWQCB). The following topics relevant to soil management at Berkeley Lab are described:

• The general distribution of known soil contaminants.

• Institutional controls that reduce potential impacts to human health and the environment from exposure to soil contaminants.

• Requirements for the on-site management of soils generated during demolition, construction, maintenance, and other activities that disturb soil.

• Sampling and analysis requirements and criteria for the on-site reuse, on-site replacement, or off-site disposal of soils generated during activities that disturb soil.

Requirements for the management of radiologically contaminated soil at Berkeley Lab are under the jurisdiction of the U.S. Department of Energy (DOE). Requirements specific to radiological contamination are therefore not governed by this document but are provided in the Soil Management Plan – Radiological Sampling and Analysis Plan (LBNL, 2017b), which complies with DOE requirements.

Management of soil excavated from an area undergoing a cleanup action under regulatory oversight may be subject to the requirements of a project-specific SMP or other governing document that must be approved by DTSC or other regulatory agencies. The requirements of such project-specific SMPs would supersede those described in this document.

2 Background

2.1 Site Description

Berkeley Lab is a scientific research campus operated by the University of California (UC) for DOE.

Beginning with a focus on nuclear physics research in the 1940s, Berkeley Lab has grown into a multidisciplinary scientific research facility that supports research in the physical, energy, life, and environmental sciences and high-performance computing. It is located on a 202-acre parcel of UC Regents’ land in the East Bay Hills in Alameda County, California, straddling the border between the cities of Berkeley and Oakland. A map showing the locations of site buildings, creeks, and surface topography is provided as Figure 1. The site physiography, geology, and hydrogeology are described in the RCRA Facility Investigation Report (LBNL, 2000).

2.2 RCRA Corrective Action Program

Berkeley Lab’s Hazardous Waste Handling Facility operates under a RCRA Part B Hazardous Waste Facility Permit issued by DTSC. The permit issued in 1993 required Berkeley Lab to investigate and address releases of hazardous waste and hazardous constituents in accordance with the RCRA CAP requirements.

The RCRA CAP has four primary components, each of which is discussed briefly in this section as it pertains to Berkeley Lab:

• RCRA Facility Assessment (RFA)

• RCRA Facility Investigation (RFI)

• Corrective Measures Study (CMS)

• Corrective Measures Implementation (CMI)

The areas of soil contamination that were addressed in the RFA, RFI, CMS, and CMI, including Solid Waste Management Units (SWMUs) and Areas of Concern (AOCs), are listed in Table 1, along with their status. The table also lists soil contamination areas that were discovered after the DTSC-approved corrective measures for soil were completed. The SWMUs, AOCs, and other areas of soil contamination are collectively referred to in this SMP as “units.” Table 1 provides the following information about these units:

• Page numbers of the reports that reference the units (LBNL, 1992, 1994, 1995b, 2000, 2003a, 2005).

• Whether the unit was determined to be acceptable for unrestricted use or whether it should be restricted to institutional land use.

• The specific soil contaminants detected.

The locations of the units are shown on Figure 2.

Background Soil Management Plan

2.2.1 RCRA Facility Assessment

The RFA was completed in 1992. Its purpose was to identify SWMUs and AOCs at Berkeley Lab that were the source of known releases of hazardous waste and hazardous constituents or had the potential for past or future releases. The RFA found that hazardous waste or hazardous constituents had been released to soil and groundwater at a number of units.

2.2.2 RCRA Facility Investigation

The RFI was conducted between October 1992 and September 2000. It identified the source and nature of contaminants that had been released to the environment at identified units, and it characterized the magnitude and extent of those releases. The RFI was divided into three phases, each documented in a report, as follows:

• RCRA Facility Investigation Phase I Progress Report (LBNL, 1994)

• RCRA Facility Investigation Phase II Progress Report (LBNL, 1995b)

• RCRA Facility Investigation Report (LBNL, 2000)

As described in the RFI reports, the principal chemical contaminants detected in the soil and groundwater at Berkeley Lab are chlorinated volatile organic compounds (VOCs) and polychlorinated biphenyls (PCBs). The chlorinated VOCs include tetrachloroethene (PCE); trichloroethene (TCE); carbon tetrachloride; 1,1,1-trichloroethane (TCA); and associated degradation products. Other contaminants detected in soil include petroleum hydrocarbons and metals, and to a much lesser extent, semivolatile organic compounds (SVOCs) and polynuclear aromatic hydrocarbons (PAHs).

The RFI used a screening process to determine which units required further action. The screening involved comparing the maximum concentration of each chemical detected in soil at each unit to the California-modified Preliminary Remediation Goals (PRGs) and EPA Region 9 PRGs for residential soil.

Concentrations of naturally occurring inorganic elements were also compared to LBNL background levels for soil (LBNL, 1995a). Units that failed the screening process were assessed in the Human Health Risk Assessment for the Lawrence Berkeley National Laboratory, Environmental Restoration Program (“HHRA”) (LBNL, 2003a).

2.2.3 Corrective Measures Study and Implementation

The initial phase of the CMS consisted of preparing the HHRA and an ecological risk assessment for chemicals (LBNL, 2002). The HHRA estimated the risk to human health for each unit that failed the screening process and for four units that passed the screening process but that were added because either additional samples that were collected after the RFI exceeded PRGs, or PRG values for some chemicals had been revised. The HHRA risk estimates were based on an industrial/institutional use scenario for Berkeley Lab that is considered to represent both the current use and the reasonable and likely future use for the facility. The units evaluated in the HHRA are noted in Table 1.

The HHRA concluded that the following four areas of soil contamination posed a potential risk to the health of institutional workers:

• Building 88 Hydraulic Gate Unit (AOC 6-3)

Background Soil Management Plan

• Building 75 Former Hazardous Waste Handling and Storage Facility (SWMU 3-6)

• Building 7 Sump (AOC 2-5)

• Building 51L Groundwater Solvent Plume Source Area (not designated)

The RCRA Corrective Measures Study Report for the Lawrence Berkeley National Laboratory, Environmental Restoration Program (“CMS Report”) (LBNL, 2005) recommended that contaminated soils in these four areas be excavated and disposed of at a permitted off-site disposal facility. Cleanups of the Building 88 Hydraulic Gate Unit and Building 75 former Hazardous Waste Handling and Storage Facility were completed as Interim Corrective Measures in 2004. Cleanups of the Building 7 Sump and the Building 51L Groundwater Solvent Plume Source Area were completed as corrective measures under the CMI in 2006 (LBNL, 2007b).

2.2.4 Activities Conducted Since Corrective Measures Implementation

Since the corrective measures documented in the RCRA Corrective Measures Implementation (CMI) Report (LBNL, 2007b) were implemented, additional soil, soil vapor, and groundwater contamination has been detected in several other areas of Berkeley Lab at concentrations exceeding regulatory screening levels. The discovery of these areas, which include the former Building 51 Bevatron area and the Old Town Demolition Project area (around former Buildings 5, 16, 52, and 52A), was reported to DTSC.

These areas of contamination are discussed in more detail in Section 4.2.

2.2.5 Release Reporting Requirements

If sampling results show contamination, Berkeley Lab will notify DTSC, as required by the corrective action section of LBNL’s Hazardous Waste Facility Permit or other enforceable document, concerning immediate or potential threats to human health and/or the environment, new releases of hazardous waste and/or hazardous constituents, and newly identified SWMUs.

3 Discussion of Key Terms

3.1 General Definitions

Area of Concern (AOC). A unit or area that does not meet the definition of a SWMU but that merits further investigation to determine the presence or absence of releases.

Historical Environmental Review. A review of historical information, process knowledge, and existing soil characterization data to evaluate environmental conditions, assess the potential for contamination, identify contaminants of concern (COCs), and determine whether the soil has been adequately characterized. For very small, well-understood sites, this review is commonly conducted as part of the penetration permit process. For larger or more complex projects, a more comprehensive review is conducted, which may include extensive historical research, interviews, etc.

Hot Spot. A localized area of contamination where concentrations are higher than those in adjacent areas.

LBNL Metals Background Concentrations. Background metals concentrations are presented in the Analysis of Background Distributions of Metals in the Soil at Lawrence Berkeley National Laboratory (LBNL, 2009) and are based on the use of 99th percentiles as the upper estimates of background.

Metals. The 17 metals listed in the California Code of Regulations (CCR), Title 22, Section 66261.24.

Solid Waste Management Unit (SWMU). Any unit at a hazardous waste facility from which hazardous constituents might migrate, irrespective of whether the units were intended for the management of wastes. Examples include containers, tanks, surface impoundments, waste piles, land treatment units, landfills, incinerators, and underground injection wells.

3.2 Soil Classification Definitions

For the purpose of this SMP, the following criteria are used to classify soil to determine reuse, replacement, or disposal options:

Clean Soil. Soil containing no metals at concentrations above the upper estimate of LBNL background (LBNL, 2009) and no other detectable chemical contaminants, and having radionuclide levels that are indistinguishable from background (LBNL, 2017b).

Contaminated Soil. Soil that does not meet the definition of clean soil listed above is considered to be contaminated soil. The following categories of contaminated soil are used to determine reuse and replacement options in this SMP:

• Industrial Soil. Nonhazardous contaminated soil in which concentrations of the COCs are less than or equal to the more conservative of regulatory screening levels for commercial/industrial workers, construction workers, or the groundwater leaching pathway. Metals concentrations may exceed screening levels and still be classified as “industrial” if they are below LBNL background concentrations (LBNL, 2009).

Discussion of Key Terms Soil Management Plan

• Nonhazardous Contaminated Soil. Soil containing metals at concentrations above the upper estimate of LBNL background and below State of California or federal hazardous waste levels, and/or soil containing detectable concentrations of organic contaminants below State of California or federal hazardous waste levels.

• Radiologically Contaminated Soil. Soil containing radionuclides above background levels (LBNL, 2017b).

Off-Site Disposal. The disposal of excavated waste soil at an off-site facility (typically a landfill) that possesses a current permit to accept the specific type of waste soil generated.

Residential Soil. Nonhazardous contaminated soil in which concentrations of the COCs are less than or equal to the more conservative of regulatory screening levels for residents, construction workers, or the groundwater leaching pathway. Metals concentrations may exceed screening levels and still be classified as “residential” if they are below LBNL background concentrations (LBNL, 2009).

Soil Replacement. The use of excavated industrial soil as backfill in the same excavation area from which it was removed.

Soil Reuse. The use of excavated soil as backfill at a location within the LBNL facility. Soil reuse is either restricted or unrestricted, as defined below:

• Restricted Reuse. The use of residential soil as backfill at a location within the developed areas of the LBNL facility.

• Unrestricted Reuse. The use of clean soil as backfill at a location anywhere within the LBNL facility.

The following definitions are used to classify waste soil solely for disposal purposes.

Designated Waste. Hazardous waste granted a variance under Health and Safety Code Section 25143, or nonhazardous waste that consists of or contains pollutants that under ambient environmental conditions could be released in concentrations exceeding applicable water quality objectives or could reasonably be expected to affect beneficial uses of the waters of the state.

Hazardous Waste. Waste containing chemical contaminants above State of California (“California hazardous”) or federal (“RCRA hazardous”) waste standards.

Inert Waste. A subset of solid waste that does not contain hazardous waste or soluble pollutants at concentrations in excess of applicable water quality objectives, nor does it contain significant quantities of decomposable waste.

4 Land Use and Land Use Restrictions

4.1 Land Use

Both the HHRA (LBNL, 2003a) and the CMS Report (LBNL, 2005) were developed based on the assumption that Berkeley Lab would continue to operate as a research laboratory for the foreseeable future, a scenario that is consistent with the current and reasonably anticipated future land use at Berkeley Lab. The ecological risk assessment (LBNL, 2002) is based on the assumption that the central developed area at the site does not provide suitable habitat or resources for wildlife and that ecological receptors will therefore not be exposed to the contaminants detected in the soil within the central developed area. These assumptions, which were used to assess human health and ecological risk, have been incorporated into the soil management requirements specified in this plan.

The central developed area and the open areas of the site are shown on Figure 3. The open areas are based on “rustic zones” where, as noted in Berkeley Lab’s Long Range Development Plan [LRDP] Environmental Impact Report [EIR] (LBNL, 2007a), “in general most Lab activities would not occur...” The rustic zones are shown on Figure 5, which is the Landscape Framework Plan of the EIR. Note that the open areas shown on Figure 3 have been modified from those shown in the EIR to include both areas that have been subsequently developed (construction of buildings, parking lots, construction staging areas, etc.) and to include small areas classified as rustic zones that separate the developed areas. Only clean soil may be reused in the open areas of the site. Contaminated soil may not be reused in the open areas unless, as indicated by the LRDP, those areas become subject to future development. If such development occurs, the developed areas will be considered to have been incorporated into the central developed area where restricted soil reuse is allowed.

4.2 Land Use Restrictions

In April 2007, Berkeley Lab submitted its CMI Report to DTSC (LBNL, 2007b). The report provided a summary of the DTSC-approved corrective measures that were implemented. All corrective measures that were required for contaminated soil were completed by the end of 2006, with all known locations of soil contamination acceptable for industrial land use. Concentrations of contaminants in the soil at 18 units, however, were at levels that posed potential health risks to hypothetical future residential receptors, based on the conservative evaluation of risk provided in the HHRA. In addition, concentrations of contaminants exceeded PRGs for residential soil at two LBNL construction sites (Building 56 and Building 58) and the Building 71B lobe source area, which were not evaluated in the HHRA. These 21 units are indicated in Table 1 as units restricted to industrial land use. The locations of the 21 units are shown on Figure 4.

Until a site is cleaned up to unrestricted land use standards, DTSC generally imposes specific land use restrictions where groundwater contamination exists above drinking water standards, or where residual soil contamination is above residential risk levels. UC has indicated that it is willing to voluntarily restrict use of the affected portions of designated parcels to institutional use through a land use covenant with DTSC (UC, 2004). In July 2007, at the request of the City of Berkeley, DTSC agreed to delay imposition of

Land Use and Land Use Restrictions Soil Management Plan land use restrictions at Berkeley Lab (DTSC, 2007). In its letter, DTSC acknowledged that Berkeley Lab operates within secured property boundaries and has internal procedures that control on-site subsurface activities.

Between 2010 and 2015, Berkeley Lab investigated potential subsurface contamination in and around the former Bevatron area. The Bevatron and associated research facilities were located in former Buildings 51 and 51A (Figure 1) before those buildings were demolished between 2010 and 2012.

The purpose of the investigations was to assess the Bevatron area for potential future redevelopment.

VOCs were detected in three separate areas, specified below, in soil and soil vapor at concentrations exceeding screening levels protective of human health; VOCs were also detected in groundwater at concentrations exceeding maximum contaminant levels (MCLs) for drinking water:

• The location of former Building 51A

• The former Building 51 Vacuum Pump Room/Cooling Tower area

• The former Building 51 Motor Generator Room Yard

These areas are shown on Figure 2 (location numbers 91, 92, and 59, respectively). Although the contamination poses no unacceptable risks to current site workers, soil vapor sampling results indicate a potential for health risks to future indoor workers through the vapor intrusion pathway (soil vapor migrating into indoor air) should a building be constructed over those areas.

Corrective measures requirements have not yet been established for these areas. New buildings or other improvements intended for human occupancy may not be constructed in these areas until at least one of the following conditions is met and approved by DTSC:

• A risk assessment is completed that indicates that there would be no unacceptable health risks to future building occupants.

• Mitigation methods are implemented to ensure that risks to future building occupants are within acceptable levels. Mitigation methods might include engineering controls such as installation of subslab organic-vapor barriers, lateral routing of utilities to avoid vapor barrier penetration, sealing of utility penetrations, and installation of subslab ventilation systems.

• Additional data are collected to document that risks to human health would be within acceptable levels.

In 2016, Berkeley Lab began construction of the Integrative Genomics Building in the area between the former Building 51 Vacuum Pump Room and former Building 51A. Construction of this building began after Berkeley Lab conducted a risk assessment approved by DTSC that indicated no unacceptable risk from vapor intrusion based on soil vapor sampling results.

From 2014 through early 2017, Berkeley Lab investigated potential subsurface contamination in and around Buildings 5, 16, 16A, 52, and 52A (the area known as “Old Town”) as part of the Old Town Demolition Project. During the investigations, PCBs and a minor amount of metals and petroleum hydrocarbons (but no VOCs or SVOCs commonly associated with petroleum hydrocarbons) were detected in soil at concentrations above screening levels both beneath and adjacent to these buildings.

Land Use and Land Use Restrictions Soil Management Plan

At the time of this writing, the PCB-contaminated soil is being excavated to the industrial land use level and disposed of off site in compliance with Toxic Substances Control Act (TSCA) requirements under EPA Region 9 oversight. Depending on the level of cleanup achieved, land use restrictions may be required for the PCB-contaminated area.

5 Classifying Soil for Replacement, Reuse, and Disposal

This section describes the requirements and process needed to classify soil in order to determine its disposition. Clean soil may be reused at any location at Berkeley Lab. Three options are available for disposition of contaminated soil at Berkeley Lab, based on regulatory requirements governing waste disposal and protection of human health and the environment:

• Replacement in the area where it was excavated

• Restricted reuse in the developed area of the Berkeley Lab site

• Disposal off site

5.1 Soil Disposition

For this SMP, the disposition of excavated soil at Berkeley Lab falls into one or more of the following five categories based on the volume and/or concentrations of contaminants. All soil is subject to the soil management requirements given in Section 6. Note that these categories do not apply to radiologically contaminated soil, which is subject to additional requirements (LBNL, 2017b).

• De Minimis – An excavation project in which the in situ soil excavation volume is 20 cubic yards (CY) or less in areas where there is no evidence of contamination based on historical site information and visual and olfactory indications during excavation, and the soil will be replaced in the original excavation area. Sampling is not required for de minimis excavation projects. The intent of the de minimis classification is to avoid unnecessary sampling and administrative costs for small excavations that have already been reviewed for issues related to soil contamination.

• Unrestricted Soil Reuse – Clean soil that does not contain radionuclides or metals above LBNL background levels or detectable levels of other chemical contaminants may be reused without restriction anywhere at Berkeley Lab. All unrestricted-reuse soil must be managed and placed in accordance with the procedures detailed in Sections 6.4 and 6.5.

• Restricted Soil Reuse – Residential soil (i.e., nonhazardous soil that has chemical concentrations below regulatory screening levels for residents, construction workers, and leaching to groundwater or LBNL background levels) can be reused within the central developed area of Berkeley Lab (Figure 3), including at a location other than the one from which it was excavated. All restricted-reuse soil must be managed and placed in accordance with the procedures detailed in Sections 6.4 and 6.5.

• Soil Replacement – Industrial soil (i.e., nonhazardous soil that has chemical concentrations below regulatory screening levels for industrial workers, construction workers, and leaching to groundwater or LBNL background levels) can be replaced in the same general excavation area (e.g., the same utility trench or the same building foundation excavation) from which it was removed. All replaced soil must be managed and placed in accordance with the procedures detailed in Sections 6.4 and 6.5.

• Soil Disposal – Soil that is not reused or replaced must be transported off site for disposal at a facility that possesses a current permit to accept the specific type of waste soil generated.

Permitted landfills are listed in the State of California’s Solid Waste Information System online database at www.calrecycle.ca.gov/SWFacilities/Directory.

http://www.calrecycle.ca.gov/SWFacilities/Directory

Soil Management Requirements Soil Management Plan

5.2 Data Quality Objectives Process

This SMP describes the methods for sampling and analysis of soil that will generate sufficient data to determine whether the soil is acceptable for on-site unrestricted reuse, restricted reuse, or replacement, or whether it must be disposed of off site. The determination must be compliant with RCRA, the California Hazardous Waste Control Law (27 CCR), TSCA, Berkeley Lab’s internal procedures, and the receiving facilities’ waste acceptance criteria.

EPA’s data quality objectives (DQOs) process (U.S. EPA, 2006) is used to establish performance or acceptance criteria, which serve as the basis for collecting data of sufficient quality and quantity to support the goals of a study. The following subsections describe the first six of the seven steps of the DQO process applicable to the sampling and analysis aspects of this SMP. The Plan for Obtaining the Data, the seventh step in the process, is provided in Sections 5.3 and 5.4 below.

5.2.1 Problem Statement

Define the problem that necessitates the study; identify the planning team; and examine budget and schedule.

• Describe the Problem – Berkeley Lab regularly conducts demolition and construction of new facilities, excavates trenches for installation of new utilities, and conducts other activities that generate excavated soil. Characterization of contaminants in excavated soil is required to determine the acceptable disposal, reuse, and/or replacement options for these materials.

• Establish Planning Team Following is a brief description of the team that plans and implements the requirements of this SMP. A more detailed discussion of roles and responsibilities is provided in Section 6.2.

Both the Berkeley Lab Facilities Division and the Berkeley Lab Project and Construction Group implement projects that result in excavation of soil. Both of these entities are responsible for the following tasks associated with their respective projects:

o Managing soil during most soil-generating activities, including excavating, storing, sampling, transporting, reusing or replacing, and disposing of soil off site.

o Implementing and maintaining best management practices (BMPs) in compliance with the sitewide Stormwater Pollution Prevention Plan (SWPPP) and any construction-related SWPPPs.

In addition to the above, Berkeley Lab’s Facilities Division is responsible for the following:

o Issuing Penetration Permits and inspecting sites for compliance with Penetration Permit requirements.

Berkeley Lab’s Environment, Health and Safety (EHS) Division is responsible for providing overall environmental project support and oversight for activities such as the following:

o Conducting historical environmental reviews as part of the penetration permit process.

o Assisting with soil testing and management strategies.

o Evaluating analytical results for comparison with on-site unrestricted reuse, on-site restricted reuse, on-site replacement, and off-site disposal criteria.

o Entering analytical results in the Environmental Sampling Monitoring database.

o Maintaining summary tables of analytical results and records discussed in Section 6.6.

The LBNL Projects & Construction Manager and the Facilities Division Director are responsible for the overall implementation of the SMP. The EHS Division Director is responsible for oversight of SMP compliance.

• Identify Available Resources, Constraints, and Deadlines – Berkeley Lab requests, obtains, and allocates funds to complete the characterization needed. Funds are obtained from project or overhead budgets associated with soil-generating activities, or from DOE directly. Constraints and deadlines are specific to each soil-generating activity.

5.2.2 Soil Management Plan Goals

State how environmental data will be used in meeting objectives and solving the problem; identify principal study questions; and define alternative outcomes.

The sample analytical results will be used to determine whether excavated soil is suitable for unrestricted reuse, restricted reuse, or replacement, or is required to be disposed of off site as nonhazardous waste, hazardous waste, designated waste, or PCB remediation waste, based on responses to the following questions.

1. Are sampling results at or below background levels for metals and radionuclides, and non-detect for other chemical contaminants so that the soil can be considered “clean”?

If not, proceed to question 2 below. If so, then the soil may be reused without restriction anywhere on site or disposed of off site at a facility that possesses a current permit to accept the specific type of waste soil generated.

2. Are sampling results at or below residential levels?

If not, proceed to question 3 below. If so, then the soil is considered inert waste and may be designated for restricted reuse anywhere within the developed areas of the LBNL site with certain restrictions (described in detail in Sections 6.4 and 6.5) to protect groundwater and surface water, or it may disposed of off site at a facility that possesses a current permit to accept the specific type of waste soil generated.

3. Are sampling results at or below industrial levels?

If not, proceed to question 4 below. If so, then the soil may be either replaced in the excavation area from which it originated or disposed of off site at a facility that possesses a current permit to accept the specific type of waste soil generated.

4. Are sampling results at or above hazardous waste or PCB remediation waste criteria?

If so, then the soil must be managed as hazardous waste or PCB remediation waste and disposed of off site at a facility that possesses a current permit to accept the specific type of waste soil generated.

5.2.3 Required Information

Identify data and information needed to answer the principal questions.

The following data and information are required:

• Historical information and environmental investigation data previously collected in the areas where soil is to be excavated

• Background concentrations in site soil of constituents being evaluated

• Hazardous waste threshold values

• DTSC, RWQCB, and EPA screening levels for soil and soil vapor

• Analytical results of samples collected

• Data gathered while in the field (notes, photos, etc.)

5.2.4 Study Boundaries

Specify the target population and characteristics of interest; define spatial and temporal limits and scale of inference.

The target population is the group of receptors that might be exposed to contaminants within the developed areas of Berkeley Lab. The physical study area is limited to in situ soil and stockpiles of soil generated by excavation and drilling activities conducted at Berkeley Lab. Generally, soil will be sampled on a grid, so the area of inference is the volume of soil in the grid section in which the samples are collected.

5.2.5 Analytical Approach

Define the parameter of interest, specify the type of inference, and develop the logic for drawing conclusions from findings.

The parameters of interest are the concentrations of potential contaminants, including primarily metals, PCBs, petroleum hydrocarbons in the diesel and motor oil ranges, and VOCs that may be present in media (soil and soil vapor) to be excavated.

The sample results will be used to classify the soil for either unrestricted reuse, restricted reuse, replacement, or disposal by comparing chemical constituent concentrations to the following:

• LBNL background levels

• Reuse/replacement levels derived from DTSC, RWQCB, and EPA screening levels for potential receptors relevant to the LBNL site

• Hazardous waste limits (federal and California)

A detailed discussion of the derivation of these reuse/replacement levels is provided in Section 5.3.

A description of the overall soil screening process is provided in Section 5.4.

5.2.6 Performance Criteria

Develop performance criteria for new data being collected, or acceptance criteria for existing data being considered for use.

Section 5.5 below describes sampling and analysis procedures developed to meet performance criteria.

If modifications to the collection or analysis procedures described in this plan are necessary, these changes will be evaluated for their impact on the usability of the resulting data. All data collected as part of these procedures must be compliant with the Quality Assurance Program Plan for the Lawrence Berkeley National Laboratory Environmental Restoration Program (“QAPP”) (LBNL, 2017a).

5.3 Method for Selecting Soil Classification Levels

As noted above, soil will be classified as follows:

• As clean soil suitable for unrestricted reuse – if analytical results for metals and radionuclides do not exceed background levels and it contains no other chemical contaminants

• As residential soil suitable for restricted reuse – if the results do not exceed residential concentration levels

• As industrial soil suitable for replacement – if the results do not exceed industrial concentration levels.

The specific background, residential, and industrial concentration levels selected are derived from comparison of the LBNL background criteria, regulatory screening criteria, and California and federal hazardous waste criteria shown in Table 2. These criteria are discussed below, along with how they are applied to developing the unrestricted soil reuse, restricted soil reuse, and soil replacement levels; the levels are listed in Table 3. All risk-based regulatory screening levels used to develop the reuse/replacement levels were derived from the more conservative of either a theoretical incremental lifetime cancer risk of 10–6 or a non-cancer hazard index of 1.0.

The residential concentration levels are equivalent to a residential risk scenario and are therefore protective of hypothetical future residents, construction workers, and groundwater quality. The industrial concentration levels are equivalent to an industrial risk scenario and are protective of commercial workers, maintenance workers, construction workers, on-site visitors, and groundwater quality. As shown in Table 2, criteria protective of some of these receptors apply to both industrial and residential risk scenarios.

• Soil criteria for metals, SVOCs, PAHs, pesticides, and PCBs – The restricted-reuse/replacement levels for metals, SVOCs, PAHs, pesticides, and PCBs in soil are the most stringent of the DTSC-modified screening levels (“DTSC-SLs”) (DTSC, 2017) for residents or commercial/industrial workers and the RWQCB Environmental Screening Levels (ESLs) (RWQCB, 2016) for the construction worker and groundwater leaching pathways and hazardous waste thresholds (22 CCR, Section 66261.24; and Code of Federal Regulations, Title 40, Section 261.24). For constituents with no DTSC-SL, the EPA Regional Screening Levels (RSLs) (U.S. EPA, 2017) are used instead of DTSC-SLs.

LBNL upper estimates of background metals concentrations (LBNL, 2009) are used as the restricted-reuse/replacement levels if they are higher than the aforementioned criteria for metals. However, arsenic in soil derived from rocks of the Great Valley Group has a distinctly higher upper estimate of background (42 mg/kg) than soil from the Berkeley Lab site as a whole (28 mg/kg). Therefore, the screening level for arsenic in soil that is excavated from and reused/replaced in the area of Berkeley Lab underlain by the Great Valley Group (shown on Figure 6) is 42 mg/kg. Great Valley Group soil exceeding 28 mg/kg arsenic cannot be reused outside the Great Valley Group area unless approved otherwise by the appropriate agency with environmental regulatory oversight. Soil with arsenic levels that do not exceed 28 mg/kg can be reused at any location within the Berkeley Lab site.

• Soil vapor criteria for VOCs – As described in Section 5.4.3 below, using soil vapor sampling data is a more accurate method for assessing potential indoor air risk from VOCs than using an estimate derived from soil sampling data. The residential restricted-reuse and industrial replacement soil vapor levels in Table 2 are based on DTSC-SLs and EPA RSLs for VOC concentrations in industrial or residential indoor air (DTSC, 2017). To obtain the concentration levels, the indoor air DTSC-SL or RSL for each chemical is divided by the DTSC-recommended attenuation factor (α), currently 0.0005 and 0.001 for the migration of soil vapor into future commercial and residential buildings, respectively (DTSC, 2011).

• Soil criteria for VOCs – The restricted-reuse/replacement concentration levels for VOC-contaminated soil are obtained using a methodology similar to that described above for metals, SVOCs, PAHs, pesticides, and PCBs (i.e., published screening levels). However, for VOCs, the pathway of concern for residents and commercial/industrial workers is primarily based on the vapor intrusion pathway for which no soil DTSC-SLs or RSLs exist. Therefore, alternative soil restricted-reuse/replacement concentration levels for this pathway are estimated by calculating the steady-state soil concentrations that would be in equilibrium with the soil vapor restricted-reuse/replacement levels. The concentrations in Table 2 are calculated using the soil/soil vapor partitioning equation from DTSC’s vapor intrusion guidance (DTSC, 2011) (see Appendix A).

These alternative restricted-reuse/replacement concentration levels will be used where representative soil vapor data cannot be obtained.

• Soil criteria for petroleum hydrocarbons – Since there are no RSLs for diesel- and oil-range petroleum hydrocarbons, TPH criteria are the most stringent of the RWQCB ESLs (RWQCB, 2016).

Current LBNL background criteria, regulatory screening criteria, and California and federal hazardous waste criteria for the most frequently detected chemicals at Berkeley Lab are presented in Table 2, and the reuse/replacement levels derived from them are presented in Table 3. These levels will be compared to current regulatory sources and updated to the most recent levels, if necessary, before each new project begins.

5.4 Soil Screening Process

Three steps are used to determine sampling requirements for excavated soil, as described below and summarized on the flowchart shown on Figure 7. A fourth step is used to determine the appropriate disposition of excavated soil based on the sampling results, as described below and summarized on the flowchart shown on Figure 8.

• Step 1: Complete a historical environmental review for the excavation site to assess the potential presence of chemicals of potential concern (COPCs).

• Step 2: Determine whether the project is classified as de minimis or whether sampling is required.

• Step 3: Prepare a project-specific sampling and analysis plan (SAP), if required, and collect and analyze samples.

• Step 4: Compare the chemical analytical results with clean soil, residential, and industrial reuse/replacement levels to determine whether the soil can be replaced or reused, or whether it requires off-site disposal.

These steps are discussed in more detail in the following subsections.

In addition, if sampling results show contamination, Berkeley Lab will notify DTSC as required by the corrective action section of LBNL’s Hazardous Waste Facility Permit or other enforceable document concerning immediate or potential threats to human health and/or the environment, new releases of hazardous waste and/or hazardous constituents, and newly identified SWMUs.

5.4.1 Step 1 – Historical Environmental Review

Complete a historical environmental review to assess the potential for contamination, identify COPCs, and determine whether the soil has been adequately characterized. The review will involve examining historical information, process knowledge, and existing soil characterization data.

For small, well-understood sites, this review is commonly conducted as part of the penetration permit process. For larger or more complex projects, a more comprehensive review will be conducted that may consist of extensive historical research, interviews, and the like. At a minimum, the initial review will involve examining the latest versions of Figures 9 through 12, which show the known locations of the following contaminants in soil at Berkeley Lab:

• VOCs (Figure 9)

• PCBs (Figure 10)

• petroleum hydrocarbons (Figure 11)

• PAHs, SVOCs, metal/cyanide, and pesticides (Figure 12)

The location numbers on the figures are cross-referenced to Table 1, which provides sources of information for the identified units. Reference sources include the various RFI reports (LBNL, 1994, 1995b, 2000), the HHRA (LBNL, 2003a), and the CMS Report (LBNL, 2005). Additional supporting information can be found in the RFA (LBNL, 1992). The information on Figures 9 through 12 and Table 1 will be updated periodically and published in the annual Environmental Restoration Program Progress Report, which is submitted each year to the DTSC Project Manager at the end of February.

5.4.2 Step 2 – De Minimis Project Determination

The intent of classifying projects as de minimis is to avoid expending unnecessary sampling and administrative costs for small, low-risk projects or emergency repairs requiring rapid response. Projects that will disturb 20 CY or less of soil or that involve emergency repairs (e.g., broken utilities, landslides, failed retaining walls) requiring rapid response may be classified as de minimis under the following circumstances:

• The historical environmental review indicates that the excavation area is not located in an area with known or suspected levels of contamination above industrial soil levels.

• There is no visual or olfactory evidence of contamination during excavation.

• The soil will be replaced in the same general excavation area from which it originated.

Typical de minimis projects, which do not require sampling of soil before replacement, include the following:

• Minor sidewalk or utility repairs

• Landscaping activities such as tree, shrub, or weed removal

• Installation of fence posts or signage

• Roadway asphalt pothole repair

• Potholing to locate subsurface utilities

• Installation of geotechnical soil boreholes outside of areas with known contamination

5.4.3 Step 3 – Characterize Soil

Soil is characterized to determine acceptable reuse, replacement, and disposal options. All soil characterization must be conducted under direct oversight of a California-licensed Professional Geologist (or Professional Engineer – Civil, with training and experience in environmental investigation).

Characterization must be conducted in accordance with the LBNL QAPP (LBNL, 2017a) and generally following the methodology described in the Test Methods for Evaluating Solid Waste: Physical/Chemical Methods (U.S. EPA, 2015).

Samples collected from within the soil mass (stockpile or in situ) should be either randomly located and uniformly spaced or biased toward hot spot areas if potential hot spots have been identified, based on professional judgment and available field screening indications. The volume of individual stockpiles from a discrete excavation can be combined when calculating the number of composite samples needed to characterize the excavated soil. Soil stockpiles do not need to be physically combined.

The following analytical methods will be used for soil characterization:

• VOCs using EPA Method 5035 + 8260

• PCBs using EPA Method 8082

• Total petroleum hydrocarbons (TPH) (diesel and motor oil ranges) using EPA Method 8015

• California Assessment Method (CAM-17) metals using EPA Method 6000 and 7000 series

Additional analyses (e.g., for PAHs, pesticides) may be required for specific areas where historical information indicates that those chemicals may be present.

The minimum number of soil samples to be collected for characterization is given in Table 4. Sampling design is discussed in the following subsections.

Sampling Design for Stockpiles with a Soil Volume of 100 CY or Less

For projects with a total soil volume stockpile of 100 CY or less, sampling and analytical requirements will be consistent with the LBNL QAPP, and a project-specific SAP may not need to be prepared. Samples will be analyzed for the recommended analytes based on the history of the area (refer to Step 1 – Historical Environmental Review).

Sampling Design for In Situ Soil Characterization or Stockpiles with a Soil Volume of More Than 100 CY

A project-specific SAP must be prepared when excavating more than 100 CY 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; the minimum requirements for preparing a SAP, as well as sampling and analytical requirements, are specified in the LBNL QAPP.

General Sampling Process

Stockpile samples should be collected using a methodology similar to that described in the U.S. EPA guidance manual Petitions to Delist Hazardous Waste (U.S. EPA, 1993). The stockpile will be divided into approximately equal volumes, as many as the number of samples required.