Site Remediation
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 Transportation Alert 30 |
Question: Are you a:
If so, the contract documents under which you’ll be working will likely require two elements. The first is submittal and approval of a Contaminated Materials Handling Plan (CMHP). This plan, required before excavation starts, is needed for the clean-up of petroleum spills, manufactured coal gas plants, metal and PCB disposal sites, and other contaminated areas. The second component is retaining a third party independent monitor to verify the proper removal and disposal of contaminants.
The items listed in the CMHP cover worker safety and the management of contaminated soils. They provide for the removal of contaminated materials, even those that extend beyond the expected limits of remediation. They list requirements for segregation, testing, storage, transportation, and disposal of contaminated soil. The plan is usually prepared by a third-party environmental specialist
retained by the Contractor.
Here are the key plan contents:
Hazardous Assessment: In this section, you’ll list the chemicals in the soil, personal protective gear needed, monitoring procedures to be used during work, the contamination level at which specific action is required, and your response if the action levels are exceeded. Emergency contacts, procedures, directions to the nearest hospital, and decontamination procedures are also listed.
Soil Segregation and Storage: This is where procedures used to segregate contaminated soil will be described. Where are intended stockpiles to be located? How will soil be moved to these locations? How will these locations be cleared and managed? Will there be dust and vapors and how will these be minimized and/or monitored?
Vapor Monitoring Plan: Petroleum vapors can impact worker health as well as migrate through the ground to create explosive conditions in buildings and utilities. To identify and mitigate this, field screening by a firm independent from the contractor is needed when working in contaminated areas, or whenever unusual or suspicious soil conditions are found. A vapor monitoring plan will detail monitoring procedures and the levels at which off-site and laboratory tests will be required. It is the primary manner by which contaminated and non-contaminated soils are segregated.
Sampling and Analysis: Since the vapor monitoring listed above only detects and measures gas concentrations, the CMHP must also identify when, how, and how many field samples will be collected and tested. The samples must be collected by someone trained in sampling protocol, chain of custody, and laboratory analysis requirements and procedures. Samples, if required, will be tested for petroleum compounds, toxicity, ignitability, pH, polychlorinated biphenyls (PCB’s), and total petroleum hydrocarbons.
Stockpile, Transportation, and Disposal: Your disposal plan, accompanied by the results of the laboratory analysis of the soil, must be reviewed and approved by the disposal facility before you may dispose of contaminated soil. This section of the CMHP will list how you will prevent water infiltration, evaporation, and spills of contaminated soil. It will detail actions to be taken if there is a soil release during loading or while in transit. It will require proof that the trucker has a waste transport permit. It will list the requirements for shipping, the hazardous waste manifest procedure, and treatment and disposal to a facility that is permitted to accept the waste.
Documentation: Lastly, the CMHP will list the documentation that is required, including advance notification letters, laboratory credentials, qualifications of people performing the work, the sampling and disposal schedule, transport identification numbers, disposal/treatment facility permits, and a host of other items.
Since most designs reference NYSDOT Standard Specifications, you can find more information in Section 205, Contaminated Materials.
Summary: Given the complexity of dealing with contaminated soils, it’s best to hire a qualified third party to prepare your Contaminated Materials Handling Plan. This person will oversee the segregation and storage of contaminated materials, screen soil using field vapor monitoring equipment, direct the sample and analysis of soils, oversee the transport and disposal of contaminated soil, and ensure that your documentation is complete.
If you’re in need of a third party monitor, site assessments, spill response, or bioremediation, please contact environmental specialists Frank Thomas or Joseph Dorety at 585-334-1310.
- Contractor undertaking petroleum-related site remediation work,
- Owner who is contemplating hiring a contractor for this work, or a
- Public agency adding petroleum-related site remediation to your bid documents?
If so, the contract documents under which you’ll be working will likely require two elements. The first is submittal and approval of a Contaminated Materials Handling Plan (CMHP). This plan, required before excavation starts, is needed for the clean-up of petroleum spills, manufactured coal gas plants, metal and PCB disposal sites, and other contaminated areas. The second component is retaining a third party independent monitor to verify the proper removal and disposal of contaminants.
The items listed in the CMHP cover worker safety and the management of contaminated soils. They provide for the removal of contaminated materials, even those that extend beyond the expected limits of remediation. They list requirements for segregation, testing, storage, transportation, and disposal of contaminated soil. The plan is usually prepared by a third-party environmental specialist
retained by the Contractor.
Here are the key plan contents:
Hazardous Assessment: In this section, you’ll list the chemicals in the soil, personal protective gear needed, monitoring procedures to be used during work, the contamination level at which specific action is required, and your response if the action levels are exceeded. Emergency contacts, procedures, directions to the nearest hospital, and decontamination procedures are also listed.
Soil Segregation and Storage: This is where procedures used to segregate contaminated soil will be described. Where are intended stockpiles to be located? How will soil be moved to these locations? How will these locations be cleared and managed? Will there be dust and vapors and how will these be minimized and/or monitored?
Vapor Monitoring Plan: Petroleum vapors can impact worker health as well as migrate through the ground to create explosive conditions in buildings and utilities. To identify and mitigate this, field screening by a firm independent from the contractor is needed when working in contaminated areas, or whenever unusual or suspicious soil conditions are found. A vapor monitoring plan will detail monitoring procedures and the levels at which off-site and laboratory tests will be required. It is the primary manner by which contaminated and non-contaminated soils are segregated.
Sampling and Analysis: Since the vapor monitoring listed above only detects and measures gas concentrations, the CMHP must also identify when, how, and how many field samples will be collected and tested. The samples must be collected by someone trained in sampling protocol, chain of custody, and laboratory analysis requirements and procedures. Samples, if required, will be tested for petroleum compounds, toxicity, ignitability, pH, polychlorinated biphenyls (PCB’s), and total petroleum hydrocarbons.
Stockpile, Transportation, and Disposal: Your disposal plan, accompanied by the results of the laboratory analysis of the soil, must be reviewed and approved by the disposal facility before you may dispose of contaminated soil. This section of the CMHP will list how you will prevent water infiltration, evaporation, and spills of contaminated soil. It will detail actions to be taken if there is a soil release during loading or while in transit. It will require proof that the trucker has a waste transport permit. It will list the requirements for shipping, the hazardous waste manifest procedure, and treatment and disposal to a facility that is permitted to accept the waste.
Documentation: Lastly, the CMHP will list the documentation that is required, including advance notification letters, laboratory credentials, qualifications of people performing the work, the sampling and disposal schedule, transport identification numbers, disposal/treatment facility permits, and a host of other items.
Since most designs reference NYSDOT Standard Specifications, you can find more information in Section 205, Contaminated Materials.
Summary: Given the complexity of dealing with contaminated soils, it’s best to hire a qualified third party to prepare your Contaminated Materials Handling Plan. This person will oversee the segregation and storage of contaminated materials, screen soil using field vapor monitoring equipment, direct the sample and analysis of soils, oversee the transport and disposal of contaminated soil, and ensure that your documentation is complete.
If you’re in need of a third party monitor, site assessments, spill response, or bioremediation, please contact environmental specialists Frank Thomas or Joseph Dorety at 585-334-1310.
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