Lead in Sediment Next to California Freeways, Identification and Waste Management Options

1. Lead in Sediment Next to California Freeways, Identification and Waste Management Options Based on a presentation originally prepared by Julia Turney and Marge Rouch UPDATED 4/2007 KC

2. Does This Look Like a Hazardous Waste Site to You?

3. Topics of Discussion • Where lead comes from and how lead levels are identified • Characteristics of lead next to freeways • Regulatory requirements • Variance • Designing for lead

4. Where Lead Comes From • Leaded Gasoline • Lead in yellow traffic paint and sand blast waste • Urban industry • Tire balance weights • Imported candy wrappers • Pesticides

5. Lead Discovery • Interstate 80 in Emeryville • Project to add traffic lanes to freeway • Excess material relinquished to the contractor and sent as clean fill to Chevron • Rejected as Calif. Hazardous Waste • Route 101 in Los Angeles • Soundwall Project near downtown • Excess material relinquished to the contractor and sent as clean fill to private land owner

6. Characteristics of Lead in Sediment • High total lead at surface next to edge of the pavement, generally decreasing with depth and distance from the road • Highest levels of lead associated with older roads with high traffic volume but many variables affect deposition

7. Lead Sample Concentration, 6 in.

8. Lead Sample Concentration, 12 in.

9. Lead Sample Concentration, 24 in.

10. Regulatory Requirements • Title 22 CCR defines a waste is a material that is discarded or relinquished or treated in a manner constituting disposal • Title 23 CCR regulates placement of waste in landfills

11. Regulatory Requirements cont’ • Waste is Hazardous by Ca law if total lead levels are greater than 1000mg/kg or soluble lead by Waste Extraction Test is greater than 5mg/l. A fed waste is greater than 5mg/l soluble by the TCLP test.

12. Regulatory Requirements cont. • Cal OSHA (Title 8 CCR) and Fed OSHA regulate Lead in Construction • Adding traffic lanes usually involves excavating about 2 feet of sediment for the new pavement section. Soundwalls require excavation for foundations

13. Variance • Caltrans applied for and received a Variance from Title 22 regulations to allow stockpiling, transporting, and reuse of sediment with hazardous levels of lead for seven Caltrans Districts (4,6,7,8,10,11,12) • The Variance allows reuse under certain conditions:

14. Variance cont. • Less then 50 mg/l soluble lead (DI WET) & Less then 3397 mg/kg total lead • 5 feet above groundwater • Use of non-hazardous cover soil or pavement • Use of special provisions to direct and control the contractor • Notification and inspection by Dept. of Toxic Substances Control • Out of 100 year flood plains

15. Variance: To Reuse Lead Soils as Fill Materials • Existing variances are in effect until June 30, 2008. • Notification to regional water quality control board 30 days prior to advertisement is required. • RWQCB can take 180 days to issue WDR when they determine they are necessary.

16. Variance cont. • Placement on other projects in corridors. The regulatory definition of “corridors” is DIFFERENT from traditional Caltrans definition of a highway corridor

17. Major Conditions of Variance Use: • Hazardous waste soils not addressed under variance are to be handled as a hazardous waste • Manage soils based on lead levels • One foot non-hazardous cover • Under hard (asphalt) cover • Implement Health and Safety procedures to protect workers and public to eliminate or minimize exposure

18. Conditions of Variance Use cont. • Hazardous waste soils must stay within designated right of way corridor, stockpiling included. Reasonable allowances for transportation • Soils not buried not allowed to be in contact with groundwater, within 10 feet of culverts, stored in low areas subject to flooding, and protected from runoff to storm drains • Changes in placement, quantities or protection measures (field changes) from plans noted in RE log within 5 days of field change

19. Reuse Based on Total and Extractable Lead Hazardous Waste >1000 mg/kg Total or > 5.0 mg/l Soluble Reusable Soil >1000 mg/kg Total >5mg/l Soluble Surplus Soil >1000 mg/kg Total >5 mg/l Soluble 1’Cover with Non-Haz Soil, 5’ Above groundwater Under pavement if DI WET is high. Class 1 Disposal

20. Variance Notification • Information availability: • Current fact sheets placed in the Caltrans RE Office/District Offices • If additional projects are identified that are not in initial public notification - District must notify public via a notice in newspaper

21. Variance Notification cont. • Comply with all applicable State policies for SWRCB, RWQCB related to waste discharges to land • Dust must be controlled • NOTIFICATION (project specific) to DTSC at least 5 days prior to construction • NOTIFICATION (project specific) to RWQCB at least 30 days prior to advertisement

22. Variance Notification cont. • Plan drawing designating limits of the corridor where lead-contaminated soils will be excavated, stockpiled, buried and covered • Name and telephone number of project resident engineer(s) • Summarize excavation quantities • Special Provisions for project specific area, soil excavation, transport and placement

23. Variance Notification cont. • List of Caltrans contractors (general) for each Caltrans project conducting any phase of work under the variance • Duration of corridor construction • Location of sampling/analytical data is located ( e.g. particular project file)

24. New Variance Notification Requirement • Type of environmental document for each project, date of adoption,document title,Clearing House number and where the document is available for review. A copy of the Notice of Exemption for any project shall be sent with the notification.

25. Special Provisions • Major areas of importance: • Health and Safety Plan (Lead Compliance Plan) • Work Plan for handling and stockpiling materials with hazardous levels of lead • No visible dust, water truck available at all times while performing earthwork, excavation or grubbing in lead areas • Bill of Lading

27. Additional Public Notice - Suggested by DTSC • If residential area or areas of potential public relations problems - additional public notice is advised; District’s call

28. DTSC Role: • Tracking of materials • Enforcement requests for inspection from DTSC headquarters • Inspections by Regional DTSC offices

29. Some Basic Concepts of Handling/Placement: • If at all possible reuse soils on the project, surplus can be a major problem • Separate layers of materials to alter volumes and/or make non-hazardous • Embankment fill, contouring- fill-in areas, creating mounds etc. • Roadbase fill, excavate clean and replace with contaminated

30. Some Basic Concepts of Handling/Placement cont. • Raise grades, e.g. Park and Ride lots • Behind retaining walls • Surcharge for future sites, i.e. on other projects