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

Does This Look Like a Hazardous Waste Site to You?

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

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

Lead Discovery Interstate 80 in Emeryville 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 Route 101 in Los Angeles  Soundwall Project near downtown  Excess material relinquished to the contractor and sent as clean fill to private land owner

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 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 Highest levels of lead associated with older roads with high traffic volume but many variables affect deposition

Lead Sample Concentration, 6 in.

Lead Sample Concentration, 12 in.

Lead Sample Concentration, 24 in.

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

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. 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.

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

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) 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: The Variance allows reuse under certain conditions:

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

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

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

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

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

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

Variance Notification Information availability: 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

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 DTSC at least 5 days prior to construction NOTIFICATION (project specific) to RWQCB at least 30 days prior to advertisement NOTIFICATION (project specific) to RWQCB at least 30 days prior to advertisement

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

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)

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. 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.

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

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

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

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

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