Due Diligence/Management of Fill - APC Diligence/Management of Fill • Pennsylvania Department of Environmental Protection (PADEP) in 2004 initially developed the Management of Fill

Due Diligence/Management of Fill

• Unanticipated discoveries of contaminated soils, groundwater and Underground Storage Tanks (USTs)

• Documentation of these discoveries• Management of Fill• Contaminated Soils Removal



• Soil has petroleum odor• Groundwater has oily sheen• Construction equipment strikes

Underground Storage Tank (UST) System



SR 202, Sect. MS1 – Borough of Bridgeport, Montgomery County

• Unless this condition was anticipated, STOP WORK in this area until Environmental Unit has been contacted

• Contact Robert Eppley, Environmental Manager at (610)205‐6713; Dave Fischer, Assistant Environmental Manager at (610)205‐6851 or Mark Radatti at (610)205‐6710

• Conditions may be assessed via use of a project environmental services contractor or Environmental Unit’s use of Rapid Response Vehicle of Statewide Environmental Services contract (Skelly & Loy)


Rapid Response deployment within 24 hours, if needed, for:•Assessment of Site Conditions due to suspect contaminated soil or groundwater•Underground Storage Tank removals and soil remediation•Soil testing and Management of Fill•Asbestos Containing Material (ACM) testing and abatement in buildings and bridge structures•Lead/Heavy Metals‐Based Paints Surveys


• Outlined in PennDOT Publication 281, Appendix D• Can either involve environmental studies during

Project Design or to note changing conditions in the Construction Phase using the EDD VI form.

• Some form of EDD should be performed prior to Construction Phase during Environmental Clearance process

• EDD VI Form is primarily used when fill is being removed from the Site or brought on Site


• Phase I EDD results in evidence of a spill or release of a regulated substance, a Phase II EDD is required

• Phase II determines if a spill or release has actually occurredo Materials must be sampled in accordance

with PADEP Management of Fill Guidance





• Performance of record search via PADEP Regional Offices• Performance of Environmental Database search

o PADEP eFacts/eMapPAo EPA Enviromappero Underground Storage Tank/Leaking Underground Storage

Tank registries• Aerial mapping• Historic mapping (Sanborn)• Interviews with former/current property owners and public

officials


• Soil sampling is not required unless EDD provides reason for further investigation

• The Department will not pay for investigational sampling without a contract work authorization

• The Department is considering a Project Special Provision with a pay item to cover costs for lapses in EDD reporting for soils testing/management of fill



SR 23, Sect. 99S – Borough of West Conshohocken, Montgomery County


• Pennsylvania Department of Environmental Protection (PADEP) in 2004 initially developed the Management of Fill Policy from its 1996 Clean Fill Policy to include definitions and procedures for the Management of Fill.

• Policy was updated in 2010• Procedures will determine whether fill is Clean Fill,

Regulated Fill or is to be managed as a municipal/residual waste, as per PA Solid Waste Management Act.


• Clean Fill• Historic Fill• Regulated Fill• Residual Waste• Uncontaminated Material


• Clean Fill ‐ Uncontaminated, nonwater‐soluble, non‐decomposable inert solid material. The term includes soil, rock, stone, dredged material, used asphalt, and brick, block or concrete from construction and demolition activities that is separate from other waste and recognizable as such. (25 Pa. Code §§ 271.101 and 287.101) Further, the concentrations of regulated substances cannot exceed the values in Table FP‐1a and b (Clean Fill tables).

• Historic fill ‐Material (excluding landfills, waste piles and impoundments) used to bring an area to grade prior to 1988 that is a conglomeration of soil and residuals, such as ashes from the residential burning of wood and coal, incinerator ash, coal ash, slag, dredged material and construction and demolition waste. The termdoes not include iron or steel slag that is separate from residuals if it meets the coproduct definition and the requirements of 25 Pa. Code § 287.8. The term does not include coal ash that is separate from residuals if it is beneficially used in accordance with 25 Pa. Code §287.661 ‐ 287.666.


• Regulated Fill ‐ Soil, rock, stone, dredged material, used asphalt, historic fill, and brick, block or concrete from construction and demolition activities that is separate from other waste and recognizable as such that has been affected by a spill or release of a regulated substance and the concentrations of regulated substances exceed the values in Table FP‐1a and b (Clean Fill Concentration Limits tables).

• Uncontaminated Material ‐Material unaffected by a spill or release of a regulated substance, or if affected by a spill or release, the concentrations of regulated substances are below the concentrations specified in Table FP‐1a and b (Clean Fill Concentration Limits tables).


• Residual Waste – Material that meets criteria of Regulated Fill that is separate from other waste and recognizable as such that has been affected by a spill or release of a regulated substance and further the concentrations of regulated substances exceed the values in Table GP‐1a and b (Regulated Fill Concentration Limits tables), as found in the General Permit WMGR096—General Permit for Processing/Beneficial Use of Residual Waste.


• Hazardous Waste – a solid waste that may cause or significantly contribute to human health or the environment when improperly managed. Solid waste means any garbage, refuse, sludge and other discarded material, including solid, liquid, semi‐solid or contained gaseous material. There are listed hazardous wastes and characteristic wastes, identifiable by their flammability, corrosiveness, reactivity or toxicity.

Source: Industrial Safety: Management & Technology, David A. Colling, 1990.


• All regulated substances are reported as non‐detect OR detected below Clean Fill levels (DEP Table FP‐1a/1b) – Clean Fill

• Any regulated substance detected exceeds Clean Fill limits, but are below Regulated Fill limits (DEP Table GP‐1a/1b from WMGR096) –Regulated Fill

• Any regulated substance detected exceeds Regulated Fill limits – Residual Waste




• Methods of Sampling• Number of Samples determined by Sampling Method &

Volume of Soil Being Evaluated


• Methods of Samplingo Discrete Sampling – Samples are gathered

from multiple locations from a pile of soil, then mathematically averaged

o Composite Sampling‐multiple individual or "grab" samples (from different locations or times) are physically combined and mixed into a single sample so that a physical (rather than mathematical) averaging takes place


• Composite Sampling: Number of Samples determined by Volume of Soil Being Evaluatedo ≤125 yd3 – total of 8 samples – additional requirements

for various analytes

o >125 yd3 and ≤3,000 yd3 – total of 12 samples –additional requirements for various analytes

o 12 samples for each additional 3,000 yd3


• Discrete Sampling:o ≤125 yd3 – minimum of 8 samples – additional

requirements for various analytes

o >125 yd3 and ≤3,000 yd3 – minimum of 12 samples –additional requirements for various analytes

o 12 samples minimum for each additional 3,000 yd3 –additional requirements for various analytes

• Regulated Fill can be used onsite with PennDOT PM approval

• Incorporate/transfer to another project with a DEP General Permit WMGR096 (Beneficial Use of Regulated Fill)

• For disposal, waste must be transported offsite by a certified waste hauler to a certified disposal facility (as per PA Solid Waste Management Act)



• Depends how facilities are permitted by PADEPo Some may accept Clean Fill only, others can accept

residual waste – facilities will provide sampling requirements

o Soils that are contaminated with petroleum products can be sent to a thermal recycling facility

o Not all facilities will accept hazardous waste

PennDOT Construction Winter School

Documents

Due Diligence/Management of Fill - APC Diligence/Management of Fill • Pennsylvania Department of Environmental Protection (PADEP) in 2004 initially developed the Management of Fill